12 As to the issue of conditions precedent, there are basically two types of conditions precedent. A true condition precedent is simply an external condition, the happening of which depends entirely on the will of a third party (Turney v. Zhilka, 1959 CanLII 12 (SCC), [1959] S.C.R. 578 at 583. The other type of condition may be referred to either as merely a "condition precedent" or as a "promissory condition".
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