In United Savings Credit Union v. F & R Brokers Inc. et al, 2003 BCSC 640, Burnyeat J., after discussing the evolution of the English practice and subsequent Canadian law, concluded, at para. 15: I am satisfied that, unless the mortgagor or charge holder can show that extraordinary circumstances are present, the appointment of a Receiver or Receiver Manager at the instigation of a foreclosing mortgagee should be made as a matter of course if the mortgagee can show default under the mortgage.
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