Lac Minerals Ltd v International Corona Resources Ltd

International Corona was a junior mining company that was investigating the mineral potential of a property at Hemlo in Northern Ontario.

Lac Minerals, a senior mining company, heard of Corona's activity and arranged to visit the site.

Corona showed Lac's representatives detailed information about their geological findings, together with their underlying theory about its mineral potential and importance.

He ordered the return of the property to Corona, but allowed Lac's claim in part for a lien for the cost of improvements and other payments.

The Ontario Court of Appeal affirmed the trial judge's ruling, also noting that a constructive trust was an appropriate remedy for both the breach of confidence and fiduciary duty.

The consequences attendant on a finding of a fiduciary relationship and its breach have resulted in judicial reluctance to do so except where the application of this "blunt tool of equity" is really necessary.

[5][6] Lac Minerals further confirms the divergence of Canadian common-law jurisprudence on constructive trusts to that of English law, which began to arise in Pettkus v. Becker.