In general, tortious conduct abroad will not be governed by Canadian law, even where the wrong is litigated before Canadian courts. It is the law of the place of the tort that will, normally, govern (Tolofson v. Jensen, 1994 CanLII 44 (SCC), [1994] 3 S.C.R. 1022, at p. 1050). The only exception is when such law is so repugnant to the fundamental morality of the Canadian legal system as to lead the court not to apply it (p. 1054).
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