In a personal injury action brought by the husband against the husband's father for non-disclosure of the husband’s financial affairs, what is the impact of the disclosure guidelines?

Manitoba, Canada


The following excerpt is from Welcher v. Welcher, 2001 MBCA 36 (CanLII):

18 As was the situation in the Bates v. Welcher case, these requests for financial disclosure were brought before any discovery had taken place. There is no evidence in this case of unreasonable expenses, or a lifestyle inconsistent with the amounts disclosed on the income tax return. There was no evidence which would contradict the affidavits indicating the husband’s father had sole control over the financial affairs of the corporation. Consequently, for the same reasons expressed in that decision, I would dismiss this appeal with respect to the issue of disclosure in relation to the Manitoba guidelines.

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