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The Court of Appeal of Ontario found in Toronto-Dominion Bank v. Konga that the interpretation of a guarantee is a question of mixed fact and law, entitled to deference on appeal. Further, for a guarantor to obtain a discharge from the guarantee, he must establish that the bank's demand caused the debtor's default.

Barbara Walker-Renshaw, Partner in the Toronto Health Law Group and National Leader of BLG’s Mental Health Law Practice has published an article in Health Law in Canada (February, 2015).