adr-sml/docs/reference/ontario-shareholder-remedies.md

# Ontario and federal shareholder, partnership and closely-held-business remedies; family-arbitration training re-checked

Committed under AGENTS.md R14 and the CLAUDE.md rule it encodes: **anything a
spec makes a claim about must be reachable from the repository.** Every fact
the six `/practice/*` pages state about the world is checkable here or it is
not published.

**Retrieved 2026-08-29.** Fetched from the primary sources listed below and
extracted with quotations pasted verbatim. This file is the artefact; the pages
cite it. Do not paraphrase a fact into a page that is not stated here.

> ⚠️ **A statute, a regulation and a tribunal page all move.** Every consolidation
> date and effective date below is as at the retrieval date and nothing more.
> Re-check before cutover, and before any republish that turns on one of them.

> ### R18 re-check — cutover pass, 2026-09-01
>
> ⚠️ **THIS FILE CARRIES THE STANDING RE-CHECK INSTRUCTION ABOVE AND WAS
> NOT ONE OF R18's SEVEN LIMBS, AND IT WENT UNSTAMPED IN THE FIRST PASS.**
> Five of seven extracts were stamped and two were not, so a reader could
> not tell whether this one was considered and found non-volatile or simply
> missed. Found by `adversarial-reviewer`, 2026-09-02 — the same
> control-fires-over-part-of-its-scope defect as R18 having no checklist
> item, one notch smaller. **Nothing here was re-retrieved.**
>
> - **No volatile limb at this cutover.** The facts this file supports on
>   `/practice/shareholder/` are OBCA sections and case law, which do not move
>   at this cadence, and a sweep of the built page for dates, statuses and
>   "as of" framings returned nothing time-anchored `[verified 2026-09-02 —
>   swept `dist/practice/shareholder/index.html`]`.

**Topic as researched:** Ontario/Canada shareholder, partnership and closely-held business disputes — statutory remedies (oppression, dissent/appraisal, winding up), the Partnerships Act, arbitration references in the corporations statutes; plus an independent re-check of Ontario family arbitration training requirements.

---

## Sources

| Kind | Source | URL |
|---|---|---|
| statute | Business Corporations Act, R.S.O. 1990, c. B.16 (Ontario e-Laws, full text) | <https://www.ontario.ca/laws/statute/90b16> |
| statute | Canada Business Corporations Act, R.S.C., 1985, c. C-44 (Justice Laws, full text) | <https://laws-lois.justice.gc.ca/eng/acts/C-44/FullText.html> |
| statute | Partnerships Act, R.S.O. 1990, c. P.5 (Ontario e-Laws, full text) | <https://www.ontario.ca/laws/statute/90p05> |
| regulation | O. Reg. 134/07: Family Arbitration, under the Arbitration Act, 1991 (Ontario e-Laws, current consolidation) | <https://www.ontario.ca/laws/regulation/070134> |
| regulation | O. Reg. 134/07: Family Arbitration — original (v1) version, Ontario e-Laws source law | <https://www.ontario.ca/laws/regulation/070134/v1> |
| regulator | Training for family arbitrators — Government of Ontario (ontario.ca) | <https://www.ontario.ca/page/training-family-arbitrators> |
| statute | Family Law Act, R.S.O. 1990, c. F.3 (Ontario e-Laws, full text) | <https://www.ontario.ca/laws/statute/90f03> |
| statute | Arbitration Act, 1991, S.O. 1991, c. 17 (Ontario e-Laws, full text) | <https://www.ontario.ca/laws/statute/91a17> |

---

## Verbatim quotations

### Business Corporations Act, R.S.O. 1990, c. B.16 (Ontario e-Laws, full text)

<https://www.ontario.ca/laws/statute/90b16> — retrieved 2026-08-29

> Business Corporations Act
> R.S.O. 1990, CHAPTER B.16
> Consolidation Period: From October 1, 2025 to the e-Laws currency date .
> Last amendment: 2024, c. 15, Sched. 1, s. 111 .

> Oppression remedy
> 248 (1) A complainant and, in the case of an offering corporation, the Commission may apply to the court for an order under this section. 1994, c. 27, s. 71 (33).

> Idem
> (2) Where, upon an application under subsection (1), the court is satisfied that in respect of a corporation or any of its affiliates,
> (a) any act or omission of the corporation or any of its affiliates effects or threatens to effect a result;
> (b) the business or affairs of the corporation or any of its affiliates are, have been or are threatened to be carried on or conducted in a manner; or
> (c) the powers of the directors of the corporation or any of its affiliates are, have been or are threatened to be exercised in a manner,
> that is oppressive or unfairly prejudicial to or that unfairly disregards the interests of any security holder, creditor, director or officer of the corporation, the court may make an order to rectify the matters complained of. R.S.O. 1990, c. B.16, s. 248 (2).

> Court order
> (3) In connection with an application under this section, the court may make any interim or final order it thinks fit including, without limiting the generality of the foregoing,
> (a) an order restraining the conduct complained of;
> (b) an order appointing a receiver or receiver-manager;
> (c) an order to regulate a corporation’s affairs by amending the articles or by-laws or creating or amending a unanimous shareholder agreement;
> ... (f) an order directing a corporation, subject to subsection (6), or any other person, to purchase securities of a security holder;
> ... (l) an order winding up the corporation under section 207;

> 245 In this Part,
> “action” means an action under this Act; (“action”)
> “complainant” means,
> (a) a registered holder or beneficial owner, and a former registered holder or beneficial owner, of a security of a corporation or any of its affiliates,
> (b) a director or an officer or a former director or officer of a corporation or of any of its affiliates,
> (c) any other person who, in the discretion of the court, is a proper person to make an application under this Part. (“plaignant”) R.S.O. 1990, c. B.16, s. 245.

> Rights of dissenting shareholders
> 185 (1) Subject to subsection (3) and to sections 186 and 248, if a corporation resolves to,
> (a) amend its articles under section 168 to add, remove or change restrictions on the issue, transfer or ownership of shares of a class or series of the shares of the corporation;
> ... (c) amalgamate with another corporation under sections 175 and 176;
> (d) be continued under the laws of another jurisdiction under section 181;
> ... (e) sell, lease or exchange all or substantially all its property under subsection 184 (3),
> a holder of shares of any class or series entitled to vote on the resolution may dissent. R.S.O. 1990, c. B.16, s. 185 (1); 2017, c. 20, Sched. 6, s. 24.

