- Parties: The plaintiff was Gold Recruitment Services Inc. The defendant was QDS Holdings Inc. 

- Subject Matter: The parties entered into a written contract for the plaintiff to recruit highly skilled cybersecurity personnel for presentation to the defendant. The plaintiff sent timely invoices, but the defendant failed to make any payment. The plaintiff sued the defendant based on the reasons in Bhasin v. Hrynew, 2014 SCC 71 for dishonesty or bad faith in contractual dealings. The defendant allegedly hired the plaintiff with the intention of benefiting from its expertise, experience, and labour but did not intend to pay for the work required by the agreement. 

- Ruling: The court ruled in the plaintiff’s favour and ordered the defendant to pay $89,750 for the amount owing under the Bhasin claim and $30,000 in punitive damages, plus prejudgment interest, costs, and disbursements. The court held that the plaintiff established more likely than not its Bhasin claim against the defendant for bad faith in contractual dealings and alternatively under the quantum meruit doctrine. The court concluded that, given the circumstances, this was a “rare and exceptional” case where the defendant’s conduct justified a punitive damages award. The court found that the defendant more likely than not did not intend to honour the agreement at any time. 

- Date: The court released its decision on Nov. 22, 2024. 

- Venue: This was a case before the Supreme Court of Nova Scotia. 

- Amount: The court said that it would receive costs submissions from the plaintiff.