In Fraternal Order of Eagles Winnipeg Aerie No. 23 v. Blumes,  M.J. No. 347 (Man. C.A.) the court at paragraph 35 stated that, ...if a claim for contribution is to succeed the person from whom recovery is sought must “have been liable” to the victim. But there is clear authority for the proposition that the execution of a release does not per se immunize from third party proceedings a party otherwise liable to the victim... If the immunity from liability arises not from the circumstances that give rise to the claim itself but from an independent transaction or settlement made after the cause of action arose, this is not a bar to the released party being sued for contribution or indemnity.
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