Does a project manager have a role in the construction of a project if they are a supervisor or a manager?

Ontario, Canada


The following excerpt is from B.I.L.D.O.N. Construction (801) Inc. v. Project 801 Inc., 2011 ONSC 4169 (CanLII):

28. Further, in the paragraph 20, I specifically adopted the finding of Zelinski J. in Marino v. Bay-Wash Ltd. [2002] OJ No 2211 at paragraph 111 where he stated: Project managers whose responsibilities, whether on site or off, contributed “in a direct and essential way to the construction of [the] improvement” are persons who have supplied services “to the improvement” whether or not the services are supervisory, managerial, physical or manual. To-day, I do not resile from that finding, and I find it to be equally applicable to the issues before me.

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