Definity Insurance won every substantive issue in an accident benefits fight - then paid nearly $1,900 over one missing line in a denial letter.
In a decision released April 10, 2026, the Ontario Licence Appeal Tribunal ruled that Definity Insurance Company must pay $1,874.96 for a chiropractic treatment plan - not because the treatment was warranted, but because the insurer's denial notice failed to check a critical procedural box.
The case, Bhambra v. Definity Insurance Company, 2026 ONLAT 24-008013/AABS, stems from a March 9, 2023 automobile accident involving Sukhjit Bhambra. Following the accident, Bhambra sought a range of benefits from Definity, including removal from the Minor Injury Guideline, several chiropractic treatment plans, and a non-earner benefit of $185.00 per week.
Adjudicator Amar Mohammed sided with Definity on nearly every count. Bhambra's injuries - cervical, lumbar, and shoulder strains - fell squarely within the Schedule's definition of a minor injury, which covers sprains, strains, whiplash associated disorders, contusions, abrasions, lacerations, and subluxations. The Tribunal found the applicant had not produced medical evidence to support any of her arguments for removal from the MIG, whether based on the combination of multiple strains, psychological impairment, or pre-existing conditions such as pre-traumatic headaches and osteoarthritis.
The non-earner benefit claim fared no better. Under the test set out in Heath v. Economical Mut. Ins. Co., the applicant needed to show a complete inability to carry on a normal life by comparing pre- and post-accident activities. Records from her own family doctor, Dr. Peter Nord, showed Bhambra attending the gym four times a week and walking one kilometre daily - a picture that did not square with the claim.
A request for a penalty award was also turned down. The Tribunal noted that errors or mistakes, without more, do not amount to the kind of unreasonable conduct that triggers an award.
Where Definity stumbled was on paperwork. Ontario's accident benefits rules require insurers to explain why they are denying a treatment plan within 10 business days and, crucially, to state that the Minor Injury Guideline applies. When an insurer skips that step, the rules say the plan must be paid. The Tribunal found that Definity's denial letter identified Bhambra's injuries and noted no evidence of anything beyond minor injuries, but never actually said the MIG applied. That omission made the $1,874.96 chiropractic plan payable.
The Tribunal pointed to the Divisional Court's earlier ruling in Zheng, Cai v. Aviva Insurance Company of Canada, confirming that this kind of procedural slip applies only to the specific plan in question and does not permanently remove an applicant from the MIG.
It is a small dollar figure, but the message is hard to miss: even when an insurer gets the substance right, a procedural gap in a denial letter can still carry a price tag. For claims teams processing high volumes of accident benefits files, the case is a practical reminder that what a denial letter says - and what it leaves out - matters.
