Does the tort of intentional inflection of mental suffering have any place in family law proceedings?

British Columbia, Canada


The following excerpt is from Fan v. Zhang, 2015 BCSC 2352 (CanLII):

Finally the tort of intentional inflection of mental suffering has no place in family law proceedings: Frame v. Smith, 1987 CanLII 74 (SCC), [1987] 2 S.C.R. 99. Counsel for the respondent could provide no authority to the contrary. As a result, para. 5 of the respondent’s counterclaim is struck.

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