This simple point was made clearly by Major J. in Patterson v. Gallant, 1994 CanLII 45 (SCC), [1994] 3 S.C.R. 1080, at para. 35: Where the policy simply expires because of the non-payment of the renewal premium, no formal termination procedure need be followed by the appellant.... In the absence of legislation to the contrary, which does not exist in this case, a lapsed policy does not need to be formally terminated.
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