The appellants applied to the Board of Revision to lower the 1981 assessment of their properties under The City of Winnipeg Act.
The respondent city obtained an order prohibiting the Board from considering the applications, arguing that provincial legislation froze assessments for 1981 and 1982 at 1980 levels.
The Supreme Court of Canada allowed the appeal, holding that the freeze legislation did not expressly repeal or amend the taxpayers' right to appeal an inequitable assessment.
Applying the principle of strict construction for taxing statutes, the Court concluded the Board of Revision retained jurisdiction to hear the complaints.
