Interest on a Manitoba Small Claims Court Judgment

Two Types of Interest in Manitoba Small Claims

When you win a small claims judgment in Manitoba, interest can add meaningfully to what you collect — especially if the other side delays payment. Manitoba law recognizes two distinct types: pre-judgment interest (before the decision) and post-judgment interest (after it).

Both are governed by Part XIV of The Court of King's Bench Act (C.C.S.M. c. C280), and both apply to small claims decided within the Court of King's Bench.

Pre-Judgment Interest

For a liquidated claim, pre-judgment interest runs from the date the cause of action arose until the date the court makes its order. For an unliquidated claim, it runs from the date you give the person responsible written notice of the claim until the date of the order. The statute does not award interest on non-pecuniary damages.

An important detail for Manitoba small claims: pre-judgment interest is excluded from the $20,000 jurisdictional limit. So if your actual loss is $19,500 and pre-judgment interest brings the total above $20,000, the claim still fits within small claims jurisdiction.

The prejudgment rate is the quarterly rate for the quarter in which the proceeding is commenced. The registrar publishes the quarterly rates. A judge may adjust the rate or period when the statute's factors make that just. A court officer can calculate any interest awarded; bring the dates and amounts needed for that calculation.

Post-Judgment Interest

Post-judgment interest generally accrues under section 84 of The Court of King's Bench Act from the date the order is pronounced until the amount is paid, unless the court orders otherwise or a special or no-interest rule applies.

You do not need to plead a claim for interest under Part XIV. If the losing party takes six months to pay, post-judgment interest generally accumulates for that period.

How to Calculate Interest on Your Claim

For a straightforward debt claim (like an unpaid invoice with a specific due date), the calculation is:

Principal amount × annual interest rate × (number of days ÷ 365)

For example, if the prejudgment rate for the quarter in which the proceeding starts is 3.5% and your $8,000 invoice has been unpaid for 14 months (approximately 425 days):

$8,000 × 0.035 × (425 ÷ 365) = $326

For claims where the loss happened over time (progressive property damage, multiple missed payments), you may need to calculate interest separately for each component from its own accrual date.

Contractual Interest vs. Statutory Interest

If your agreement specifies prejudgment interest or compensation instead of interest, the statutory prejudgment-interest rules may not apply. Include the contract clause in your evidence package; whether it is enforceable depends on the agreement and applicable law.

If no contract rate exists, the statutory rate under Part XIV applies by default.

Interest and Enforcement

When you move to enforce a judgment through garnishment (Notice of Garnishment, Form 60E), writ of seizure and sale, or registration against property, the enforceable amount includes both the principal judgment and all accrued post-judgment interest.

If the debtor makes partial payments, interest continues to accrue on the remaining balance until the judgment is fully satisfied.

Claiming Interest on Form 76A

You do not need to include a claim for Part XIV interest in your pleading. If you provide a calculation with Form 76A or at the hearing, use the applicable start date and rate, and update it through the date the court makes its order. The court officer can check the calculation.

For a complete guide to every step — from calculating your claim through filing, service, and collecting the judgment — the Manitoba Small Claims Filing Guide walks through the entire process.

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