work was concluded he left a copy of the bill of lading with the captain and the original and a copy were forwarded to respondent. This practice, he stated, continued in respect of the vessels of Paterson Steamships Limited ntlhe
CoO until they were taken off the service in 1943.
In November, 1941, the appellant had sent a representative to Georgetown "To generally supervise and see that the money and office work was done as far as the boats were concerned."
This representative was present at Georgetown when the Hamildoc was there in December, 1942, and deposes that he did not see any bill of lading. So far as he knew the captain did not issue a bill of lading and, in reference to their practice: "We never issued any bills of lading for our boats on that shuttle service;" that Sprostons Limited did other work such as making repairs to the ship for the appellant. Their offices were across the street and ". . . we were all the time in contact" and "We had to work very, very closely together . . ." and, while he made the disbursements to Sprostons Limited, he says he never paid an agency fee. He says that the "Naval Control" "issued instructions that I was not to document the ships, and I never had any occasion to go and ask them to change that."
The captain also deposed that he did not have or receive a bill of lading, and other captains in the service deposed to the same effect.
The foregoing evidence of the plant and dock superintendent, as well as that of the traffic superintendent, is in accord with the terms of the charterparty and with what is the general practice among shippers, carriers and consignees. A bill of lading is not only evidence of the agreement between the shipper and the carrier, but through it the goods may be transferred. That so important a document should have been discarded and no substitute provided therefor in respect of shipments extending throughout so substantial a period of time is difficult to accept. Respondent, however, submits, as its justification, the orders of the Naval Control authorities. These orders, it was suggested, were similar to the Defence of Canada Regulations, but were not proved nor was our attention directed to any provision under which judicial notice might be taken thereof. In order to succeed upon this basis, the respondent should have proved the orders in order that their effect might have been determined.
It follows that the finding of the trial judge, affirmed as it was by the Court of King's Bench, that the bill of lading oF was signed by Sprostons Limited, acting on behalf of the master, is supported by the evidence and ought not to be disturbed.
The appellant further contends that the respondent, as consignee, cannot succeed under this bill of lading because it is not a party to whom the property in the goods therein mentioned passed upon or by reason of such consignment within the meaning of sec. 2 of the Bills of Lading Act (R.S.C. 1927, c. 17, s. 2). Sec. 2 reads as follows:
This section, originally sec. 1 of the Bills of Lading Act 1889 (S. of C. 1889, c. 30), was enacted in order that the consignee might bring an action under the bill of lading in his own name, provided, of course, he otherwise came within the terms of the section. The precise contention of the appellant is that the respondent was the owner of the bauxite before the issue of the bill of lading, by virtue of the provision in cl. 5 of the Agreement for Sale under which Demerara was required to "deliver the bauxite, trimmed in ship's hold, at Mackenzie, B.G.," a place seventy miles up the Demerara River from Georgetown, and, therefore, the property in the bauxite did not pass to it "by reason of such consignment."
This cl. 5 is part of the Agreement for Sale and cl. 4 thereof reads:
These clauses 4 and 5 must be read together and the entire agreement must, I think, be read and construed in relation to the usual practice of the trade. This Agreement for Sale contemplated that orders would be given by the respondent and filled by Demerara by delivering the s
.A...s bauxite as aforesaid and following the instructions with respect to billing. The instructions contemplated in cl. 4 were given under date of May 26, 1942, and provided that Demerara would send one original ocean bill of lading to the respondent, Montreal, Quebec, and one non-negotiable copy of the ocean bill of lading to the Saguenay Terminals Limited at Montreal.
It, therefore, would appear that the parties intended that the title should pass to the bauxite when "trimmed in ship's hold" and the shipping documents prepared in accordance with the instructions given.
These instructions and the practice developed thereunder were followed throughout 1942.
