In this case, the purchaser defaulted on closing, forcing the vendor to put the property up for resell, and starting lawsuit against the defaulting purchaser for the difference in the selling price. The defaulting purchaser argued, amongst other things, that the vendor failed to mitigate their damages on the theory that the vendor failed to speak with the defaulting purchaser about possible other potential purchase offers. This argument was rejected by the lower court, and by the Court of Appeal. In this regard, the appellate court said: “there is no merit to the appellant’s argument that the respondent failed to mitigate by not considering his subsequent offers and assurances, or by not replying to all of them. (The vendor)… was under no obligation to deal with him any further.”
Calleja v. Ahmadi, 2022 ONCA 106
https://www.canlii.org/en/on/onca/doc/2022/2022onca106/2022onca106.html