What is the test for a finding of jurisdictional fraud?

British Columbia, Canada

The following excerpt is from Lang v. Lapp, 2009 BCSC 638 (CanLII):

I bear in mind that even when considering an allegation of jurisdictional fraud, as opposed to fraud going to the merits, the domestic court should be reluctant to make a finding of fraud: Powell v. Cockburn, 1976 CanLII 29 (SCC), [1977] 2 S.C.R. 218. Caution is particularly apt where the defendants ask this court to make findings of fraud, or to draw inferences of misconduct, based on what counsel did and did not say in two brief passages extracted from the transcript of the foreign proceedings.

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