In Monenco Ltd. v. Commonwealth Insurance Co., 2001 SCC 49, the Supreme Court of Canada has reaffirmed the applicability of the "Pleadings Rule" in determining whether an insurer is bound to defend a claim. The court went on to state that in making this determination, courts could, in the appropriate circumstances, go beyond the pleadings and look to extrinsic evidence to determine the "substance" and "true nature" of the claim.

type Case Comment - Monenco Ltd. v. Commonwealth Insurance Co., 2001 SCC 49