Does the Applicant have to accept the value of the Respondent's undisclosed assets?

[24] The Applicant’s counsel also referred to Burnett v. Burnett, [1999] O.J. No. 3063 at paragraph 9 (S.C.J.). There, the respondent husband had adopted an obstructive stance, refusing to provide meaningful disclosure of assets apparently worth millions of dollars. He had only made limited and selective financial disclosure, and refused to answer relevant questions about his financial affairs. The court held that a party who refuses to co-operate, or who obstructs, should be regarded with great scepticism and should not be rewarded for his antagonistic stance. It therefore accepted the applicant’s limited evidence of the high value of the respondent’s undisclosed assets. In our case, the applicant’s counsel suggested that the respondent had not met his obligation to provide realistic and accurate valuations of many items of property in his possession, especially chattels, and it would therefore be unjust to accept his values because that would penalize the applicant who, he submitted, had taken much greater care. (d) Valuation of Chattels