Civil Litigation10 min read

Ontario Class Action Law: Certification, Common Issues & Settlement Approval

Class Proceedings Act 5-part certification test, preferable procedure analysis, carriage motions, settlement approval (Dabbs factors), and cy-pres awards for Ontario class action practitioners.

Updated June 2025

Ontario's Class Proceedings Act, 1992 (CPA) provides the framework for class action litigation — one of the most complex and high-stakes areas of civil practice. Ontario is one of Canada's most active class action jurisdictions. This guide covers the certification test, strategic considerations, carriage disputes, and settlement approval requirements that Ontario class action practitioners navigate.

The 5-Part Certification Test (s. 5 CPA)

Certification is the gateway to a class proceeding. The plaintiff bears the burden on all five elements. The standard for factual assertions is "some basis in fact" — not a balance of probabilities. The certification motion is not a merits hearing.

Cause of Action

s. 5(1)(a)

Standard: Pleadings must disclose a cause of action — same test as motion to strike; accepts all pleaded facts as true

Key point: The lowest bar — courts are very reluctant to refuse certification on this element alone; bare minimum pleading requirements

Identifiable Class

s. 5(1)(b)

Standard: Class can be defined by reference to objective criteria — not dependent on merits of the claim; must be possible to determine membership

Key point: Class definition is a key strategic decision — too narrow loses class members, too broad creates manageability problems; class can be defined by reference to a date range, geographic area, or type of transaction

Common Issues

s. 5(1)(c)

Standard: Issues common to all class members — success for one class member must advance the position of all. Need not be determinative of liability; even one common issue can support certification

Key point: Defendants argue individual issues predominate; plaintiffs argue common issues advance the litigation even if individual issues remain. The 'some basis in fact' standard applies to factual assertions — not a full merits hearing

Preferable Procedure

s. 5(1)(d)

Standard: Class action must be preferable to other available means (individual actions, regulatory proceedings, etc.) for resolving common issues

Key point: Two-branch test: objectives (behaviour modification, judicial economy, access to justice) and manageable (workable litigation plan). Not required to be perfect — only preferable

Representative Plaintiff

s. 5(1)(e)

Standard: Representative plaintiff must: fairly and adequately represent class interests; have a workable litigation plan; have no conflict of interest with class members

Key point: Defendants regularly challenge adequacy of representative plaintiff. Disqualifying conflicts include claims that differ materially from the class, or undisclosed financial arrangements

Common Issues: Strategy & Framing

The common issues element is typically the most contested at certification. Plaintiffs frame issues broadly to encompass the class; defendants argue individual issues predominate. Post-certification, common issues are tried first; individual issues (damages, causation) follow in individual proceedings or aggregate damages.

What qualifies as a common issue
An issue that, when resolved in the plaintiff's favour, advances each class member's claim. Need not determine liability completely — partial resolution is enough.
Aggregate damages (s. 24)
Courts can assess and award aggregate damages without individual proof of loss if: the nature of the right supports it and individual determination is impractical or unnecessary.
Waiver of tort / gain-based damages
In some class actions plaintiffs claim disgorgement of defendant's gains rather than loss-based compensation — particularly in consumer protection and data breach cases.
Individual issues management
After common issues trial, individual class members may claim their individual damages in a reference, through a claims process, or in individual proceedings as ordered by the court.
Reverse bifurcation
Some courts permit trial of aggregate damages before individual causation — practical where defendant's liability is clear and aggregate harm is provable without individual proof.
Issue certification
Courts sometimes certify only specific common issues rather than the full proceeding — useful where some claims are suitable for class treatment but others are not.

Settlement Approval: The Dabbs Factors

Under s. 29 CPA, any settlement, discontinuance, or abandonment of a class proceeding requires court approval. The leading case is Dabbs v. Sun Life Assurance (1998), which identified the factors Ontario courts apply.

1
Likelihood of recovery at trial
Probability that the class would succeed at trial on liability; strength of the defendants' defences
2
Amount offered vs. potential at trial
Whether the settlement amount represents a fair proportion of what the class could recover if successful — discounted for risks
3
Complexity, expense, and duration of continued litigation
Class actions are expensive and slow; settlement avoids years of additional proceedings and appeals
4
Views of class members
Number and quality of objections; opt-out rate; support or opposition expressed at the fairness hearing
5
Recommendations of class counsel
Experienced class action counsel's view that the settlement is fair is entitled to weight — but not determinative
6
Good faith negotiations
Evidence that negotiations were arm's-length and adversarial; absence of collusion; mediator involvement is persuasive

Cy-Pres Awards

Where unclaimed or undistributed settlement funds remain after the claims process, courts may approve cy-pres distribution to charitable or non-profit organizations with a nexus to the class's interests or the subject matter of the litigation. Cy-pres recipients must be approved by the court; class counsel typically proposes candidates and the court scrutinizes the nexus and the organizations' independence.

Carriage Motions

Where multiple plaintiff firms file competing class actions arising from the same facts, a carriage motion determines which counsel proceeds. Courts apply a multi-factor analysis with no single determinative criterion.

Nature and scope of causes of action — breadth and creativity of theories
Proposed class definition — who is included and excluded
State of the proceedings — who acted first and with what diligence
Resources and experience of counsel — class action track record
Funding arrangements and litigation risk
Proposed fee arrangement — reasonableness of counsel fees

Frequently Asked Questions

What is the test for certification of a class action in Ontario?

Under s. 5(1) of the Class Proceedings Act, 1992, a proceeding may be certified as a class action if: (1) the pleadings disclose a cause of action; (2) there is an identifiable class of two or more persons; (3) the claims of the class members raise common issues; (4) a class action is the preferable procedure for resolution of the common issues; and (5) there is a representative plaintiff who will adequately represent the class, has a workable litigation plan, and has no conflict of interest with class members. All five criteria must be met.

What does 'preferable procedure' mean in Ontario class action certification?

The preferable procedure requirement (s. 5(1)(d) Class Proceedings Act) asks whether a class action is preferable to other available means of resolving the common issues. Courts apply two branch analysis: (1) does the class action satisfy the objectives of behaviour modification, judicial economy, and access to justice better than other alternatives?; (2) is the class action manageable, given the nature of the common issues and the proposed litigation plan? A class action need not be the perfect procedure — only the preferable one.

What is a carriage motion in Ontario class actions?

When multiple law firms file competing class action proceedings arising from the same events, a carriage motion determines which firm will have carriage (control) of the litigation. Courts assess: the nature and scope of the causes of action advanced; the theories of liability; the proposed class definitions; the state of each proceeding; the resources and experience of counsel; and the fees proposed. Carriage motions are decided before certification.

How is a class action settlement approved in Ontario?

Under s. 29 of the Class Proceedings Act, a class action settlement requires court approval. The court must be satisfied the settlement is fair, reasonable, and in the best interests of the class as a whole. The hearing requires: notice to class members, opportunity for class members to object, class counsel's fees approval (separate from settlement), and affidavit evidence on the negotiations and settlement factors. Courts apply the Dabbs factors: likelihood of recovery, amount offered vs. amount achievable at trial, complexity and cost of continued litigation, views of class members, and class counsel's views.

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