All About Estates
By Latoya Brown & Elyse Mitchell
August 14th, 2026
Hidden Risks of a Do-It-Yourself Codicil: Schickedanz v. Schickedanz
Holograph wills and codicils are often viewed as a simple and inexpensive way to record testamentary wishes. In Ontario, a holograph will or codicil is valid if it is entirely in the testator’s handwriting and signed by the testator. That simplicity often makes holograph documents attractive.
The recent Ontario Court of Appeal decision, in Schickedanz v. Schickedanz, demonstrates that although a holograph codicil satisfies the formal requirements of the Succession Law Reform Act, it does not mean it will survive a challenge after the testator’s death.
In Schickedanz, the codicil complied with the formal requirements for a holograph document. What it lacked were the safeguards that would allow a court to confidently conclude that the document represented the testator’s informed and capable testamentary intentions.
