Page: 26 Proceedings of the Standing Senate Committee on Legal and Constitutional Affairs (5 April [62] While such statements are of assistance in understanding the intent of the proponents of a legislative measure, they do not determine the parliamentary intent. Applying the ordinary dictionary definition of the word, fraud is 1) the action or an instance of deceiving someone in order to make money or obtain an advantage illegally, 2) a person or thing that is not what it is claimed or expected to be, 3) a dishonest trick or stratagem: Concise Canadian Oxford Dictionary, 2005 ed, sub verbo “fraud”. [63] The concept of fraud invalidating transactions of a civil nature has a long history in the common law. In civil law, fraud is a knowing misrepresentation of the truth or concealment of a material fact giving rise to a claim of damages for the loss sustained or the avoidance of a contract: Bryan A Garner, ed, Black’s Law Dictionary, 7th ed (St Paul, Minnesota: West Group, 1999). [64] As discussed by Justice Lederer at para 47 of Wrzesnewskyj, above: Fraud is proved when it is shewn that a false representation has been made (1) knowingly, or (2) without belief in its truth, or (3) recklessly, careless whether it be true or false." (see: Derry v. Peek, [1886-1890] All E.R. Rep. 1 (H.L.); adopted in Vale v. Sun Life Assurance Co. of Canada, [1998] O.J. No. 6465 at para. 18 (Gen. Div.) (QL); and, Gregory v. Jolley, [2001] O.J. No. 2313 at para. 15 (C.A.) (QL); as quoted in Canada v. Granitile Inc., 2008 CanLII 63568 (Ont. Sup. Ct. J.) at para. 286). 2013 FC 525 (CanLII) 2000).