In Lax v. Lax. the Ontario Court of Appeal determined that the limitation period for enforcement of a foreign judgement was six year, as a foreign judgement is equivalent to a contract. The section 45 (1) (c) reference to "an action upon a judgment or recognizance" only applied to domestic judgements. The action is to proceed to trial on an issue of discoverability.
Note that the limitation period changed as of January 1, 2004, by the enactment of the new Limitation Act, 2002.
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