Introduction
C.M. Callow Inc. v.
Zollinger
1
, the Supreme Court of Canada
(
SCC ) clarified the scope of the duty
of honest contractual performance, as recognized by the Court in
Bhasin v. Hrynew
Bhasin, and further expanded on in
C.M.
Callow, the duty of honest contractual performance is one of
the manifestations of the organizing principle of good faith in
performance of contracts. While the organizing principle of good
faith usually manifests itself in specific legal doctrines, such as
the doctrine of unconscionability, and in specific types of
contractual relationships, such as those where the parties are
required to cooperate to achieve the objectives of the contract and