Sprostons Limited were agents for Demerara and the latter apparently followed the practice, as already outlined, of having the bill of lading prepared by its agents at Georgetown with the full knowledge and acquiescence of all parties concerned and, under these circumstances, it cannot be said that the title to the bauxite passed to the respondent until such time as the bill of lading was executed and mailed by Demerara, or its agents, addressed to the respondent. If the point were in issue, I should be prepared to hold that when so mailed and executed the bill of lading related back to, and became effective as of the time when the loading was completed. In Delaurier v. Wyllie (1), the purchasers (Delaurier & Company) agreed to buy from Stevenson & Company coal to be shipped as follows:
Stevenson & Company chartered a ship and named itself as consignee in the bill of lading, which it endorsed to Delaurier & Company. The ship with its cargo was lost and Delaurier & Company sued the ship owners (Wyllie and Others) on the bill of lading. Lord Shand, at p. 180, stated:
The case of Delaurier v. Wyllie supra dealt not only with a shipment of coal, but also with one of iron, and while the property did pass in respect to the iron, the property did not pass by virtue of the endorsement of the bill of lading. There the shippers were instructed to, and did purchase the iron as agents for the endorsees of the bill of lading. When shipped, the bill of lading covering the iron showed the Estey J. agents as consignees and they endorsed the bill of lading to their principals. In these circumstances Lord Shand stated at p. 184:
This case is also distinguishable from The Insurance Company of North America v. Colonial Steamships Limited (1), where an endorsement of the bill of lading was made for the purpose of presenting a claim to the insurance company and it was held that a subsequent endorsement to the insurance company which acquired the goods by. reason of its obligations under its policy, certificate and attached endorsement did not bring the insurance company within the language of the aforesaid sec. 2 of the Bills of Lading Act.
The appellant's position is not improved because the Hamildoc would have unloaded the cargo at Chaguaramas instead of Arvida. It is true that there is no consignee specified at Chaguaramas, but what the bill of lading further contemplates is a re-forwarding from that port to the Aluminum Company of Canada at Arvida, Quebec. The practice of the parties in this shuttle service was sufficiently well established and followed to justify the conclusion that the Aluminum Company of Canada was the consignee at both points and that the goods would be dealt with at Chaguaramas either by that company by an agent appointed to protect its interests there.
The respondent is, in the circumstances of this case, a consignee named in the bill of lading to whom the property passed by reason of such consignment and entitled to bring this action within the meaning of the foregoing sec. 2 of the Bills of Lading Act.
STD.
The appeal is dismissed with costs.
AC
CARTWRIGHT J.-I agree that this appeal should be LTD. dismissed with costs.
Estey J.
Appeal dismissed with costs. Solicitors for the appellant: Montgomery, McMichael, Common, Howard, Forsyth and Ker.
Solicitors for the respondent: Heward, Holden, Hutchison, Cliff, McMaster, Meighen and Hebert.
IN RE THE ASSESSORS OF THE- *May 23,24
PARISH OF BATHURST IN THE
APPELLANTS; *Oct.2.
COUNTY OF GLOUCESTER.
AND
THE KING
AND
JOSEPH L. RYAN, JUDGE OF THE
GLOUCESTER COUNTY COURT,
EX PARTE DEXTER CONSTRUC- TION COMPANY LIMITED .....
ON APPEAL FROM THE SUPREME OF NEW BRUNSWICK (APPEAL DIVISION)
Assessment-Taxes-Personal Property-Situs-Contractor having head office and chief place of business in one parish and equipment and machinery ini another-Where taxable-"Place of business"-Meaning -The Rates and Taxes Act, R.S.N.B. 1927, c. 190, s. 20.
The Rates and Taxes Act, R.S.N.B. 1927, c. 190, s. 20 provides that all personal property shall be assessed to the owner in the parish where he resides except that if he has a "place of business" in another parish all personal property connected therewith or employed therein shall be assessed in the parish where he has such place of business. The respondent, whose head office was in the Parish of Lancaster, Saint John County, contracted to pave among others, a road leading through the Parish of Bathurst, Gloucester County, to Douglastown, Kerwin, Rand, Estey, Locke and Fauteux JJ.
Northumberland County, and acquired 59 acres of land in Bathurst
Parish on which it erected 38 buildings, including an office, mess hall, BT T sleeping camps, repair shops, an asphalt plant and a gravel-crushing plant. During the winter months moveable equipment was stored at the property and some 20 men employed in repairing it.
The
. Bathurst Parish Assessors purporting to act under the authority of s. 20 assessed the respondent's personal property in the parish at Ex $600,000.
On appeal to the County Court Judge the latter reduced the ConTRe assessment to $275,000 but otherwise confirmed it. On appeal by way of certiorari to the Appeal Division, Supreme Court of New Brunswick, the assessment was set aside on the grounds that the company had no place of business in Bathurst Parish within the meaning of s. 20 of the Act.
