Where a party seeks to amend pleadings to add resulting trust claims late in proceedings, the inability of the opposing party to obtain evidence from a deceased witness on the question of intention — a factual issue relevant to resulting trusts but not to the existing constructive trust claims — constitutes significant prejudice justifying refusal of leave to amend. The fact that a proposed new claim is not subject to a limitation period and could be brought as a separate proceeding does not preclude refusal of leave to join it into existing proceedings where no explanation is given for the delay.
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