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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 ....