The case of Whiten v. Pilot Insurance Co., [2002] 1 S.C.R. 515 has been given wide attention in the legal profession in Canada and among other matters, stands for the proposition that consent on the part of the insurer cannot be unreasonably withheld and failure to consent to a reasonable resettlement can constitute an independent bad faith action, exposing the insurer to punitive damages in certain circumstances (see p. 639.)
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