According to Drost L.J.B.C. in Gill v. Insurance Corporation of British Columbia, [1989] B.C.J. No. 1417: A willful act may be described as one done intentionally, knowingly, and purposely, without justifiable excuse, as distinguished from an act done carelessly, thoughtlessly, heedlessly or inadvertently. A willful act differs essentially from a negligent act. The one is positive and the other negative.
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