April 10, 2026. News Release. Manitoba Adds Nearly 11,000 New Jobs in March Manitoba’s employment growth outpaced the national average in March, reflecting broad-based strength across the provincial economy and continued confidence in Manitoba’s labour market.
April 10, 2026. News Release. Hot Water Required at Large Construction Sites The Manitoba government is taking action to strengthen workplace health by requiring hot water for handwashing at larger construction sites, Labour and Immigration Minister Malaya Marcelino announced today. […] The new requirements will come into effect April 1, 2027, giving employers time to prepare and transition.
April 11, 2026. News Release.Province Updates 2026 Spring Flood Outlook Manitoba Transportation and Infrastructure’s Hydrologic Forecast Centre is updating its 2026 spring flood outlook, indicating increased flood risk in the Interlake region including the Icelandic River and Fisher River basin, as well as an elevated risk of overland flooding in the Parkland region. Flood risk remains moderate to low elsewhere in the province.
April 13, 2026. Media Bulletin. Standing Hearing for Inquest into Deaths of Patrick Eaglestick, Farron Rowan, Melvis Owen, Adrian Young and Curt Harper Before the inquest begins, the Judge will decide who can participate in the process and question witnesses. Individuals and groups may make an application to be granted standing and participate in the inquest. Those interested in applying for standing should contact Aaron Braun, inquest counsel, at (204) 982-4414 or abraun@sccmlaw.ca by May 20, 2026. The standing hearing will be held at 10 a.m. on June 3, 2026, in courtroom 402 at the Manitoba Law Courts Complex, 408 York Ave., Winnipeg.
April 13, 2026. News Release. Premier Welcomes Nobel Laureate Geoffrey Hinton to Manitoba The Manitoba government, through the Department of Innovation and New Technology, is studying the recommendations in a report produced by the Innovation and Productivity Task Force. The report offers guidance on building an independent, value-added economy to the benefit of all Manitobans.
April 16, 2026. News Release.Manitoba Government Creates Nearly 1,900 Jobs for Young Manitobans Non-profit organizations, education authorities, Northern Affairs Community Councils and municipal governments are awarded the Urban/Hometown Green Team grants to hire youth between the ages of 15 and 29 to work on community projects between May and September. For more information on the Urban/Hometown Green Team program, visit gov.mb.ca/grants/.
Public Service Act (April 8, 2026) – Fanaye Humes is appointed to the position of Executive Assistant
Education and Early Childhood Learning
Education Administration Act (April 8, 2026) – Order in Council 297/2024 appointing Bobbi Taillefer as Commissioner under The Education Administration Act is revoked.
Finance
Public Service Act (April 8, 2026) – Bradford Gyselman is appointed to the position of Graphic Designer.
Health, Seniors and Long-Term Care
Hearing Aid Act (April 8, 2026) – Justyn Pisa of Winnipeg is designated as a member and as chair of The Hearing Aid Board.
Labour Relations Act (April 8, 2026) – Krista Klassen is appointed as a part-time Vice-Chairperson and member of the Manitoba Labour Board
President of the Executive Council
Executive Government Organization Act (April 9, 2026) – The MMIWG2S+ and Gender-Based Violence Committee of Cabinet is continued consisting of Honourable Nahanni Fontaine, Chairperson, Honourable Bernadette Smith, Vice-Chairperson, Honourable Matt Wiebe, Honourable Ian Bushie, Billie-Jo Marie Cross, MLA, Logan Jax Oxenham, MLA
Public Service Delivery
Public Service Act (April 8, 2026) – Keri Ranson is appointed to the position of Public Guardian and Trustee
April 1, 2026. Media Bulletin. Provincial Minimum Wage to Increase to $16.40 on Oct. 1 Manitoba Labour and Immigration is notifying Manitobans the provincial minimum wage will increase by 40 cents to $16.40, effective Oct. 1.
The Legislative Assembly of Manitoba
Third Session, Forty-Third Legislature
Private Members’ Bills
Introduced
Bill 234The Registered Landscape Architects Act/Loi sur les architectes paysagistes – The Registered Landscape Architects Act is established to provide self-governing authority for and title protection to landscape architects. The Manitoba Association of Landscape Architects becomes the profession’s regulatory body and a governing council is established with public representatives. Only registered members can use the title “Registered Landscape Architect”. A process is created for complaints against and discipline of members.
The Building and Electrical Permitting Improvement Act (Various Acts Amended and Permit Dispute Resolution Act Enacted) Schedule C — The Manitoba Hydro Amendment Act (whole act)
Financial Admin Act, Appropriation Act, MB Dev. Corp. Act (March 18, 2026) – The Minister of Business, Mining, Trade and Job Creation requests that Manitoba make a loan to JasperVOCAL Inc. in the amount of $475,000. The Loan is to be administered by MDC, as agent for Manitoba.