> Winding up by court
> 207 (1) A corporation may be wound up by order of the court,
> (a) where the court is satisfied that in respect of the corporation or any of its affiliates,
> (i) any act or omission of the corporation or any of its affiliates effects a result,
> (ii) the business or affairs of the corporation or any of its affiliates are or have been carried on or conducted in a manner, or
> (iii) the powers of the directors of the corporation or any of its affiliates are or have been exercised in a manner,
> that is oppressive or unfairly prejudicial to or that unfairly disregards the interests of any security holder, creditor, director or officer; or

> (b) where the court is satisfied that,
> (i) a unanimous shareholder agreement entitled a complaining shareholder to demand dissolution of the corporation after the occurrence of a specified event and that event has occurred,
> ... (iv) it is just and equitable for some reason, other than the bankruptcy or insolvency of the corporation, that it should be wound up; or
> (c) where the shareholders by special resolution authorize an application to be made to the court to wind up the corporation. R.S.O. 1990, c. B.16, s. 207 (1).

> Matter that a unanimous shareholder agreement may provide
> (6) A unanimous shareholder agreement may, without restricting the generality of subsection (2), provide that,
> (a) any amendment of the unanimous shareholder agreement may be effected in the manner specified therein; and
> (b) in the event that shareholders who are parties to the unanimous shareholder agreement are unable to agree on or resolve any matter pertaining to the agreement, the matter may be referred to arbitration under such procedures and conditions as are specified in the unanimous shareholder agreement. R.S.O. 1990, c. B.16, s. 108 (6).

### Canada Business Corporations Act, R.S.C., 1985, c. C-44 (Justice Laws, full text)

<https://laws-lois.justice.gc.ca/eng/acts/C-44/FullText.html> — retrieved 2026-08-29

> Canada Business Corporations Act ( R.S.C. , 1985, c. C-44)

> Marginal note: Application to court re oppression
> 241 (1) A complainant may apply to a court for an order under this section.

> Marginal note: Grounds
> (2) If, on an application under subsection (1), the court is satisfied that in respect of a corporation or any of its affiliates
> (a) any act or omission of the corporation or any of its affiliates effects a result,
> (b) the business or affairs of the corporation or any of its affiliates are or have been carried on or conducted in a manner, or
> (c) the powers of the directors of the corporation or any of its affiliates are or have been exercised in a manner
> that is oppressive or unfairly prejudicial to or that unfairly disregards the interests of any security holder, creditor, director or officer, the court may make an order to rectify the matters complained of.

> Marginal note: Powers of court
> (3) In connection with an application under this section, the court may make any interim or final order it thinks fit including, without limiting the generality of the foregoing,
> (a) an order restraining the conduct complained of;
> (b) an order appointing a receiver or receiver-manager;
> (c) an order to regulate a corporation’s affairs by amending the articles or by-laws or creating or amending a unanimous shareholder agreement;
> ... (f) an order directing a corporation, subject to subsection (6), or any other person, to purchase securities of a security holder;
> ... (l) an order liquidating and dissolving the corporation;

> Marginal note: Alternative order
> (7) An applicant under this section may apply in the alternative for an order under section 214.

> 238 In this Part,
> complainant means
> (a) a registered holder or beneficial owner, and a former registered holder or beneficial owner, of a security of a corporation or any of its affiliates,
> (b) a director or an officer or a former director or officer of a corporation or any of its affiliates,
> (c) the Director, or
> (d) any other person who, in the discretion of a court, is a proper person to make an application under this Part. ( plaignant )

> Marginal note: Right to dissent
> 190 (1) Subject to sections 191 and 241, a holder of shares of any class of a corporation may dissent if the corporation is subject to an order under paragraph 192(4)(d) that affects the holder or if the corporation resolves to
> (a) amend its articles under section 173 or 174 to add, change or remove any provisions restricting or constraining the issue, transfer or ownership of shares of that class;
> ... (c) amalgamate otherwise than under section 184;
> (d) be continued under section 188;
> (e) sell, lease or exchange all or substantially all its property under subsection 189(3); or
> (f) carry out a going-private transaction or a squeeze-out transaction.

> Marginal note: Payment for shares
> (3) In addition to any other right the shareholder may have, but subject to subsection (26), a shareholder who complies with this section is entitled, when the action approved by the resolution from which the shareholder dissents or an order made under subsection 192(4) becomes effective, to be paid by the corporation the fair value of the shares in respect of which the shareholder dissents, determined as of the close of business on the day before the resolution was adopted or the order was made.

> Marginal note: Further grounds
> 214 (1) A court may order the liquidation and dissolution of a corporation or any of its affiliated corporations on the application of a shareholder,
> (a) if the court is satisfied that in respect of a corporation or any of its affiliates
> (i) any act or omission of the corporation or any of its affiliates effects a result,
> (ii) the business or affairs of the corporation or any of its affiliates are or have been carried on or conducted in a manner, or
> (iii) the powers of the directors of the corporation or any of its affiliates are or have been exercised in a manner
> that is oppressive or unfairly prejudicial to or that unfairly disregards the interests of any security holder, creditor, director or officer; or
> (b) if the court is satisfied that
> (i) a unanimous shareholder agreement entitles a complaining shareholder to demand dissolution of the corporation after the occurrence of a specified event and that event has occurred, or
> (ii) it is just and equitable that the corporation should be liquidated and dissolved.

> 146 (1) An otherwise lawful written agreement among all the shareholders of a corporation, or among all the shareholders and one or more persons who are not shareholders, that restricts, in whole or in part, the powers of the directors to manage, or supervise the management of, the business and affairs of the corporation is valid.

### Partnerships Act, R.S.O. 1990, c. P.5 (Ontario e-Laws, full text)

<https://www.ontario.ca/laws/statute/90p05> — retrieved 2026-08-29

> Partnerships Act
> R.S.O. 1990, Chapter P.5
> Consolidation Period: From October 1, 2023 to the e-Laws currency date .
> Last amendment: 2023, c. 9, Sched. 26 .

> Dissolution by expiry of term or notice
> 32 Subject to any agreement between the partners, a partnership is dissolved,
> (a) if entered into for a fixed term, by the expiration of that term;
> (b) if entered into for a single adventure or undertaking, by the termination of that adventure or undertaking; or
> (c) if entered into for an undefined time, by a partner giving notice to the other or others of his or her intention to dissolve the partnership, in which case the partnership is dissolved as from the date mentioned in the notice as the date of dissolution, or, if no date is so mentioned, as from the date of the communication of the notice. R.S.O. 1990, c. P.5, s. 32.

