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of <h1>Estoppel not applicable due to statutory obligations: Privy Council restores judgment in favor of appellants</h1> <h3>Maritime Electric Co., Ltd. Versus General Dairies, Ltd.</h3> Maritime Electric Co., Ltd. Versus General Dairies, Ltd. - AIR 1937 PC 114 Issues Involved:1. Estoppel in the context of statutory obligations under the Public Utilities Act.2. The impact of a mistake in computation of accounts on statutory duties.3. The applicability of estoppel in cases involving public policy and statutory obligations.Issue-wise Detailed Analysis:1. Estoppel in the context of statutory obligations under the Public Utilities Act:The appellants, a public utility company, supplied electric energy to the respondents, a dairy business, and charged them based on incorrect meter readings due to a computational error. The respondents paid these incorrect amounts, believing them to be accurate. The appellants later sought to recover the undercharged amount of $1,931.82. The respondents raised the defense of estoppel, arguing that they had relied on the incorrect statements to their detriment. The appellants contended that estoppel was barred by the provisions of the Public Utilities Act, which mandated strict adherence to scheduled rates and prohibited any deviation from these rates.2. The impact of a mistake in computation of accounts on statutory duties:The Supreme Court of Canada had previously ruled in favor of the respondents, accepting the plea of estoppel and allowing the appeal. However, the Privy Council emphasized that the Act imposes a statutory duty on both parties to adhere to the scheduled rates. The specific question was whether this statutory duty could be defeated by a mere mistake in the computation of accounts. The Privy Council held that the answer must be in the negative, as the statutory obligation to charge and pay the scheduled rates could not be nullified by an inadvertent mistake.3. The applicability of estoppel in cases involving public policy and statutory obligations:The Privy Council noted that estoppel is a rule of evidence and cannot be used to override statutory obligations imposed for public policy reasons. They cited various authorities and cases to support their view that estoppel cannot be invoked to defeat a statutory duty of an unconditional character. The Court highlighted that allowing estoppel in this case would effectively repeal the statutory provisions of the Public Utilities Act, which is impermissible.Conclusion:The Privy Council concluded that estoppel was not available to the respondents due to the statutory obligations imposed by the Public Utilities Act. They restored the judgment of the Appeal Division of the Supreme Court of New Brunswick and of Richards, J., which had ruled in favor of the appellants, awarding them the amount of $1,931.82 and costs. The Privy Council did not express an opinion on the second ground of the appellants' challenge to the estoppel, as their decision on the statutory obligation issue was sufficient to resolve the case.
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