A Landlord's insurer is not entitled to bring a subrogated claim against a tenant whose rent financed the insurance
A Landlord’s Insurer was not entitled to bring a subrogated claim against a Tenant to recover the amounts paid out on the Landlord’s claim following a fire caused by the Tenant’s negligence where the Tenant paid the Landlord’s insurance premium as additional rent under the lease.
The case reference is: Alberta Importers and Distributers (1993) Inc. v. Phoenix Marble Ltd.  A.J. No. 1514, the Alberta Court of Queen's Bench, Clark J. November 30, 2006.