“The case law establishes that the threshold to prove that an agreement was made under duress is high. In Ludmer v. Ludmer, 2013 ONSC 784, 33 R.F.L. (7th) 331, Penny J. states at para. 53:
Duress involves a coercion of the will or a situation in which one party has no realistic alternative but to submit to pressure. There can be no duress without evidence of an attempt by one party to dominate the will of the other at the time of the execution of the contract. To prove duress, the applicant must show that she was compelled to enter into the marriage contract out of fear of actual or threatened harm of some kind. There must be something more than stress associated with a potential breakdown in familial relations. There must be credible evidence demonstrating that the complaining party was subject to intimidation or illegitimate pressure to sign the agreement.”