Moran v Pyle National (Canada) Ltd

Moran v Pyle National (Canada) Ltd is a landmark Canadian case in the area of conflict of laws, specifically concerning the determination of jurisdiction in tort cases. The case, decided by the Supreme Court of Canada in 1975, established the "real and substantial connection" test for asserting jurisdiction over out-of-province defendants.

Prior to Moran, Canadian courts often relied on a "doing business" test to determine whether they had jurisdiction over foreign corporations. Moran shifted the focus to whether there was a real and substantial connection between the defendant, the cause of action, and the forum province. This meant that even if a defendant didn't actively conduct business within a province, the province's courts could still assert jurisdiction if the tort occurred there, or if the defendant's actions elsewhere had a direct and foreseeable impact within the province.

The facts of the case involved a fatal accident in Saskatchewan caused by an allegedly defective lamp manufactured by Pyle National (Canada) Ltd, a company based in Ontario. The plaintiff, the widow of the deceased, sued Pyle National in Saskatchewan. The Supreme Court of Canada held that the Saskatchewan court had jurisdiction because there was a real and substantial connection between the defendant and the province. The court reasoned that Pyle National, as a manufacturer, knew or ought to have known that its lamps would be used in vehicles operating throughout Canada, including Saskatchewan, and that a defect in a lamp could cause harm in that province.

The Moran test has been influential in shaping Canadian jurisdictional jurisprudence. It recognizes the increasingly interconnected nature of modern commerce and the need for courts to have the power to adjudicate disputes where the harm is felt, even if the defendant is not physically present within the jurisdiction. While subsequent cases have refined and clarified the "real and substantial connection" test, Moran v Pyle National (Canada) Ltd remains a foundational precedent in Canadian conflict of laws.