What is authority that there must be an express request or request by implication from a person to be charged with a lien?

Alberta, Canada


The following excerpt is from Sparky’s Electrical Services Ltd. v. Dencass Canada Inc., 2002 ABQB 264 (CanLII):

Hamilton v. Cipriani, [1977] 15 S.C.R. 169 is authority that there must be an express request or a request by implication from the circumstances in order to give rise to lien rights against persons to be charged.

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