> Dissolution by death or insolvency of partner
> 33 (1) Subject to any agreement between the partners, every partnership is dissolved as regards all the partners by the death or insolvency of a partner. R.S.O. 1990, c. P.5, s. 33 (1).
> Where partner’s share charged for separate debt
> (2) A partnership may, at the option of the other partners, be dissolved if any partner suffers that partner’s share of the partnership property to be charged under this Act for that partner’s separate debt. R.S.O. 1990, c. P.5, s. 33 (2).

> By illegality of business
> 34 A partnership is in every case dissolved by the happening of any event that makes it unlawful for the business of the firm to be carried on or for the members of the firm to carry it on in partnership. R.S.O. 1990, c. P.5, s. 34.

> By the court
> 35 (1) On application by a partner, the court may order a dissolution of the partnership,
> (a) when a partner is found to be incapable as defined in the Substitute Decisions Act, 1992 ;
> (b) when a partner, other than the partner suing, becomes in any other way permanently incapable of performing the partner’s part of the partnership contract;
> (c) when a partner, other than the partner suing, has been guilty of such conduct as, in the opinion of the court, regard being had to the nature of the business, is calculated to prejudicially affect the carrying on of the business;
> (d) when a partner, other than the partner suing, wilfully or persistently commits a breach of the partnership agreement, or otherwise so conducts himself or herself in matters relating to the partnership business that it is not reasonably practicable for the other partner or partners to carry on the business in partnership with the partner;
> (e) when the business of the partnership can only be carried on at a loss; or
> (f) when in any case circumstances have arisen that in the opinion of the court render it just and equitable that the partnership be dissolved. R.S.O. 1990, c. P.5, s. 35; 2009, c. 33, Sched. 2, s. 57 (1).

> 39 On the dissolution of a partnership every partner is entitled, as against the other partners in the firm and all persons claiming through them in respect of their interests as partners, to have the property of the partnership applied in payment of the debts and liabilities of the firm and to have the surplus assets after such payment applied in payment of what may be due to the partners respectively after deducting what may be due from them as partners to the firm, and for that purpose any partner or the partner’s representative may, on the termination of the partnership, apply to the court to wind up the business and affairs of the firm. R.S.O. 1990, c. P.5, s. 39.

### O. Reg. 134/07: Family Arbitration, under the Arbitration Act, 1991 (Ontario e-Laws, current consolidation)

<https://www.ontario.ca/laws/regulation/070134> — retrieved 2026-08-29

> O. Reg. 134/07: FAMILY ARBITRATION, Under: Arbitration Act, 1991, S.O. 1991, c. 17
> ONTARIO REGULATION 134/07
> family arbitration
> Consolidation Period: From June 4, 2021 to the e-Laws currency date .
> Last amendment: 411/21 .

> Qualifications of arbitrator
> 3. Every arbitrator who conducts a family arbitration shall have received the training approved by the Attorney General for the arbitrator or class of arbitrators, as set out on a Government of Ontario website. O. Reg. 134/07, s. 3; O. Reg. 411/21, s. 1.

> 5. I, ......................... (print name of arbitrator ) , confirm the following matters:
> i. I will treat the parties equally and fairly in the arbitration, as subsection 19 (1) of the Arbitration Act, 1991 requires.
> ii. I have received the appropriate training approved by the Attorney General.
> iii. The parties were separately screened for power imbalances and domestic violence and I have considered the results of the screening and will do so throughout the arbitration, if I conduct one.
> iv. The parties were separately screened for power imbalances and domestic violence by someone other than me and I have considered his or her report on the results of the screening and will do so throughout the arbitration.

> 1. In this Regulation,
> “mediation-arbitration agreement” means a family arbitration agreement that provides that,
> (a) a mediation between the parties is to be conducted before any arbitration is conducted, and
> (b) if the mediation fails, the mediator shall arbitrate the dispute and make a binding resolution of it; (“convention de médiation-arbitrage”)

> (3) The arbitrator shall keep the record for at least 10 years after the date of the award. O. Reg. 134/07, s. 4 (3).

### O. Reg. 134/07: Family Arbitration — original (v1) version, Ontario e-Laws source law

<https://www.ontario.ca/laws/regulation/070134/v1> — retrieved 2026-08-29

> Qualifications of arbitrator 3. Every arbitrator who conducts a family arbitration shall have received the training approved by the Attorney General for the arbitrator or class of arbitrators, as set out on the Ministry’s website. O. Reg. 134/07, s. 3.

### Training for family arbitrators — Government of Ontario (ontario.ca)

<https://www.ontario.ca/page/training-family-arbitrators> — retrieved 2026-08-29

> In Ontario, family arbitrators must complete training approved by the Attorney General. Arbitration awards made by family arbitrators who have not completed the required training are not enforceable by the court.

> You need to complete a training program of at least 14 hours (within one week) to learn about screening parties for domestic violence and power imbalances. You should ensure your training covers most of or all the following elements:

> Your training must follow the principles outlined in the Ontario Association for Family Mediation’s Policy on Domestic Violence and Power Imbalances , adjusted for arbitration.

> All family law arbitrators who are not a part of the Ontario Bar, or another Canadian bar, must complete 30 hours of training about Ontario family law. You do not need to complete this training all at once, but there are certain areas of family law that would be best to learn together.

> Your training must have been done within five years of an arbitration where you certified that you were trained, unless you have done on average at least two family arbitrations per year, during those five years.

> Ongoing training
> As a family arbitrator, you will also need to take ongoing training of 10 hours over any two-year period. Five of these hours must be related to domestic violence or power imbalance issues.

> Updated: August 12, 2021
> Published: May 04, 2021

### Family Law Act, R.S.O. 1990, c. F.3 (Ontario e-Laws, full text)

<https://www.ontario.ca/laws/statute/90f03> — retrieved 2026-08-29

> “family arbitration” means an arbitration that,
> (a) deals with matters that could be dealt with in a marriage contract, separation agreement, cohabitation agreement or paternity agreement under this Part, and
> (b) is conducted exclusively in accordance with the law of Ontario or of another Canadian jurisdiction; (“arbitrage familial”)

> 59.1 (1) Family arbitrations, family arbitration agreements and family arbitration awards are governed by this Act and by the Arbitration Act, 1991 . 2006, c. 1, s. 5 (10).

> Conditions for enforceability
> 59.6 (1) A family arbitration award is enforceable only if,
> (a) the family arbitration agreement under which the award is made is made in writing and complies with any regulations made under the Arbitration Act, 1991 ;
> (b) each of the parties to the agreement receives independent legal advice before making the agreement;
> (c) the requirements of section 38 of the Arbitration Act, 1991 are met (formal requirements, writing, reasons, delivery to parties); and
> (d) the arbitrator complies with any regulations made under the Arbitration Act, 1991. 2006, c. 1, s. 5 (10).

