What is the test for wilful blindness in the context of a motion for personal injury?

Canada (Federal), Canada

The following excerpt is from Gallery v. The Queen, 2008 TCC 583 (CanLII):

In examining this issue I must also consider whether the conduct of the Appellant amounted to wilful blindness. As stated by Nadon J.A. speaking for the court in Panini v. Canada[15]: . . . Consequently, the law will impute knowledge to a taxpayer who, in circumstances that dictate or strongly suggest that an inquiry should be made with respect to his or her tax situation, refuses or fails to commence such an inquiry without proper justification.

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