In a common law misrepresentation claim, does reliance need to be an essential element?

In this case, the plaintiff cites many of the authorities that were referred to by Rady J. in McCann v. C.P. Ships in support of the proposition that Canadian and common law courts have recognized that reliance per se is not an essential element of a common law misrepresentation claim and that the plaintiff need simply establish that the impugned statements caused the plaintiff to sustain damage. The plaintiff’s counsel says “If causation can be established by some means other than reliance, then the plaintiff can state a valid cause of action.”

In my respectful view, some of the authorities referred to by the plaintiff are not cases of negligent misrepresentation – as Van Rensburg J. pointed out at para. 73 of Silver v. Imax - Certification, they are cases of negligence or negligent mis-statement where the mis-statement had been made to someone other than the plaintiff, but the plaintiff suffered damages as a result.