Can the tort of intentional infliction of mental suffering be extended to the same tort of unlawful interference with another's relationship?

Canada (Federal), Canada

The following excerpt is from Frame v. Smith, [1987] 2 SCR 99, 1987 CanLII 74 (SCC):

45. Counsel for the appellant submitted that the torts of intentional infliction of mental suffering and unlawful interference with another's relationship could cover the facts as pleaded. It may well be that the tort of intentional infliction of mental suffering could be extended to cover the facts alleged by the appellant. The requirements of this cause of action were set out in the case of Wilkinson v. Downton, [1897] 2 Q.B.D. 57. In that case the defendant as a "practical joke" told the plaintiff that her husband had been involved in an accident and had broken his legs. The plaintiff believed the defendant and as a result suffered nervous shock and a number of physical consequences. In granting recovery, Wright J. stated (at p. 59): One question is whether the defendant's act was so plainly calculated to produce some effect of the kind which was produced that an intention to produce it ought to be imputed to the defendant, regard being had to the fact that the effect was produced on a person proved to be in an ordinary state of health and mind. I think that it was. It is difficult to imagine that such a statement, made suddenly and with apparent seriousness, could fail to produce grave effects under the circumstances upon any but an exceptionally indifferent person, and therefore an intention to produce such an effect must be imputed, and it is no answer in law to say that more harm was done than was anticipated, for that is commonly the case with all wrongs. The other question is whether the effect was, to use the ordinary phrase, too remote to be in law regarded as a consequence for which the defendant is answerable.

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