In Soper v Canada, Justice Robertson of the Canadian Federal Court of Appeal opined:
"Upon reflection, it seems arguable to me that the term 'diligence' is synonymous with the term 'care'. That is, diligence is simply the degree of attention or care expected of a person in a given situation....
"Others, however, have taken a different approach by contending not only that diligence is an independent element of the statutory standard but also that that requirement, unlike the statutory requirements for skill and care, is more onerous than at common law."
REFERENCES:
Soper v Canada 1998 1 FC 124, published at http://www.canlii.org/en/ca/fca/doc/1997/1997canlii6352/1997canlii6352.html