Held: (Reversing the decision of the New Brunswick Supreme Court,
Appeal Division).
1. That on the facts the assessors could properly find the existence of a business carried on at a "place" in the parish of Bathurst within the meaning of s. 20 of The Rates, and Taxes Act.
De Beers Consolidated Mines Ltd. v. Howe [19061 A.C. 455 and Kirkwood v. Gadd
[19101 A.C. 422 referred to and distinguished; Swedish Central Ry.
Co. v. Thompson [19251 A.C. 495, Mitchell v. Egyptian Hotels Ltd.
[19151 A.C. 1022, and San Paulo (Brazillian) Ry. Co. v. Carter [1896] A.C. 31, referred to.
2. That only the machinery and other property used for repairing and storing purposes could be taken to be "connected with or employed in"
the business: what was repaired or stored, was not in that language.
3. That in making the assessment the assessors proceded upon a wrong principle in whole or in part but a legal and correct assessment could have been made and as provided by s. 126 the matter should be remitted to them for re-assessment on the principles laid down by this Court. The King v. Assessors of Woodstock [19241 S.C.R. 457.
Estey J. would have allowed the appeal reducing the amount of the assessment to $175,000.
APPEAL from the judgment of the Appeal Division of the Supreme Court of New Brunswick (1) whereby an appeal from the judgment of His Honour Joseph L. Ryan,
Judge of the County Court of Gloucester, was allowed and a rule absolute ordered to quash the assessment by the
Assessors of the Parish of Bathurst upon the personal property of the Dexter Construction Co. Ltd.
C. F. Inches K.C. for the appellants.
J. J. F. Winslow K.C. and M. G. Teed K.C. for the respondent.
(1) (1950) 26 M.P.R. 1.
83864-4
:- J.:-The respondent is a company whose main business is the construction of paved highways. Its head office is at Fairville, New Brunswick, and it is not disputed that its residence in the sense of the locus where its central management and control is exercised, is at that place. During the early part of 1947 the company entered into several contracts with the Government of New Brunswick for reconstructing and paving certain roads in Gloucester County, including one section, about 50 miles in length, of the main highway between Bathurst and Douglastown, in Northumberland County, lying to the south.
To enable this and any other work in that district of the province awarded it to be carried out, the company acquired about 59 acres of land in the parish of Bathurst. On tis land, part of which seems to have been a gravel pit, 38 buildings were erected in the spring of 1947. They consisted of an office, 23 sleeping camps, kitchen, mess hall, storehouse, oil house, shovel shop, truck shop, machine shop, welding shop, 4 stock buildings and a paint shop.
There were set up also on this land, an asphalt plant and a gravel crushing plant. The office was opened not later than in May. During the following winter the units of moveable equipment used for the road work mentioned as well as other units had been kept in storage and repaired at this station by a staff of 20 men.
For the summer operations approximately 200 men were engaged. They included crews for both the asphalt and the gravel crushing plants and the several shops, the truck and machine operators and the general road forces. A superintendent and gang foreman were in immediate charge of the field operations.
General instructions would be received from the head office or from an executive field officer.
In the office at the Bathurst headquarters three clerks were employed.
From slips turned in each night, they made up the employees' time and wages for which they issued weekly cheques drawn on a bank in the City of Saint John. Records were kept of the supplies of food, oil, gas, repair parts and other materials for and used in the several shops and on the road work.
The moveable equipment consisted of trucks, tractors, loaders, bulldozers, shovels and graders. There were also spreaders and other units forming part of or used in Asss connection with the asphalt and crushing plants, machines and tools in the shops, and the furniture and equipment of the office.
Ex DExR The municipality claims to be entitled to tax that property. The general taxing clause is s. 20 of The Rates and Taxes Act, sub-secs. (1) and (2) of which are as Rand J. follows:- 20.
(a) Where any person has a shop, factory, office or place of business in a parish other than that in which he resides, or in which shop, factory, office or place of business he carries on his trade, p-3fession, calling, or business, all his personal property connected with or employed in his trade, profession, calling or business so carried on, shall be assessed to him in the parish where he has such shop, factory, office, or place of business: (b) Where any person has two or more shops, offices, factories or other places of business situate in different parishes, at which he carries on his trade, profession, calling or business, he shall be assessed in each parish for the portion of his personal property connected with, or employed in the business carried on thereat, By s. 11:- For the purpose of assessment on property or income, every person carrying on business in any parish shall be deemed to be an inhabitant thereof.