Finance
Securities Act (March 25, 2026) – Douglas Brown is appointed as a member and designated as Chair of the Commission.
Health, Seniors, and Long Term Care
Public Service Act (March 25, 2026) – Selam Beyene is appointed to the position of Executive Assistant.
Housing, Addictions and Homelessness
Public Service Act (March 25, 2026) – Keigan Buckley is appointed to the position of Press Secretary.
Innovation and New Technology
Research Manitoba Act (March 18, 2026) – The board of directors of Research Manitoba is appointed for 2026-2027.
Justice and Attorney General
Provincial Court Act (March 18, 2026) – The following persons are appointed as staff justice of the peace in and for the Province of Manitoba: Gena May Francisco, of Mitchell; Cheryl Koss, of Winnipeg; and Chantell Vaillancourt-Ducharme, of The Pas. The appointment of Oluwagbemisola Onigbogi as staff justice of the peace in and for the Province of Manitoba is revoked.
Justice
Public Service Act (March 18, 2026) – Hannah Janzen is appointed to the position of Special Assistant.
Provincial Court Act (March 25, 2026) – A. Blair Graham, K.C., is appointed as a member and chairperson of the Judicial Compensation Committee. Bernice Bowley and Kris Dangerfield are appointed as members of the committee.
Minister responsible for the Manitoba Public Service Act
Public Service Act (March 18, 2026) – The Minister responsible for the Manitoba Public Service is authorized to enter into a collective agreement, inclusive of a pay plan, on behalf of the government, with the Canadian Union of Public Employees (CUPE) Local 2153 respecting Family Support Workers and Emergency Placement Resources who are employed primarily with the Department of Families.
Crown Lands Act (March 24, 2026) – The administration and control of all interests held by His Majesty the King in right of Manitoba, […] is transferred to His Majesty the King in right of Canada: Sapotaweyak Cree Nation Swan River Phase 3 Indian Reserve In the Province of Manitoba.
Crown Lands Act (March 24, 2026) – The following Crown (Manitoba) land (“Land”) is set aside as an area to enable the Government of Canada (“Canada”) to fulfil a portion of its obligations to the Bunibonibee Cree Nation under the adhesion to Treaty No. 5:
Trout Falls Site 15-02 and now named Nahmakos Pahwestik Indian Reserve In the Province of Manitoba
Wipanipanis Portage Site 20-02 and now named Wapinapanis Indian Reserve In the Province of Manitoba
Crown Lands Act (March 24, 2026) – The following Crown (Manitoba) land (“Land”) is set aside as an area to enable the Government of Canada (“Canada”) to fulfil a portion of its obligations to the Norway House Cree Nation under the adhesion to Treaty No. 5: Lebrix Lake A In the Province of Manitoba
Crown Lands Act (March 24, 2026) – The following Crown (Manitoba) land (“Land”) is set aside as an area to enable the Government of Canada (“Canada”) to fulfil a portion of its obligations to the Wuskwi Sipihk First Nation under the adhesion to Treaty No. 4: Wuskwi Sipihk First Nation Mistikoskak Sipihk Reserve In the Province of Manitoba
Crown Lands Act (March 24, 2026) – The administration and control of all interests held by His Majesty the King in right of Manitoba […] in the following described land is transferred to His Majesty the King in right of Canada: Site 4-11 In the Province of Manitoba
Sport, Culture, Heritage and Tourism
Public Service Act (March 25, 2026) – Lucie Besken is appointed to the position of Executive Assistant to the Minister.
March 24, 2026, News ReleaseManitoba Government Announces Budget 2026 “With the lowest deficit-to-gross domestic product ratio in Canada, the Manitoba government’s Budget 2026 makes responsible investments that aligns with Manitobans’ priorities while making progress on the path to balance the budget within four years, Finance Minister Adrien Sala announced today.”
March 25, 2026, News ReleaseManitoba Government Makes Groceries More Affordable “The Manitoba government will save Manitobans $24 million by removing provincial sales tax (PST) from all grocery food items, Premier Wab Kinew announced today.”
This release features updates to the case law and commentary in Chapter 21. Occupiers’ Liability.
Highlights
CHAPTER 21. OCCUPIERS’ LIABILITY-INVITEE An invitee is a person who comes on the occupier’s premises at the invitation of the occupier on a matter of common interest. The invitation may be express or implied. In the absence of an express invitation, however, the courts are reluctant to extend the doctrine of implied invitation. An implied invitation is not shown by mere tolerance of a trespass or passive acquiescence in permitting a person upon the premises or by use without the owner’s knowledge. However, where the use has continued for so long as to lead the public to think that the owner invited such use, liability has been held to arise.
