Law360 Canada ( June 26, 2026, 2:52 PM EDT) -- Appeal by Fayant from an order declaring that transfer of property from Poitras to her was at undervalue and requiring her to pay the shortfall to the bankrupt estate. Forester, Poitras’s former spouse, was his principal unsecured creditor by virtue of a family property judgment that awarded her a substantial equalization payment and costs. Before that judgment was issued, but after the family proceedings had begun, Poitras transferred an acreage to his mother. In the transfer documents, the acreage was valued at $162,000. In the earlier family property litigation, however, Poitras  swore that the acreage was worth $300,000, listed it for sale at higher amounts, and the trial judge ultimately valued it at $300,000. After the family property judgment, Poitras made an assignment into bankruptcy. Because the trustee declined to pursue the transfer-at-undervalue claim, Forester obtained leave to do so. Fayant opposed the application, arguing that Forester’s claim was not provable in bankruptcy and that the statutory requirements for relief were not met. On the merits, she disputed the acreage’s value, maintained that the consideration Poitras received was not conspicuously less than fair market value, and challenged reliance on findings made in the family property judgment. The chambers judge rejected those positions. Fayant argued that the chambers judge erred by relying on the family property judgment as evidence of value and intention, by effectively reversing the onus of proof, and by failing to properly apply the test for whether the consideration was conspicuously less than fair market value. Forester responded that the evidentiary objection to the family property judgment was a new argument raised for the first time on appeal....