What is the meaning of the term "wage or salary continuation plan"?

New Brunswick, Canada


The following excerpt is from Co-Operative Fire & Casualty Co. v. Sweet, 1983 CanLII 2955 (NB CA):

While I would not put it quite that way, I think the trial judge is substantially right. Many employers provide for the continuation of all or part of their employees' remuneration for some time during disability, whether or not the cause of disability is related to their employment. That type of scheme would be the first to spring to mind as being comprised in the expression "wage or salary continuation plan". It may well be confined to such arrangements in this policy. The expression appears to connote the continuation of the wages or salary themselves. Besides, as Spence J., dissenting, in Madill v. Chu (1976), 1976 CanLII 32 (SCC), 71 D.L.R. (3d) 295 at p. 302, [1977] 2 S.C.R. 400 at p. 405, [1977] I.L.R. para. 1-810, has stated, "apart altogether from the contra proferentem rule, it is sound construction of a contract to construe the provision thereof broadly and the exclusions thereof narrowly".

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