January 3, 2025 – Section 55(1), Family Law Act

“With respect to the appellant’s first ground of appeal, the video recording made by the appellant confirmed the respondent’s acknowledgement that he had signed the August 2 Document. However, the purpose of the formal requirements in s. 55(1) of the FLA is not just to “provide proof that [a document] was in fact signed by the parties”, but also to “ensure a measure of formality in the execution of a domestic contract”, and to “avoid ‘kitchen table’ agreements”: Gallacher, at para. 24 (citations omitted). As Pepall J.A. explained in Virc v. Blair, 2014 ONCA 392, 119 O.R. (3d) 721, at para. 78:

The purpose of this provision is in part to provide some assurance that the parties were deliberate in reaching their agreement and understood the obligations being imposed: see A. Swan & J. Adamski, Canadian Contract Law, 3rd ed. [Toronto: LexisNexis Canada Inc., 2012], at para. 5.50.”

              El Rassi-Wright v. Arnold, 2024 ONCA 2 (CanLII) at 14

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