The following excerpt is from Abrasive Engineering & Manufacturing, Inc. v. Cowan & Stevens Machinery Sales, Ltd., 2003 CanLII 8979 (ON SC):
The parties agree that the leading case on equitable set-off in Canada is Holt v. Telford, 1987 CanLII 18 (SCC), [1987] 2 S.C.R. 193 and both commend the recent decision of Justice Lane in Cuddy Food Products v. Puddy Bros. Ltd., [2002] O.J. No. 3181 as thoughtfully considering the cases applying Holt v. Telford.
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