CHAPTER 21. OCCUPIERS’ LIABILITY-LICENSEES A licensee is a person who enters on premises with the permission of the occupier on a matter concerning the licensee and in which the occupier has no interest. Although the occupier has not invited the licensee onto the premises and has no interest in them being there, the occupier has expressly permitted the licensee to use the premises or knows about their presence on the premises. Furthermore, the occupier has either given permission to remain on the premises or has done nothing to stop their further presence there. Thus, the main distinction between an invitee and a licensee is that an invitor and invitee have a common interest, but the licensor and licensee do not.
CHAPTER 21. OCCUPIERS’ LIABILITY-ELEMENTS OF CAUSE OF ACTION For the plaintiff to succeed in an action based on occupiers’ liability, the following four elements must be established – that the defendant was an occupier of the premises on which the accident occurred; that the defendant breached a duty of care owed to the plaintiff; that the defendant’s breach caused the plaintiff’s injury; and that the plaintiff suffered damage. This applies whether the action is brought in New Brunswick, Newfoundland and Labrador, Saskatchewan, and The Territories (Yukon, Northwest Territories, and Nunavut) within a common law approach to occupiers’ liability or in Alberta, British Columbia, Manitoba, Nova Scotia, Ontario, and Prince Edward Island under a statutory framework.
This release features updates to Appendix IF – Issues in Focus, Appendix SLL – Selected Legal Literature and Appendix WP – Words and Phrases.
Highlights
Appendix WP. Words and Phrases–Procedural Fairness Procedural fairness comprises the right to be heard and the right to an impartial hearing: Sull v. Trevitt (2025) CarswellBC 2114, 2025 BCSC 1366 (B.C. S.C.) at para. 22 Chan J.
Circumstantial Evidence Circumstantial evidence tends to establish those facts which are at issue at trial, but it does so indirectly (…). It concerns the proof of facts from which inferences can be drawn about the facts relevant to the legal issue under consideration (…). Each piece of evidence need not alone lead to the conclusion sought to be proved, and pieces of circumstantial evidence can be combined to justify the inference that a certain fact or state of mind exists (…): R. v. Rioux (2025), 2025 CSC 34, 2025 SCC 34, 2025 CarswellQue 11393 (S.C.C.) at para 58 Per Martin J. (Karakatsanis, Kasirer, Jamal, O’Bonsawin JJ. concurring).
Chapter 4 — Will Planning The entire chapter has been reviewed and refreshed. Commentary has been significantly updated under the headings for the Terminal Year regarding Compliance with Statutory Conditions, Shares of a Private Corporation, and Charitable Donations. Also, under the main heading for The Estate, The Testamentary Trust and the Beneficiaries for subheadings Facilitating Post Mortem Planning regarding Separate Testamentary Trusts, and Post-Mortem Contributions.
Chapter 6 — Gifts and Trusts Inter Vivos The entire chapter has been reviewed and refreshed. Commentary has been significantly updated under the headings of Income Taxation Affecting Gifts and Transfers to and From Personal Trusts Inter Vivos General comments, and Gifts of Farm or Fishing Property. A new section, Loss Restriction Events, has been added to the end of the chapter.
In this release, the author has prepared a new Year in Review, updated practice directions, legislation, and the prejudgment and post judgment interest rates.
Highlights
Chapter 5 – Forms The forms have been relaunched in this release to enable linking to the fillable forms in the electronic versions of this publication.
Chapter 7 – Miscellaneous – Court of King’s Bench and Court of Appeal Notices and Practice Directions The following Practice Directions have been added:
Re: Length and Formatting of Application and Motion Briefs (October 2, 2025)
Re: Change to Teleconference Numbers for Associate Judges Uncontested List (October 28, 2025)
Re: Anonymizing Pleadings and the Contents of Publicly Available Court Records (December 10, 2025)
Re: Self-Representing Litigants on Civil Applications and Motions (December 10, 2025)
The following Court of Appeal Notices have also been included:
Re: Hours of Registry Counter Services (October 1, 2025)
Re: Judges’ Books of Authorities (October 24, 2025)
Re: Security for Costs Required in Motions Requesting a Rehearing (December 4, 2025)
Appendix D – Recent Developmentsin Civil Litigation Year in Review–2025 The 2025 Year in Review lists some of the notable trends and developments in civil litigation in Manitoba from January 1 to December 31, 2025. The topics covered include – a review of practice directions issued by the Court of Appeal and the Court of King’s Bench in 2025; commentary on Notable decisions of the Manitoba Courts dealing with issues of civil procedure; and a comment on the report of the Civil Rules Working Group in Ontario.
The Manitoba Law Library would like to acknowledge with gratitude that we are situated on Treaty One Territory, the traditional lands of the Anishinaabe, Cree and Dakota peoples, and the homeland of the Métis Nation.
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