Motion to set aside order should be brought in proceeding where order made

Cunningham v. Moran, 2011 ONCA 476 deals with many issues regarding the intersection of family law and civil litigation. One statement of general importance deals with setting aside an order:

[52]         Absent special circumstances, in order to set aside an order in a particular proceeding, in our view, a party should apply for relief in that proceeding. To hold otherwise would be to sanction multiplicity of proceedings. To the extent that Lawyers' Professional Indemnity Co. v. Geto Investments Ltd. (2001), 54 O.R. (3d) 795 (S.C.) may suggest otherwise, we disagree with it.