Does the parol evidence rule extend to cases where a document may not embody all the terms of the agreement?

British Columbia, Canada


The following excerpt is from Honey v. Star-FM Radio Inc., 2000 BCSC 832 (CanLII):

In Gallen v. All State Grain Co., referred to above, which case is also referred to as Gallen v. Butterley et al, Lambert, J.A. said, with respect to the parol evidence rule: So the rule does not extend to cases where the document may not embody all the terms of the agreement. And even in cases where the document seems to embody all the terms of the agreement, there is a myriad of exceptions to the rule.

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