Morguard Investments Ltd v De Savoye, [1990] 3 SCR 1077[2] is the leading decision of the Supreme Court of Canada on the enforcement of extraprovincial judgments.

The Court held that the standard for enforcing a default judgment from a different province is not the same as if it were from another country; rather the Court adopts the test from Indyka v Indyka, [1969] 1 AC 33 (HL) and Moran v Pyle National (Canada) Ltd, [1975] 1 SCR 393 where there must be a "real and substantial connection" between the petitioner and the country or territory exercising jurisdiction.

Instead, he emphasized that the business community operates on a world economy and so the law must accommodate "the flow of wealth, skills and people across state lines".

These various constitutional and sub-constitutional arrangements and practices make unnecessary a "full faith and credit" clause such as exists in other federations, such as the United States and Australia.

[4] He intentionally left the meaning of "real and substantial connection" open, stating: I am aware, of course, that the possibility of being sued outside the province of his residence may pose a problem for a defendant.

In a world where even the most familiar things we buy and sell originate or are manufactured elsewhere, and where people are constantly moving from province to province, it is simply anachronistic to uphold a "power theory" or a single situs for torts or contracts for the proper exercise of jurisdiction.The test established in this case was later elaborated on by the Court of Appeal for Ontario in Muscutt v Courcelles,[5] where a list of eight factors was given to be considered when determining whether a real and substantial connection exists: The Morguard principles were elaborated upon in subsequent cases, notably in: