shared citizenship and a common market. In that regard, For La Forest, the concern was to define an outer limit of comity. The solution was to limit the jurisdiction to where there is a "real and substantial connection" between the action and the province. He intentionally left the meaning of "real and substantial connection" open, stating: Aftermath The test established in this case was later elaborated on by the Court of Appeal for Ontario in Muscutt v Courcelles, where a list of eight factors was given to be considered when determining whether a real and substantial connection exists: the connection between the forum and the plaintiff's claim; the connection between the forum and the defendant; unfairness to the defendant in assuming jurisdiction; unfairness to the plaintiff in not assuming jurisdiction; the involvement of other parties to the suit; the court's willingness to recognize and enforce an extraprovincial judgment rendered on the same jurisdictional basis; whether the case is interprovincial or international in nature; and comity and the standards of jurisdiction, recognition and enforcement prevailing elsewhere. The Morguard principles were elaborated upon in subsequent cases, notably in: Hunt v T&N plc (where the Morguard principles were held to apply to constitutional challenges as well), and Beals v Saldanha (where the "real and substantial connection" test was applied in an international setting) See also List of Supreme Court of Canada cases References Conflict of laws case law Canadian civil procedure case law Supreme Court of Canada cases 1990 in Canadian case law