Can Rule 21-1 apply to in rem proceedings other than Admiralty matters?

British Columbia, Canada


The following excerpt is from British Columbia (Director of Civil Forfeiture) v. Violette, 2014 BCSC 1520 (CanLII):

In that regard I must also note that I have considered the decision of the master in Director of Civil Forfeiture v. Ngo, 2011 BCSC 1191 [Ngo], and have not followed comments made at para. 16 in which the master said that Rule 21-1 could apply to in rem proceedings other than Admiralty matters. Those comments were not only obiter dicta but were delivered in a case where no argument contrary to that presented by counsel for the Director was made because the application for forfeiture of monies was not defended.

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