“The most basic obligation in family law is the duty to disclose financial information. This requirement is immediate and ongoing. The failure to abide by this fundamental principle impedes the progress of the action; causes delay; disadvantages the opposing party; and impacts on the administration of justice. Unnecessary judicial time is spent and the final adjudication is stalled: see Roberts v. Roberts, 2015 ONCA 450, 65 R.F.L. (7th) 6.
Indifference or willful blindness to the most basic disclosure obligations is more than a nuisance or irritant. Such contemptuous behaviour undermines the integrity of the court process and public confidence in our system. To the extent that inadequate disclosure creates a strategic advantage — by causing delay, frustration and needless expense for the opposing party — the court has both an obligation and a self-interest to severely sanction such mischief: see Benzeroual v. Issa and Farag, 2017 ONSC 6225, 97 R.F.L. (7th) 111.”