A failure to give adequate reasons is not a free-standing basis for appeal. In Ecobase Enterprises Inc. v. Mass Enterprise Inc., 2017 BCCA 29, the British Columbia Court of Appeal dismissed an appeal where the appellant alleged the reasons for judgment were insufficient, but did not allege that the trial judge's crucial finding of fact was an error.
In Ecobase the sole issue on appeal was whether the trial judge's reasons addressing an estoppel defence were sufficient.
The dispute in Ecobase concerned business dealings between the respondent, Ecobase Enterprises Inc., and the appellant, Mass Enterprises Inc. In 2008, the parties entered into a "Joint Venture Agreement" to develop land in New Westminster. That project ultimately failed. To finance its investment Mass borrowed $150,000 from Ecobase. Mass never repaid this loan. Ecobase claimed against Mass for the amount of the loan plus interest.
At trial Mass argued Ecobase was estopped from enforcing its right to repayment of the loan. The defence of estoppel was dealt with summarily by the trial judge:
Mass relies on the doctrine of promissory estoppel to preclude Ecobase from enforcing the loan. To rely on this doctrine Mass must point to words or conduct on the part of Ecobase that are unambiguously intended to alter the relationship between the parties such that, Mass would be entitled to treat its obligation to pay the loan to have ended: Maracle v. Travellers Indemnity Co. of Canada,  2 S.C.R. 50. I cannot find Mr. Parvaresh spoke such words or conducted himself towards Mr. Tehrani to that effect. If there was to be forgiveness of the $150,000 loan, it was contingent on an agreement between Mr. Parvaresh and Mr. Tehrani for the former to purchase shares in Jupiter, and that never happened. In my view the doctrine of promissory estoppel plays no role in this matter.
The sole issue on appeal was whether this single paragraph addressing the estoppel defence was sufficient to permit appellate review.
Madam Justice Fenlon cited K.L.K. v. E.J.G.K., 2011 BCCA 276 at para. 25, for the test for sufficiency of reasons:
The function of reasons in the civil context is to justify and explain the result, to tell the losing party why he or she lost, to provide for informed consideration of the grounds of appeal, and to satisfy the public that justice has been done: F.H. v. McDougall, 2008 SCC 53,  3 S.C.R. 41.
Sufficiency of reasons is not a free-standing basis for appeal. An appellate court cannot intervene merely because it believes the trial judge did a poor job of expressing himself or herself: para. 7. And a decision should not be set aside if the record permits meaningful review, even where the logical connection between the evidence and the decision cannot be discerned: para. 9.
The appellant did not challenge the judge's crucial finding of fact regarding an element of estoppel. The appellant challenged only the sufficiency of the judge's reasons. The trial judge was not required to refer to all of the evidence tendered by the parties: para. 21.The reasons read in the context of the record as a whole adequately explained the "why" of the finding on estoppel and permitted appellate review. The reasons therefore met the standard for sufficiency. The appeal was dismissed.