By Majid Pourostad  ( November 3, 2025,  8:43 AM EST) -- As we discussed in the first article of this two-part series, the culture of ad hoc arbitration remains stronger than institutional arbitration in Canada. The Ontario Court of Appeal’s recent decision in Dhaliwal v. Richter International Ltd., 2025 ONCA 522 (Dhaliwal), released on July 15, 2025, once again brought Aroma Franchise Company, Inc. v. Aroma Espresso Bar Canada Inc., 2024 ONCA 839 (Aroma) back into focus....