Caledonia Service Station Inc. v. Cango Inc., 2011 ONCA 184, released today online, is a useful source of a definition for improvements and trade fixtures:
[14] This distinction accords with the ordinary meaning of improvements and trade fixtures in the law of real property: improvements refer to things constructed on and attached to the realty that are intended to become part of it; trade fixtures refer to things placed on and connected to the realty but in a way that the connection can be severed, restoring their character as chattels. See Stack v. T. Eaton Co. (1902), 4 O.L.R. 335 (Div. Ct.); Fas Gas Oil Ltd. v. J. H. Automotive Ltd. (2004), 31 Alta. L.R. (4th) 197 (C.A.); Beloit Sorel Walmsley, Ltd. v. New Brunswick (1976), 71 D.L.R. (3d) 240 (N.B.C.A.).
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