> 59.4 A family arbitration agreement and an award made under it are unenforceable unless the family arbitration agreement is entered into after the dispute to be arbitrated has arisen. 2006, c. 1, s. 5 (10).

### Arbitration Act, 1991, S.O. 1991, c. 17 (Ontario e-Laws, full text)

<https://www.ontario.ca/laws/statute/91a17> — retrieved 2026-08-29

> Arbitration Act, 1991
> S.O. 1991, Chapter 17
> Consolidation Period: From March 22, 2017 to the e-Laws currency date .
> Last amendment: 2017, c. 2, Sched. 5, s. 13 .

> Family arbitrations, agreements and awards
> 2.1 (1) Family arbitrations, family arbitration agreements and family arbitration awards are governed by this Act and by the Family Law Act . 2006, c. 1, s. 1 (2).
> Conflict
> (2) In the event of conflict between this Act and the Family Law Act, the Family Law Act prevails. 2006, c. 1, s. 1 (2).

> Other third-party decision-making processes in family matters
> 2.2 (1) When a decision about a matter described in clause (a) of the definition of “family arbitration” in section 1 is made by a third person in a process that is not conducted exclusively in accordance with the law of Ontario or of another Canadian jurisdiction,
> (a) the process is not a family arbitration; and
> (b) the decision is not a family arbitration award and has no legal effect. 2006, c. 1, s. 1 (2).

> Family arbitration awards
> 50.1 Family arbitration awards are enforceable only under the Family Law Act . 2006, c. 1, s. 1 (10).

---

## What this establishes

Each item names the source it rests on. An item here that no quotation above
supports is a defect in this file, not a fact.

