In The Law of Limitations, 2nd Edition, (Mew), page 177, there is the following: 5.3 Payment of Periodical Benefits Where benefits are payable periodically, a new cause of action may arise at the end of each period. In Zigouras v. Royal Insurance Co. of Canada, weekly benefits were payable within 30 days after receipt by the insurer of proof of claim. A one-year limitation period applied to the bringing of an action against the insurer for non-payment of benefits. It was held that at the end of each 30-day period a right of action accrued. Accordingly, even though time had passed for recovering some weekly payments, all those accruing less than a year and 30 days prior to commencement of proceedings could be recovered.
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