Executive Summary: Key Legal and Evidentiary Issues

• Pipe & Piling Supplies Ltd. initiated proceedings in the Montreal judicial district despite the case having no connecting link to that district.
• Both the plaintiff and the defendants are located in the Longueuil judicial district, making it the more natural forum.
• At issue is whether Article 48 of the Code of Civil Procedure justified a transfer order raised by the Chief Justice on her own initiative.
• Convenience of counsel — whose offices are in Montreal — was held not to be a determinative factor in the transfer analysis.
• Proportionality and sound case management, as required by Articles 9 and 18 C.p.c., guided the court's exercise of discretion.
• Filing cases in Montreal for convenience was found to unduly concentrate judicial activity there, negatively affecting delays in that district.

Facts of the case

Pipe & Piling Supplies Ltd., a manufacturer and supplier of steel products with its place of business in Saint-Hubert in the Longueuil judicial district, brought an action against Anshu Bhatia and Inder Bhatia, who were among its senior officers. The plaintiff alleged that the defendants had, without its knowledge, participated in the development of a steel mill in the State of New York. Both defendants maintained their office and residence in Brossard, also within the Longueuil judicial district. The plaintiff chose to institute proceedings in the Montreal judicial district, and the defendants did not oppose that choice at the time.

Applicable legal framework

The court's analysis centered on Article 48 of the Code of Civil Procedure, which provides that the Chief Justice may, at any stage of a proceeding and exceptionally — where the interests of the parties or third parties concerned so require, or where other serious grounds command it — order the transfer of a case to another judicial district, even on the court's own initiative. The court also applied the guiding principles of proportionality and sound case management set out in Articles 9 and 18 C.p.c.

Court's reasoning and analysis

Chief Justice Marie-Anne Paquette raised the transfer question on her own initiative pursuant to Article 48 C.p.c. and invited the parties on May 26, 2026 to submit written representations on the appropriateness of transferring the file to the Longueuil judicial district. The plaintiff sought to keep the matter in Montreal, citing the complexity of the litigation involving entities from multiple jurisdictions, the location of both parties' counsel in Montreal, and the parties' shared expectation of frequent in-person court appearances. The defendants did not oppose the plaintiff's position and deferred to the court's discretion.

The Chief Justice found that the Montreal district had been selected purely for convenience, as the case presented no connecting link to that district. Applying established jurisprudence, she confirmed that the location of counsel's offices is not a determinative factor in a transfer analysis. She further noted that filing cases in Montreal for reasons of convenience contributes to an undue concentration of judicial activity in that district, increasing court delays. The interests of justice, she held, call for a more rational use of judicial resources across the province by referring cases to their more natural forum — here, Longueuil, where all parties are situated.

Ruling and overall outcome

On June 17, 2026, Chief Justice Marie-Anne Paquette ordered the transfer of the file from the Montreal judicial district to the Longueuil judicial district. The order was made on the court's own initiative on a procedural matter, and no monetary award, damages, or costs were ordered — the transfer was granted without costs.