In Stingelin Estate v. Woods (Ont CA, 2026) the Ontario Court of Appeal dismissed an appeal, here brought against "an order granting summary judgment dismissing [SS: the appellant's] negligence and breach of fiduciary duty claims against the respondent, a lawyer retained to prepare the will of his aunt".
Here the court considered the basics of an ad hoc fiduciary relationship:
3. Fiduciary duty
[28] The appellant also alleges an ad hoc fiduciary relationship.
[29] Such a relationship requires an undertaking to act in the claimant’s best interests and defined beneficiaries vulnerable to the fiduciary’s discretionary power affecting their legal or substantial practical interests: Alberta v. Elder Advocates of Alberta Society, 2011 SCC 24, [2011] 2 S.C.R. 261, at paras. 30-36.
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