The CRTC granted Bell Canada an interim rate increase in 1984, subject to review.
In 1986, after a final hearing, the CRTC determined that the interim rates had yielded excess revenues of $206 million and ordered Bell Canada to distribute this amount to customers via a one-time credit.
The Federal Court of Appeal quashed the order.
The Supreme Court of Canada allowed the CRTC's appeal, holding that the power to make interim orders under the Railway Act and National Transportation Act necessarily implies the power to review those rates retrospectively and to make remedial orders, such as a one-time credit, if the interim rates are found to be unjust or unreasonable.
