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In Print N’ Promotion the court affirmed that, “proof of an intention by the defendant to injure the plaintiff is an essential element of the tort of intentional interference with contractual relations and economic interests.”  (Para. 23)  The Court explicitly cites the Alleslev-Krofchak decision for this proposition.

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Affirming the position taken on appeal in the case of 595799 Ontario Ltd. v. Galpin, 2010 ONCA 834, won by Beament Green’s Sean Bawden, the Court of Appeal held that, “the intentional acts at issue must be directed, at least in part, against the complaining party.” (Para. 23)

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The Print N’ decision arguably distinguishes the earlier decision of the Court of Appeal in Reach M.D. Inc. v. Pharmaceutical Manufacturers Assn. of Canada (2003), 65 O.R. (3d) 30 (C.A.) by holding that, “the requirement of an intention to injure is not made out where the wrongful conduct at issue was not deliberately targeted against the complaining party but, rather, was simply an incidental or foreseeable result of the defendant’s wrongful conduct.  The purpose of the unlawful or wrongful conduct must be to inflict injury on the complaining party, that is, the plaintiff.”  (Para. 24)

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It would appear that the analysis set out in Alleslev-Krofchak, for which leave to appeal to the Supreme Court has currently has been sought, [2010] S.C.C.A. No. 403, is becoming the benchmark for the tort of intentional interference with economic relations.

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