Last Updated: August 22 2026
In Ontario Small Claims Court, do judges have to explain their reasons for a decision?
Yes, judges in Small Claims Court must give reasons that explain both what was decided and why, so the parties can understand the outcome and, if needed, seek judicial review on appeal. In Elnasr v. Mostafa, 2022 ONSC 1735, the court confirms that even with the informal Small Claims process, the reasons must be sufficiently clear for meaningful appellate review, citing requirements reflected in cases like Maple Ridge Community Management Ltd. v. Peel Condominium Corp., 2015 ONCA 520. If you need help interpreting what “adequate reasons” means for your situation in Ontario, paralegals at Freed Legal Services can assist with next steps, call (800) 716-1897 to book a consult.
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Judges Are Required to Explain the Reasons for a Decision
A judge of any court, even the Small Claims court, is required to provide an explanation that explains what decision is made and why the decision is made. The mandate is known as the duty to provide reasons and is necessary to ensure that the parties to a dispute understand the reasoning for a decision as well as to ensure a review, if necessary, upon Appeal.
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The Law
Court judges, including judges within the Small Claims Court, are required to provide an explanation of the reasoning for which a decision is based. This requirement was explained within Elnasr v. Mostafa, 2022 ONSC 1735, wherein it was stated:
[28] In assessing the sufficiency of the Deputy Judge’s Reasons, I acknowledge the tremendous volume of matters in the Small Claims Court as well as the informal nature of the Small Claims Court. As stated in Maple Ridge Community Management Ltd. v. Peel Condominium Corp. No. 231, 2015 ONCA 520, 389 DLR (4th) 711, at paras. 34 and 35:
[34] The Small Claims Court is mandated under s. 25 of the Courts of Justice Act, R.S.O. 1990, c. C.43, to “hear and determine in a summary way all questions of law and fact and may make such order as is considered just and agreeable to good conscience.” The Small Claims Court plays a vital role in the administration of justice in the province by ensuring meaningful and cost effective access to justice for cases involving relatively modest claims for damages. In order to meet its mandate, the Small Claims Court’s process and procedures are designed to ensure that it can handle a large volume of cases in an efficient and economical manner.
[35] Reasons from the Small Claims Court must be sufficiently clear to permit judicial review on appeal. They must explain to the litigants what has been decided and why: Doerr v. Sterling Paralegal, 2014 ONSC 2335, at paras. 17-19. However, appellate consideration of Small Claims Court reasons must recognize the informal nature of that court, as well as the volume of cases it handles and its statutory mandate to deal with these cases efficiently. In short, in assessing the adequacy of the reasons, context matters: Massoudinia v. Volfson, 2013 ONCA 29, at para. 9. Just as oral reasons will not necessarily be as detailed as written reasons, reasons from the Small Claims Court will not always be as thorough as those in Superior Court decisions. Failing to take the Small Claims Court context into account only serves to restrict access to justice by unnecessarily imparting formality and delay into a legal process that is designed to be informal and efficient.
[29] Or, in other words, to permit meaningful appellate review, the reasons must adequately express “what” was decided and “why” it was decided, see: Maple Ridge, at para. 24; Law Society of Upper Canada v. Neinstein, 2010 ONCA 193, at para. 61.
[30] If the reasons are not sufficiently detailed to understand “the what” and “the why” for the decision under review, then this is an error in law and the standard of review is correctness, see Maple Ridge, at para 22; Barbieri v. Mastronardi, 2014 ONCA 416, at para. 22.
Conclusion
Judges, including Small Claims Court judge, must explain the basis for a decision. While the reasons may be expressed with less detail than a case in the higher court, the reasons must be sufficient for a review by an Appeal court if such situation were to occur.
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