What is the applicable standard of proof in the defence of fraud and arson?

In Edwards v. Insurance Corporation of British Columbia, [1995] B.C.J. No. 2091, by Holmes J. of this court put it in this way: The defences of fraud and arson are of the most serious allegations that can arise in civil proceedings. The standard of proof to be applied is a balance of probabilities (Haines v. Wawanesa, 1963 CanLII 1 (SCC), [1963] S.C.R. 154), however, the degree of proof will vary with the gravity of the allegations contained in the defence to the action. Mr. Justice Macfarlane in Hanlon v. The Insurance Corporation of British Columbia, [1983] B.C.J. No. 675 (B.C.C.A.), considered the applicable standard and summarized it as: I do not question for a moment that the standard of proof is proof on a balance of probabilities, but the degree of proof required to meet that standard varies with the gravity of the offence involved in the defence of the civil action ... and with the seriousness of the consequences of such a finding.