- OPPRESSION REMEDY (Ontario): the oppression remedy is s. 248 of the Business Corporations Act, R.S.O. 1990, c. B.16. Section 248(1) gives a 'complainant' (and, for an offering corporation, the Commission) standing to apply to the court. The operative test in s. 248(2) is conduct 'that is oppressive or unfairly prejudicial to or that unfairly disregards the interests of any security holder, creditor, director or officer of the corporation', on which 'the court may make an order to rectify the matters complained of.'
  *Source:* <https://www.ontario.ca/laws/statute/90b16>
- The OBCA oppression provision is broader than its federal counterpart in one respect visible on the face of the text: s. 248(2) reaches conduct that 'effects or threatens to effect a result' and affairs 'are, have been or are threatened to be carried on', i.e. it expressly captures threatened conduct. The CBCA equivalent (s. 241(2)) uses only 'effects a result' and 'are or have been carried on', with no 'threatened' language.
  *Source:* <https://laws-lois.justice.gc.ca/eng/acts/C-44/FullText.html>
- OBCA s. 248(3) lists the remedial orders available, including '(f) an order directing a corporation, subject to subsection (6), or any other person, to purchase securities of a security holder' (the buy-out order) and '(l) an order winding up the corporation under section 207'. Payment under (3)(f) or (g) is barred by s. 248(6) where the corporation is or would become unable to pay its liabilities as they become due.
  *Source:* <https://www.ontario.ca/laws/statute/90b16>
- 'Complainant' is defined in OBCA s. 245 to include a registered holder or beneficial owner (and former holder/owner) of a security, a director or officer (or former director or officer), and '(c) any other person who, in the discretion of the court, is a proper person to make an application under this Part.'
  *Source:* <https://www.ontario.ca/laws/statute/90b16>
- OPPRESSION REMEDY (federal): the equivalent is s. 241 of the Canada Business Corporations Act, R.S.C., 1985, c. C-44, marginal note 'Application to court re oppression'. Section 241(1) provides 'A complainant may apply to a court for an order under this section', and the s. 241(2) test is conduct 'that is oppressive or unfairly prejudicial to or that unfairly disregards the interests of any security holder, creditor, director or officer', on which 'the court may make an order to rectify the matters complained of.'
  *Source:* <https://laws-lois.justice.gc.ca/eng/acts/C-44/FullText.html>
- CBCA s. 241(3) lists the same remedial menu as the OBCA, including a buy-out order at (3)(f) and, at (3)(l), 'an order liquidating and dissolving the corporation'. CBCA s. 241(7) expressly permits an oppression applicant to 'apply in the alternative for an order under section 214'.
  *Source:* <https://laws-lois.justice.gc.ca/eng/acts/C-44/FullText.html>
- 'Complainant' is defined in CBCA s. 238 and, unlike the Ontario definition, expressly includes '(c) the Director' alongside security holders, former security holders, directors, officers, and any other person a court in its discretion finds a proper person.
  *Source:* <https://laws-lois.justice.gc.ca/eng/acts/C-44/FullText.html>
- APPRAISAL / DISSENT RIGHTS (Ontario): OBCA s. 185, headed 'Rights of dissenting shareholders'. Section 185(1) is expressed 'Subject to subsection (3) and to sections 186 and 248' and lists the triggering resolutions (certain article amendments, amalgamation, continuance out of the jurisdiction, and sale/lease/exchange of all or substantially all property under s. 184(3)).
  *Source:* <https://www.ontario.ca/laws/statute/90b16>
- APPRAISAL / DISSENT RIGHTS (federal): CBCA s. 190, marginal note 'Right to dissent'. Section 190(3) states the remedy: a complying shareholder 'is entitled ... to be paid by the corporation the fair value of the shares in respect of which the shareholder dissents, determined as of the close of business on the day before the resolution was adopted or the order was made.' The CBCA list of triggers includes, at s. 190(1)(f), 'carry out a going-private transaction or a squeeze-out transaction'.
  *Source:* <https://laws-lois.justice.gc.ca/eng/acts/C-44/FullText.html>
- A shareholder cannot use both remedies on the same amendment: OBCA s. 248(5) and CBCA s. 241(5) each provide that a shareholder is not entitled to dissent (under s. 185 / s. 190 respectively) if an amendment to the articles is effected under the oppression section.
  *Source:* <https://www.ontario.ca/laws/statute/90b16>
- WINDING UP / JUST AND EQUITABLE (Ontario): OBCA s. 207, headed 'Winding up by court'. Section 207(1)(a) reproduces the oppression grounds; s. 207(1)(b)(iv) is the just-and-equitable ground — 'it is just and equitable for some reason, other than the bankruptcy or insolvency of the corporation, that it should be wound up'. Section 207(1)(b)(i) separately covers a unanimous shareholder agreement that entitled a shareholder to demand dissolution on a specified event that has occurred. By s. 207(2), on such an application 'the court may make such order under this section or section 248 as it thinks fit.'
  *Source:* <https://www.ontario.ca/laws/statute/90b16>
- LIQUIDATION AND DISSOLUTION / JUST AND EQUITABLE (federal): CBCA s. 214, marginal note 'Further grounds'. A court may order liquidation and dissolution 'on the application of a shareholder' on the oppression grounds in s. 214(1)(a) or, under s. 214(1)(b)(ii), where 'it is just and equitable that the corporation should be liquidated and dissolved.' Section 214(2) mirrors the Ontario cross-reference: 'a court may make such order under this section or section 241 as it thinks fit.'
  *Source:* <https://laws-lois.justice.gc.ca/eng/acts/C-44/FullText.html>
- PARTNERSHIPS ACT (Ontario) citation: Partnerships Act, R.S.O. 1990, Chapter P.5. The e-Laws consolidation retrieved was 'From October 1, 2023 to the e-Laws currency date', last amendment 2023, c. 9, Sched. 26.
  *Source:* <https://www.ontario.ca/laws/statute/90p05>
- Partnerships Act dissolution provisions run from s. 32 under the heading 'Dissolution of Partnership': s. 32 (expiry of term, completion of the adventure, or notice by a partner where the partnership is for an undefined time); s. 33 (death or insolvency of a partner; and, at the option of the other partners, where a partner's share is charged for a separate debt); s. 34 (illegality of the business); and s. 35 (dissolution by the court).
  *Source:* <https://www.ontario.ca/laws/statute/90p05>
- Sections 32 and 33 of the Partnerships Act are each expressed 'Subject to any agreement between the partners' — so a partnership agreement can displace them. Section 34 (illegality) is not so qualified: 'A partnership is in every case dissolved by the happening of any event that makes it unlawful for the business of the firm to be carried on'.
  *Source:* <https://www.ontario.ca/laws/statute/90p05>
- Partnerships Act s. 35(1) sets out six grounds on which, 'On application by a partner, the court may order a dissolution of the partnership', including (d) wilful or persistent breach of the partnership agreement or conduct such 'that it is not reasonably practicable for the other partner or partners to carry on the business in partnership with the partner'; (e) 'when the business of the partnership can only be carried on at a loss'; and (f) the just-and-equitable ground — 'when in any case circumstances have arisen that in the opinion of the court render it just and equitable that the partnership be dissolved.'
  *Source:* <https://www.ontario.ca/laws/statute/90p05>
- Partnerships Act s. 39 provides that on dissolution every partner is entitled to have partnership property applied to the firm's debts and the surplus distributed, and that 'for that purpose any partner or the partner's representative may, on the termination of the partnership, apply to the court to wind up the business and affairs of the firm.'
  *Source:* <https://www.ontario.ca/laws/statute/90p05>
- ARBITRATION IN THE CORPORATIONS STATUTES — Ontario: YES, in exactly one place. OBCA s. 108(6)(b) provides that a unanimous shareholder agreement may provide that 'in the event that shareholders who are parties to the unanimous shareholder agreement are unable to agree on or resolve any matter pertaining to the agreement, the matter may be referred to arbitration under such procedures and conditions as are specified in the unanimous shareholder agreement.' This is the only occurrence of the string 'arbitrat' in the whole Act — a case-insensitive search returned exactly 1 hit in both the converted text and the raw HTML, and the hit was read in full context.
  *Source:* <https://www.ontario.ca/laws/statute/90b16>
- ARBITRATION IN THE CORPORATIONS STATUTES — federal: NO. A case-insensitive search of the complete CBCA full text for 'arbitrat' returned zero occurrences, in both the converted text and the raw HTML. The instrument was validated on the same file in the same run ('oppressive' returned 3 hits, 'unanimous shareholder agreement' 26), and the retrieved document was confirmed complete (it runs through s. 267, the Schedule of Offences, and the Related Provisions). The CBCA does validate unanimous shareholder agreements at s. 146(1) but, unlike OBCA s. 108(6)(b), says nothing about referring a dispute under one to arbitration.
  *Source:* <https://laws-lois.justice.gc.ca/eng/acts/C-44/FullText.html>
- Neither corporations statute mentions mediation. A search for 'mediat' returned 23 hits in the CBCA and 25 in the OBCA; every one was read and all are 'immediately' or 'immediate'. The Ontario Partnerships Act likewise contains zero occurrences of 'arbitrat', and its only 'mediat' hits (4) are 'immediately'.
  *Source:* <https://www.ontario.ca/laws/statute/90p05>
- FAMILY ARBITRATION — the 14-hour screening requirement is CONFIRMED. The Government of Ontario page states: 'You need to complete a training program of at least 14 hours (within one week) to learn about screening parties for domestic violence and power imbalances.' This independently reproduces the figure in the repo's existing extract at docs/reference/ontario-family-arbitration-training.md.
  *Source:* <https://www.ontario.ca/page/training-family-arbitrators>
- FAMILY ARBITRATION — the 30-hour Ontario family law requirement is CONFIRMED, and it applies only to non-lawyers: 'All family law arbitrators who are not a part of the Ontario Bar, or another Canadian bar, must complete 30 hours of training about Ontario family law.'
  *Source:* <https://www.ontario.ca/page/training-family-arbitrators>
- FAMILY ARBITRATION — the ongoing-training requirement is CONFIRMED: 'As a family arbitrator, you will also need to take ongoing training of 10 hours over any two-year period. Five of these hours must be related to domestic violence or power imbalance issues.'
  *Source:* <https://www.ontario.ca/page/training-family-arbitrators>
- FAMILY ARBITRATION — a currency requirement the repo's existing extract does NOT record: 'Your training must have been done within five years of an arbitration where you certified that you were trained, unless you have done on average at least two family arbitrations per year, during those five years.' This is a fourth requirement alongside the three hour figures.
  *Source:* <https://www.ontario.ca/page/training-family-arbitrators>
- FAMILY ARBITRATION — the enforcement consequence, stated by the government page itself: 'In Ontario, family arbitrators must complete training approved by the Attorney General. Arbitration awards made by family arbitrators who have not completed the required training are not enforceable by the court.'
  *Source:* <https://www.ontario.ca/page/training-family-arbitrators>
- IMPORTANT QUALIFICATION on the word 'prescribed': the hour figures are NOT set out in the regulation. O. Reg. 134/07, s. 3 ('Qualifications of arbitrator') requires only that 'Every arbitrator who conducts a family arbitration shall have received the training approved by the Attorney General for the arbitrator or class of arbitrators, as set out on a Government of Ontario website.' The regulation makes the training mandatory by reference; the content and the hours live on the ontario.ca page, which the Attorney General can change without amending the regulation.
  *Source:* <https://www.ontario.ca/laws/regulation/070134>
- The hour figures have NEVER appeared in O. Reg. 134/07. The original (v1) version of s. 3 reads identically except that it referred to 'the Ministry's website'; O. Reg. 411/21, s. 1 changed only that phrase to 'a Government of Ontario website'. So the delegation to a web page has been the mechanism since the regulation was made.
  *Source:* <https://www.ontario.ca/laws/regulation/070134/v1>
- The screening requirement has a second, harder anchor than the government web page: the arbitrator's certificate prescribed by O. Reg. 134/07, s. 2(4) para. 5 requires the arbitrator to confirm in the agreement itself both 'ii. I have received the appropriate training approved by the Attorney General' and that 'The parties were separately screened for power imbalances and domestic violence and I have considered the results of the screening and will do so throughout the arbitration'. This text IS in the regulation.
  *Source:* <https://www.ontario.ca/laws/regulation/070134>
- The statutory chain for family arbitration: Family Law Act, R.S.O. 1990, c. F.3, s. 51 defines 'family arbitration'; s. 59.1(1) provides that family arbitrations 'are governed by this Act and by the Arbitration Act, 1991'; and s. 59.6(1) makes an award 'enforceable only if' the agreement complies with the regulations, each party 'receives independent legal advice before making the agreement', s. 38 of the Arbitration Act, 1991 is met, and '(d) the arbitrator complies with any regulations made under the Arbitration Act, 1991' — which is the provision that makes O. Reg. 134/07 s. 3 training bite on enforceability.
  *Source:* <https://www.ontario.ca/laws/statute/90f03>
- Family Law Act s. 59.4 requires that a family arbitration agreement be entered into after the dispute has arisen: 'A family arbitration agreement and an award made under it are unenforceable unless the family arbitration agreement is entered into after the dispute to be arbitrated has arisen.' This is a structural difference from commercial arbitration, where pre-dispute clauses are the norm.
  *Source:* <https://www.ontario.ca/laws/statute/90f03>
- Arbitration Act, 1991, S.O. 1991, c. 17, s. 2.1(1) states that family arbitrations 'are governed by this Act and by the Family Law Act', and s. 2.1(2) that 'In the event of conflict between this Act and the Family Law Act, the Family Law Act prevails.' Section 2.2(1) provides that a family-matter decision made in a process 'not conducted exclusively in accordance with the law of Ontario or of another Canadian jurisdiction' is not a family arbitration and 'has no legal effect'. Section 50.1: 'Family arbitration awards are enforceable only under the Family Law Act.'
  *Source:* <https://www.ontario.ca/laws/statute/91a17>
- O. Reg. 134/07 defines 'mediation-arbitration agreement' for family matters as a family arbitration agreement providing that '(a) a mediation between the parties is to be conducted before any arbitration is conducted, and (b) if the mediation fails, the mediator shall arbitrate the dispute and make a binding resolution of it' — a definition of med-arb that exists in Ontario law only in the family context.
  *Source:* <https://www.ontario.ca/laws/regulation/070134>

