What is the test for punitive damages for a breach of contract?
Ontario, Canada
The following excerpt is from Randy River Inc. v. Mint Accessories Inc., 2018 ONSC 1215 (CanLII):
Punitive damages are not recoverable for a breach of contract unless the conduct constituting the breach is also an independent actionable wrong: Vorvis v. Insurance Corporation of British Columbia, 1989 CanLII 93 (SCC), 1989 CarswellBC 76 at para. 25.
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