R v Zlatic
[1993] 2 SCR 29
Supreme Court of CanadaQuebec1993Whether reckless conduct can amount to 'other fraudulent means'
View source Case Overview
The accused diverted money owed to suppliers to fund personal gambling, contributing to business failure.
Legal Issue
Whether reckless conduct can amount to 'other fraudulent means'
Decision
Reckless, dishonest business conduct can constitute fraud, even without active deceit.
Why this Case Matters
Broadened the conduct that can ground a fraud conviction — dishonest risk-taking with other people's money qualifies.
What Changed Because of This Case
Made clear that 'other fraudulent means' is a distinct, conduct-based branch of the fraud offence.
Practical Implications for Investigators
Look beyond express misrepresentations — reckless misuse of entrusted funds can meet the actus reus.
Related Sections
Related Episodes
- Episode F1 — The Canadian Fraud Framework: From the Criminal Code to the Courts
- Episode F2 — R. v. Olan: Dishonesty, Deprivation, and the Foundation of Canadian Fraud Law
- Episode F3 — R. v. Théroux: The Modern Fraud Test
- Episode F4 — R. v. Zlatic: Other Fraudulent Means and Dishonest Business Conduct
- Episode F6 — Cox and Paton v. The Queen: Early Fraud and Conspiracy Foundations
- Episode F7 — How Olan, Théroux, Zlatic, and Riesberry Fit Together
- Episode F8 — Fraud Actus Reus: Deceit, Falsehood, and Other Fraudulent Means
- Episode F9 — Fraud Mens Rea: What Did the Accused Know?
- Episode F10 — Deprivation in Fraud: Actual Loss, Risk of Loss, and Economic Prejudice
- Episode F13 — Forgery, False Pretences, and Fraud: Understanding the Differences
- Episode F14 — Investment Fraud, Ponzi Schemes, and Dishonest Business Representations
- Episode F15 — Fraud Investigations: Evidence, Red Flags, and Practical Lessons
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