The Rain court declined jurisdiction because there were other avenues of resolution and there was no deprivation of liberty. (ablawg.ca)
Upon the first court establishing jurisdiction, the second court will then decline jurisdiction. (newlawjournal.co.uk)
The Supreme Court of Canada also declined to disturb the findings of the courts below that the Ontario courts should not decline jurisdiction on the basis of forum non conveniens. (thelitigator.ca)