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The Alberta Court of Appeal (the “ABCA”)’s anticipated decision in Manitok Energy Inc (Re), 2022 ABCA 117 (“Manitok”) confirmed that the sales proceeds of a debtor estate’s valuable petroleum and natural gas assets that are subject environmental claims including, notably, abandonment and reclamation obligations, must first be applied to abandonment and reclamation obligations, even where such assets are “unrelated” to the abandonment and reclamation obligations.

A recent unreported decision in the Alberta Court of Queen’s Bench has clarified the ranking of certain municipal tax claims against a bankrupt in Alberta. In Bank of Nova Scotia et al v. Virginia Hills Oil Corp.