“In Akagi v. Synergy Group (2000) Inc, 2015 ONCA 368 the Ontario Court of Appeal confirmed that the mandate of a receiver appointed under section 101 of the Courts of Justice Act can in appropriate cases include an investigation. As Blair J.A. stated:
Indeed, whether it is labelled an “investigative” receivership or not, there is much to be said in favour of such a tool, in my view – when it is utilized in appropriate circumstances and with appropriate restraints. Clearly, there are situations where the appointment of a receiver to investigate the affairs of a debtor or to review certain transactions – including even, in proper circumstances, the affairs of and transactions concerning related non-parties – will be a proper exercise of the court’s just and convenient authority under section 101 of the Courts of Justice Act: Agaki, at para. 66”