Chaining Across Canada

In the common law provinces, chaining of foreign judgments may be possible. I.e., find a province that has a reciprocation agreement with the state from which you have a judgment, register the judgment in that province, and then register and enforce the now provincial judgment in your home province as a Canadian judgment. At least that’s the theory.

The practical problem is that across Canada, provinces have a very limited numbe of reciprocation agreements with U.S. states and other countries. A while back I had to investigate the possibility of chaining and as a result compiled a handy table, which includes all provinces (except Quebec), their applicable acts, and the states/countries with which they have reciprocation agreements.

Of interest is that B.C. has can register judgments from the greatest number of states: Washington, Alabama, California, Oregon, Colorado and Idaho, as well as Australia, Germany, Austria and UK; Alberta has agreements with Montana; and Manitoba is the only Canadian province with a reciprocation agreement with France.

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