---

## What this does NOT establish

**Read this section before writing copy.** It is the half that keeps a page
honest, and on this project it is the half that has twice been skipped.

- **Does the word 'prescribed' accurately describe Ontario's family arbitrator training hours, as AGENTS.md §9 Q39 and line 1952 currently put it?**
  - *Searched:* Fetched the current consolidation of O. Reg. 134/07 and its original (v1) version from ontario.ca, and read s. 3 in full in both.
  - *Outcome:* NOT CONFIRMED — and this looks like a wording defect in the repo, not a sourcing gap. No hour figure appears anywhere in the regulation, in any version. The regulation requires 'the training approved by the Attorney General ... as set out on a Government of Ontario website'; the 14/30/10 figures are administratively approved training published on a web page the Attorney General can revise without amending the regulation. The requirement is mandatory and enforceability-bearing, so 'required' or 'approved by the Attorney General' is accurate; 'prescribed' implies the numbers sit in the instrument, and they do not. Flagging for Pouya rather than fixing — AGENTS.md is his record.
- **Is the ontario.ca training page still the operative statement of approved training as at 2026-08-29, given it carries 'Updated: August 12, 2021'?**
  - *Searched:* Fetched the live page today (HTTP 200) and read its own date stamps; also fetched the current e-Laws consolidation of O. Reg. 134/07 to confirm s. 3 still points to a Government of Ontario website.
  - *Outcome:* PARTLY. The page is live today and the regulation still delegates to it, so it is the operative source by the regulation's own terms. But its content stamp is 'Updated: August 12, 2021 / Published: May 04, 2021'. I found no separate published register of Attorney General training approvals against which to cross-check, so I cannot independently confirm the figures have not been superseded by an approval not reflected on the page. Treat the hours as 'what the government page states as at 2026-08-29'.
- **Do the regulations made under the CBCA (as distinct from the Act) say anything about arbitration?**
  - *Searched:* Only the CBCA Act full text at laws-lois.justice.gc.ca was retrieved and searched. The Canada Business Corporations Regulations, 2001 (SOR/2001-512) were not fetched.
  - *Outcome:* NOT SEARCHED. The negative finding above is scoped to the Act only. If the site is going to say anything about federal corporate arbitration, the regulations should be checked too before that claim is written.
- **Do any of these sources support a claim about what qualifications a COMMERCIAL arbitrator or mediator in Ontario needs?**
  - *Searched:* All eight sources above were searched for arbitration/mediation references; the family arbitration chain (FLA ss. 51, 59.1-59.7; Arbitration Act ss. 2.1, 2.2, 50.1; O. Reg. 134/07) was read in full.
  - *Outcome:* NOT ESTABLISHED, and this confirms the honest limit the repo's own extract already records. Every training and qualification requirement found is expressly tied to 'family arbitration' as defined in FLA s. 51. Nothing retrieved states, either way, what a commercial arbitrator or mediator requires. The absence of a commercial requirement in family-specific instruments is not authority that none exists — AGENTS.md §4 is right to carry the commercial half as Pouya's stated position rather than as a sourced fact, and nothing in this pass changes that.
- **Is there a statutory buy-out or shotgun mechanism for closely-held Ontario corporations outside the oppression remedy?**
  - *Searched:* Read OBCA ss. 108, 185, 207, 245-250 and CBCA ss. 146, 190, 214, 238-241 in full text.
  - *Outcome:* NOT FOUND as a freestanding mechanism. The buy-out order exists only as a discretionary remedy the court may grant under OBCA s. 248(3)(f) / CBCA s. 241(3)(f), subject to the solvency limit in s. 248(6) / s. 241(6). Shotgun and buy-sell clauses are creatures of the shareholders' agreement, not of either statute. Do not let site copy imply a statutory buy-out right.

