In the recent Alberta decision of
Duhn Estate, 2021
ABQB 35, the Court of Queen s Bench has confirmed that, absent
a sufficient evidentiary basis, the Court will not displace a
testator s right to keep her pre-death financial life private
and confidential.
The applicants in
Duhn Estate were two of the
Testator s children and beneficiaries of her estate. The
applicants sought a full financial disclosure regarding
inter
vivos transfers of money and real and personal property during
the last four years of her life. The value of the Testator s
estate had decreased significantly in the four years preceding her
death, which the Court noted raised