Background:

• Martha Beach, the sole director and shareholder of the three corporations, was adjudged bankrupt in 2022.
• MNP Ltd. was appointed receiver of these corporations by an order of Hackland J., following a motion initiated in Martha Beach’s bankruptcy.
• Gary Beach (Martha’s spouse) filed an appeal against this receivership order, claiming that it could be appealed without leave, which was incorrect as per the Bankruptcy and Insolvency Act (BIA).

Issues Raised by Gary Beach:

1. The bankruptcy judge failed to apply the correct legal test for appointing a receiver.
2. The judge provided no reasons for the decision.
3. The formal order was settled without Beach’s involvement.
4. Assurances made during the hearing were not reflected in the final order.

Court's Analysis:

• Leave to Appeal: Leave is required under the BIA to appeal a receivership order, which Beach conceded but sought after filing the appeal.
• Grounds for Appeal: None of the proposed grounds were deemed prima facie meritorious. The bankruptcy judge’s rulings during the oral hearing sufficed as reasons, and no errors were identified in the receiver’s appointment.

Outcome:

• Leave to appeal denied. No significant legal issues were raised, and none of the appeal grounds justified further review.
• Amount for costs was not specified.