---

## Adversarial check on this extract

An independent pass was run over the items above with one instruction: decide
whether the pasted quotations actually support each one, and flag anything
broader than its quote. `PARTLY` means the wording overreaches the source.

**Overreach found:** YES — see below

| Verdict | Claim | Why |
|---|---|---|
| **PARTLY** | [3] OBCA s. 248(3) remedial orders incl. (3)(f) buy-out and (3)(l) winding up; plus 'Payment under (3)(f) or (g) is barred by s. 248(6) where the corporation is or would become una | The first sentence is verbatim in the quote. The second sentence overreaches: no quote of s. 248(6) is pasted anywhere, and the words 'is or would become unable to pay its liabilities as they become due' appear in no source. The quote's own words go only as far as 'subject to subsection (6)' — it does not disclose what subsection (6) says. Paragraph '(g)' also appears in no pasted quote at all. Ov |
| **PARTLY** | [6] 'CBCA s. 241(3) lists the same remedial menu as the OBCA', incl. (3)(f) buy-out and (3)(l) liquidation; s. 241(7) alternative application under s. 214 | The (3)(f), (3)(l) and 241(7) elements are verbatim in the quotes. 'lists the same remedial menu as the OBCA' overreaches: both pasted s. 248(3) and s. 241(3) quotes are elided (each contains '...'), so the full menus were never put side by side, and the one paragraph the fact itself compares differs textually — OBCA (l) is 'an order winding up the corporation under section 207', CBCA (l) is 'an o |
| **PARTLY** | [8] OBCA s. 185 dissent rights — 'Subject to subsection (3) and to sections 186 and 248' and the triggering resolutions | The heading, the 'Subject to' clause and the four named triggers are in the quote. But the pasted s. 185(1) is elided ('... (c) amalgamate') so at least paragraph (b) is missing from the source text, while the fact presents its parenthetical as 'the triggering resolutions' — a closed list a copywriter would reproduce as complete. Overreaching words: 'lists the triggering resolutions (…)' read as e |
| **NOT** | [10] OBCA s. 248(5) and CBCA s. 241(5) each bar dissent where an article amendment is effected under the oppression section | No quote of s. 248(5) or s. 241(5) appears anywhere in the source set — the OBCA and CBCA quote blocks jump from (3) to other sections. The proposition may well be true in the world, but nothing pasted supports any part of it, including the characterisation 'A shareholder cannot use both remedies on the same amendment'. |
| **PARTLY** | [11] OBCA s. 207 winding up — 207(1)(a) oppression grounds, (b)(iv) just and equitable, (b)(i) USA dissolution trigger; and 'By s. 207(2) … the court may make such order under this | Everything up to and including s. 207(1)(b)(iv) and (b)(i) is verbatim in the two pasted 207(1) quotes. The final sentence is not: no quote of s. 207(2) exists in the source set, yet the fact renders it inside quotation marks as source text. Overreaching words: "By s. 207(2), on such an application 'the court may make such order under this section or section 248 as it thinks fit.'" — presented as  |
| **PARTLY** | [12] CBCA s. 214 liquidation/dissolution — 214(1)(a) and (b)(ii); and 'Section 214(2) mirrors the Ontario cross-reference: a court may make such order under this section or section | The marginal note 'Further grounds', 'on the application of a shareholder', the oppression grounds and the just-and-equitable ground are verbatim in the quote. The s. 214(2) sentence is not supported by any pasted quote and is again presented in quotation marks; the word 'mirrors' additionally rests on the equally unquoted OBCA s. 207(2). Overreaching words: the whole final sentence 'Section 214(2 |
| **PARTLY** | [14] Partnerships Act dissolution provisions 'run from s. 32 under the heading Dissolution of Partnership'; content of ss. 32, 33, 34, 35 | The substance of ss. 32, 33(1), 33(2), 34 and 35 is verbatim in the quotes. The structural claim is not: the string 'Dissolution of Partnership' appears in no pasted quote — the quoted headings are 'Dissolution by expiry of term or notice', 'Dissolution by death or insolvency of partner', 'By illegality of business' and 'By the court'. Nor does anything quoted show where the dissolution provisions |
| **PARTLY** | [15] 'Sections 32 and 33 are each expressed Subject to any agreement between the partners — so a partnership agreement can displace them'; s. 34 not so qualified | s. 32 and s. 33(1) do carry the phrase in the quotes, and the s. 34 quote demonstrably lacks it. But the quoted s. 33(2) — 'A partnership may, at the option of the other partners, be dissolved if any partner suffers that partner's share … to be charged' — carries no 'subject to any agreement' qualifier, so a section-level statement about 's. 33' is broader than the pasted text. 'so a partnership a |
| **PARTLY** | [18] Arbitration in the OBCA: 'YES, in exactly one place' — s. 108(6)(b), 'the only occurrence of the string arbitrat in the whole Act' | The text of s. 108(6)(b) is pasted verbatim and fully supports the affirmative half. The exhaustive half cannot be supported by any quote: a pasted excerpt cannot establish that a string occurs nowhere else in a 732 KB statute — that claim rests on a grep reported in searchesRun, not on quoted source text, and it is the kind of statement that would appear on a public page as a bare assertion about |
| **PARTLY** | [19] Arbitration in the CBCA: 'NO' — zero occurrences of 'arbitrat'; document confirmed complete; CBCA validates USAs at s. 146(1) but says nothing about arbitration | Only the last clause is quote-backed: s. 146(1) is pasted and does validate unanimous shareholder agreements without mentioning arbitration. Everything else is an absence claim about a whole statute that no pasted quote can carry — the zero-hit counts, the control-hit validation, and the completeness assertion ('runs through s. 267, the Schedule of Offences, and the Related Provisions') appear in  |
| **NOT** | [20] 'Neither corporations statute mentions mediation' (23 CBCA / 25 OBCA hits, all 'immediately'); Partnerships Act has zero 'arbitrat' and 4 'mediat' hits, all 'immediately' | No pasted quote supports any part of this. It is entirely a report of grep output listed in searchesRun, and the sources contain no quoted text in which the word does or does not appear. The scope also runs past the cited source: the item is filed against the Partnerships Act URL while asserting negatives about both the OBCA and the CBCA. This is a three-statute class statement with zero quoted in |
| **PARTLY** | [22] The 30-hour Ontario family law requirement 'applies only to non-lawyers' | The 30-hour sentence is verbatim, but the class it describes is 'family law arbitrators who are not a part of the Ontario Bar, or another Canadian bar' — membership of a Canadian bar, not lawyer status. A foreign-qualified lawyer is a lawyer and is caught by the quoted words, so 'non-lawyers' widens (and misdescribes) the quoted class. 'only' also converts a positive requirement on one class into  |
| **PARTLY** | [26] 'Prescribed' is inaccurate: the hour figures are NOT in O. Reg. 134/07; s. 3 delegates to a Government of Ontario website the AG can change without amending the regulation | The s. 3 quote fully supports the delegation mechanism and the exact words 'as set out on a Government of Ontario website'. The absence half is not quote-provable: the pasted regulation excerpts are four fragments (ss. 1, 2(4) para 5, 3, 4(3)), which cannot show that no hour figure appears anywhere in the instrument. 'which the Attorney General can change without amending the regulation' is also a |
| **PARTLY** | [27] 'The hour figures have NEVER appeared in O. Reg. 134/07'; v1 s. 3 identical but for 'the Ministry's website'; O. Reg. 411/21 s. 1 changed only that phrase | Comparing the two pasted texts of s. 3 supports the wording change and its amending citation. It does not support an all-versions, whole-regulation negative: only s. 3 is quoted from v1, and nothing at all is quoted from v2 or v3 despite searchesRun saying they were fetched. Overreaching words: 'The hour figures have NEVER appeared in O. Reg. 134/07' and 'changed only that phrase' as a statement a |
| **PARTLY** | [28] The certificate 'prescribed by O. Reg. 134/07, s. 2(4) para. 5' requires the arbitrator to confirm 'in the agreement itself' both item ii (training) and item iii (screening) | The certificate text is pasted and does contain items ii and iii verbatim. Three things exceed it. The pinpoint: the quote begins bare, at '5.', with nothing showing it sits in s. 2(4). The location: nothing quoted says the certificate goes 'in the agreement itself'. And the conjunction: the quote sets out iii (screened by me) and iv (screened by someone other than me) as apparent alternatives, so |
| **PARTLY** | [29] Statutory chain: FLA s. 51 defines 'family arbitration'; s. 59.1(1) governance; s. 59.6(1) enforceability conditions, (d) making O. Reg. 134/07 s. 3 bite | The definition, s. 59.1(1) and all four limbs of s. 59.6(1) are pasted verbatim, and the closing synthesis follows directly from quoted 59.6(1)(d) plus the quoted regulation heading ('Under: Arbitration Act, 1991'). The one thing outside the quotes is the pinpoint: the definition quote carries no section number, so 's. 51' is supplied from outside the source. Overreaching words: 's. 51' as a pinpo |
| **PARTLY** | [30] FLA s. 59.4 requires a post-dispute family arbitration agreement; 'This is a structural difference from commercial arbitration, where pre-dispute clauses are the norm.' | The s. 59.4 quote is verbatim and supports the first sentence entirely. The second sentence is supported by nothing: no source in the set says anything about commercial arbitration practice, and the extract's own notEstablished section concedes that nothing retrieved speaks to commercial arbitration. Overreaching words: 'This is a structural difference from commercial arbitration, where pre-disput |
| **PARTLY** | [32] O. Reg. 134/07 definition of 'mediation-arbitration agreement' — 'a definition of med-arb that exists in Ontario law only in the family context' | The definition itself is pasted verbatim and fully supports the first half. The trailing clause is a negative about the whole of Ontario law drawn from a family-specific regulation — precisely the class statement from a single instance this audit is looking for. The greps reported in searchesRun covered three corporations/partnership statutes and did not search for 'med-arb' or for the definition  |

*14 of 32 items were found fully supported; only the
others are tabled above.*

---

## Searches run

- `curl https://www.ontario.ca/laws/statute/90b16 (OBCA full text, HTTP 200, 732,644 bytes)`
- `grep -c -i 'arbitrat' obca.txt / obca.html — 1 hit each, read in full context (s. 108(6)(b))`
- `grep -o -i '[a-z]*mediat[a-z]*' obca.txt | sort | uniq -c — 25 hits, all 'immediately'`
- `curl https://laws-lois.justice.gc.ca/eng/acts/C-44/FullText.html (CBCA full text, HTTP 200, 883,143 bytes)`
- `grep -c -i 'arbitrat' cbca.txt / cbca.html — 0 hits in both; instrument validated with controls 'oppressive' (3), 'unanimous shareholder agreement' (26); document completeness confirmed to s. 267 + Schedule + Related Provisions`
- `grep -o -i '[a-z]*mediat[a-z]*' cbca.txt | sort | uniq -c — 23 hits, all 'immediately'/'immediate'`
- `curl https://www.ontario.ca/laws/statute/90p05 (Partnerships Act, HTTP 200); grep 'arbitrat' — 0 hits in text and raw HTML, control 'partnership' 127 hits`
- `curl https://www.ontario.ca/laws/regulation/070134 (O. Reg. 134/07 current consolidation, HTTP 200)`
- `curl https://www.ontario.ca/laws/regulation/070134/v1, /v2, /v3 — historical versions of s. 3, to test whether hour figures were ever in the regulation`
- `WebSearch (allowed_domains: ontario.ca): 'Ontario family arbitrator training approved by the Attorney General hours screening domestic violence' — used only to locate the URL; snippets not relied on`
- `curl https://www.ontario.ca/page/training-family-arbitrators (HTTP 200) — primary source fetched and quoted directly rather than via search snippet`
- `curl https://www.ontario.ca/laws/statute/90f03 (Family Law Act, HTTP 200) — ss. 51, 59.1, 59.4, 59.6, 59.7`
- `curl https://www.ontario.ca/laws/statute/91a17 (Arbitration Act, 1991, HTTP 200) — ss. 2.1, 2.2, 50.1`
- `git grep -n -i '14 hours|30 hours|10 hours|screening' — located the repo's existing extract at docs/reference/ontario-family-arbitration-training.md and the AGENTS.md Q39 entry, for independent comparison`