Manitoba’s proposed Limitations Act amendment would remove time limits on IPV civil claims
Survivors of intimate partner violence in Manitoba could soon have no deadline to sue their abusers in civil court. The Manitoba government has introduced proposed amendments to the Limitations Act that would remove time limits on civil claims arising from intimate partner violence involving coercive control.
Justice Minister Matt Wiebe made the announcement on October 5, 2026. The move directly addresses a gap left by the Supreme Court of Canada’s landmark May 2026 ruling, which created a new tort of intimate partner violence but did not set a limitation period.
What Manitoba’s bill would do
The proposed changes to the Limitations Act would allow survivors to pursue Manitoba intimate partner violence (IPV) civil claims regardless of when the abuse took place. The act already removes limitation periods for assault and sexual assault claims. This amendment extends that protection to claims involving coercive control.
The legislation recognises that survivors are often unable to come forward right away because of:
- trauma from the abuse
- safety concerns
- fear of retaliation
- the controlling nature of coercive control itself
Coercive control can take on several forms, such as:
- emotional abuse
- financial control
- surveillance
- isolation
Justice Minister Wiebe said the legislation “ensures arbitrary legal deadlines do not stand in the way of seeking justice,” and that by removing these limitation periods, “survivors can come forward when they are ready.”
Families Minister Nahanni Fontaine, who is responsible for women and gender equity, added that healing and recovery “happen on a survivor’s timeline, not the legal system’s timeline.”
The announcement also said that the “amendments follow a May 2026 Supreme Court of Canada ruling that recognized a new civil tort of intimate partner violence,” which refers to Ahluwalia v. Ahluwalia, 2026 SCC 16, decided on May 15, 2026.
How the Ahluwalia ruling created new tort
Writing for the majority, Justice Nicholas Kasirer in Ahluwalia recognised a new tort of IPV, centred on coercive control.
To establish liability under IPV, three conditions must be met:
- wrongful conduct occurred during or after an intimate partnership
- defendant intentionally engaged in the abusive conduct
- conduct constitutes coercive control
Notably, Justice Kasirer did not set a limitation period for this new tort. That gap is what Manitoba’s proposed amendments directly address.
Why existing torts fell short for survivors
The path of Ahluwalia in introducing the new tort of IPV began at the Ontario Superior Court of Justice in 2022, where Justice Renu Mandhane found that existing legal remedies did not go far enough. Mandhane created a tort of family violence and assessed damages of $150,000 against the defendant.
The Ontario Court of Appeal overturned that decision in 2023, finding that the existing torts of assault, battery, and intentional infliction of emotional distress were adequate. The court also reduced damages to $100,000.
The Supreme Court disagreed. In Ahluwalia, Justice Kasirer wrote that existing torts “cannot remedy the full scope of the injury inflicted by intimate partner violence,” finding that they force survivors to fit their experiences into legal categories that leave “aspects of the wrong and the injury unaddressed.”
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