Executive Summary: Key Legal and Evidentiary Issues

• Alleged reputational harm to Injection SF inc. from negative Google Reviews and threats by former employees.
• Disputed authorship and veracity of online reviews, including use of false identities purporting to be clients.
• Application of Quebec’s criteria for provisional interlocutory injunctions, focusing on serious issue, irreparable harm, and balance of convenience.
• Evaluation of evidence of actual or imminent economic loss, client loss, or measurable reputational damage.
• Interplay between civil liability (arts. 3, 1457 C.c.Q.) and Charter protection of reputation and dignity (arts. 4, 49 of the Quebec Charter).
• Procedural consequences for unrepresented defendants who must file a response or risk a default judgment later in the case.

Facts of the case

Injection SF inc. is a Québec company that has been operating for approximately 13 years in the business of repairing and refurbishing foundations, concrete slabs and installing French drains for residential clients. It employs around five employees, and Mr. Steve Rose is its sole shareholder and administrator. The company alleges that, on 1 April 2026, it received threats from a former employee, Jonathan Woods-Wright. According to the company, Woods-Wright threatened to damage its reputation with clients by spreading negative information about it. On the same date, three negative Google Reviews were posted on the company’s Google profile page. One of these reviews was taken down the next day, 2 April 2026. The company contends that a second review was written by another former employee, Samuelsson Arseneault, who allegedly pretended to be a client. A third review was posted under the pseudonym “Ernest Naica,” from an unknown author who also allegedly presented himself falsely as a client of the business. The plaintiffs, Injection SF inc. and Steve Rose, claim that these actions constitute an attack on the company’s reputation and standing in the marketplace.

Procedural posture and nature of the relief sought

On 8 April 2026, the plaintiffs filed an originating application seeking a provisional interlocutory injunction, an interlocutory injunction, a permanent injunction and damages. They framed their recourse under both civil liability principles and human rights protections. Specifically, they relied on articles 3 and 1457 of the Civil Code of Québec (C.c.Q.), which govern civil responsibility and the protection of personality rights, and on articles 4 and 49 of the Charte des droits et libertés de la personne (Quebec Charter), which protect dignity, honour and reputation and provide for recourses where these rights are unlawfully infringed. The judgment at issue is rendered at the provisional stage only. The Superior Court, presided over by Justice Jean-François Roberge, was asked to decide whether a provisional interlocutory injunction should issue immediately, based on the evidence available at this early point, to urgently curb the alleged reputational harm from the online reviews and threats.

Legal framework for provisional interlocutory injunctions

The Court restated the three cumulative criteria that must be met for an interlocutory injunction in Québec. First, there must be a serious issue to be tried, meaning that a preliminary review of the file shows a sufficient appearance of right on the merits. Second, the applicant must demonstrate a serious, even irreparable, harm that will occur if the injunction is not granted while awaiting a judgment on the merits. Third, the balance of convenience or preponderance of inconvenience must favour the applicant, such that it would suffer greater prejudice than the respondent if the injunction were refused. These criteria, derived from articles 510 and 511 of the Code of Civil Procedure and relevant appellate and Supreme Court jurisprudence, are assessed globally and are interrelated; the court weighs them in light of the circumstances. At the provisional stage, the injunction is an exceptional and temporary measure that addresses urgent situations where serious, imminent and irreparable harm is about to occur. The harm cannot be merely hypothetical, speculative or based on conjecture. A lack of urgency is fatal at this provisional step, even if the same relief might still be considered at a later interlocutory hearing with fuller evidence.

Application of the criteria to the evidence

In analyzing the evidence, the Court focused in particular on the second criterion: the existence of serious, irreparable and imminent harm. The plaintiffs asserted that the two remaining negative Google Reviews and the alleged threats of denigration by former employees posed an acute risk to the company’s reputation and economic viability. However, the judge found that there was no concrete evidence at this stage that any client had decided not to retain Injection SF inc.’s services as a result of the reviews or threats. There was also no prima facie proof of a decline in revenue or of any measurable decrease in the firm’s business volume attributable to the impugned online postings. Similarly, there was no evidence before the Court that existing or potential clients currently held negative views about the company because of these reviews. The Court did not exclude the possibility that reputational harm might arise over the medium or long term if the situation persisted, but at this moment such harm remained hypothetical and not supported by specific, immediate factual proof. As a result, the requirement of imminent serious or irreparable harm was not met, and the urgency needed for a provisional order was absent.

No discussion of insurance or policy clauses

The decision does not involve insurance coverage issues or the interpretation of policy terms. The legal analysis is framed entirely around general civil liability provisions (arts. 3, 1457 C.c.Q.), fundamental rights under the Quebec Charter (arts. 4, 49) and the procedural law governing injunctive relief in the Code of Civil Procedure. There are no clauses from insurance policies or other contractual documents that the Court is asked to interpret or apply. The case is instead concerned with how online statements and threats by former employees may engage civil fault and reputational harm, and with whether those alleged wrongs justify urgent injunctive relief.

Outcome, next steps in the case and successful party

Because the criteria for a provisional interlocutory injunction are cumulative, the Court held that the failure to establish serious, irreparable and imminent harm was enough to dispose of the request at this stage. It therefore rejected the application for a provisional interlocutory injunction. The judge emphasized, however, that this refusal does not predetermine the fate of any later interlocutory or permanent injunction request. Any subsequent application will be considered anew, de novo, on the basis of whatever additional evidence is then presented, and this provisional ruling does not bind the judge who will hear the matter at a later stage. The judgment also reminded the defendants, Jonathan Woods-Wright and Samuelsson Arseneault, that they are required to file a response in the court file, set out their defences and consider negotiation. If they fail to respond, they risk having a default judgment rendered against them later in the proceedings. In terms of present relief, the Court simply dismissed the plaintiffs’ request for a provisional interlocutory injunction, and it did so “without costs,” meaning no judicial fees were ordered against either side at this point. Consequently, in this particular decision, the effective successful parties are the defendants, because the injunctive relief sought by the plaintiffs was rejected, and there was no damages award or costs ordered in anyone’s favour; the total monetary award, including costs or damages, cannot be determined as any positive amount and stands at zero in this ruling.