1022 is a landmark decision of the Supreme Court of Canada on conflict of laws in tort.

Under Saskatchewan law the claimant must prove gross negligence in order for a gratuitous passenger to recover and the limitation period is 12 months.

He contemplated that there may be exception at the international level where there may be injustice[3] or where both parties are domiciled in the forum.

In Hanlan v Sernesky (1998, Ont.CA) where the court found exception to the rule on an international matter.

However, similar reasoning was rejected on provincial matters in Leornard v Houle (1997, Ont.CA).