What is the current state of the law on third party claims for declaratory relief under Rule 22(1)(c)?
British Columbia, Canada
The following excerpt is from Northmark Mechanical Systems Inc. v. Watson (Estate), 2009 BCSC 1237 (CanLII):
There need not always be a lis between the defendant and the third party. In Rurka v. JLG Industries Inc. (1999), 30 C.P.C. (4th) 34 (B.C.S.C.), Holmes J. described the law with respect to third party claims for declaratory relief under Rule 22(1)(c):
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