Does writing on a document fall within the definition of "entry in a book or record"?

British Columbia, Canada


The following excerpt is from Animal Welfare International Inc. v. W3 International Media Ltd., 2013 BCSC 989 (CanLII):

This submission suggests that any writing on a document falls within the definition of “entry in a book or record” for the purposes of the section. However, a more limited definition of the phrase was adopted in Minister of National Revenue v. Furnasman Ltd., [1973] F.C. 1327 (T.D.) in which Addy J. held at para. 20: In so far as section 29(1) is concerned the word “entry” in the expression “entry in any book or record” means an ordinary financial or bookkeeping entry, that is, the figures and the required explanation for such figures, in a ledger, book, card system or computer card system. In my view, it is intended to cover primarily the bookkeeping type of information or, in other words, the debit, credit or balance type of entry with the required explanatory words to identify or clarify the entry. It does not, in my view, cover such things as interoffice memos or written reports between branches of an organization such as in the present case.

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