"Person" includes any corporation liable to be rated. S. 25, ss. (1) provides that personal estate belonging to a joint stock company "having a place of business within the Province, may be assessed within the parish in which it has a place of business in the name of the corporation, or of the president, manager or agent thereof,
*
* and s.s. (3):- Stocks or goods or any other personal estate, except shares in ships or shipping, used in any trading or mercantile business including any fur bearing animals kept in captivity for breeding purposes or in connection with the business of fur farming, in any city, town or parish, belonging to any person or persons not resident therein, or to any corporation not having its principal place of business therein, may 'be assessed in such city, town or parish in the name of the owner or owners of such business or of the agent or manager thereof, in such city, town or parish, and such personal estate shall not be liable to be rated or assessed against the owner or owners -thereof in the city, town or parish where he or they reside or in the case of a corporation, in the city, town or parish where such corporation has its principal place of business * * * 83864-41
The language of the statute has been more or less preserved in its earliest form. Intended to meet the usual and simpler modes of "business" and reflecting possibly the difficulties in attributing characteristics of personality to corporations, the object of s. 25 is not free from doubt, Ex but for the purposes of this case, the essential requirement under both sections 20 and 25 is that the company should have had a "place of business" at which it carried on -business within the parish: and the property to be taxed must have been connected with or employed in the business so carried on.
The original assessment was on a valuation of $600,000. It was made, apparently, on an estimate little better than a guess that the company had three times as much equipment as that of another company which some workman "had heard" was valued around $250,000.
An appeal was taken to the County Court Judge who reduced the amount to $275,000 but otherwise confirmed it. Neither the particulars of the reduction nor of the amount confirmed have been given us and we are left in the dark as to the basis on which the judge proceeded.
The proceedings were then brought by certiorari before the Appeal Division of the Supreme Court and by a unanimous judgment (1), the entire assessment was set aside on the ground that the facts did not show a business being carried on as required and that there was consequently no jurisdiction to make it. That conclusion was founded upon what were considered to be principles laid down in De Beers Consolidated Mines Limited v. Howe (2), and Kirkwood v. Gadd (3), and the first question is whether the Court has properly interpreted these two judgments.
Both of them deal with the rather complicated provisions of The Income Tax Act of the United Kingdom, and it is essential in deducing rules or conceptions from those cases that the intricacies of that law be clearly appreciated. In De Beers the issue was whether a mining company, incorporated in South Africa and carrying on the business of diamond mining there, was subject to income tax in England. In order to be so, it was necessary, under Schedule D to the second section of The Income Tax Act, 1853, that it reside in the United Kingdom, and the question was whether it did or not. Following decisions in Calcutta Jute Mills v. Nicholson (1), and Cesena Sulphur Co. v. Nicholson (1), the House of Lords laid it down that a company is to be deemed to reside where it keeps house and does business, and that it kept house and did business where its central management and control actually was. The majority of directors and life governors of Co. the company lived in England, their meetings were held in London, and they exercised the real control in all the important activities of the company except the actual mining operations.
It was found, therefore, as a fact that in London that central management and control did abide. From this it followed that the company resided in England and carried on some part of its business there. As a result, it came under the charge of the rule of Schedule D that rendered it liable to taxation on the whole of its profits. But it was never suggested that the company was not also carrying on business in South Africa; its business extended to both countries.
The decision meant simply that for the purposes of income tax in England the company was resident and doing business there of a central managing and controlling character.
The language of Lord Loreburn, "practically all the important business of the company except the mining operations" implies, obviously, that these operations were themselves part of the "important business". But no one questions the fact here that the company through the same degree of control is resident at Fairville; there is no question of residence at all: it is one of doing business at a place of business; and on the authority of De Beers, that business is being conducted both at Fairville and in the parish of Bathurst. In Kirkwood's case, the question was whether, under the Money-Lenders' Act, the money-lender was bound to carry on every detail of his business at his registered address, and it was held that he was not. The language of Lord Atkinson must be interpreted in the light of the controversy which he was considering. The acts which were in question were the negotiation of the detailed terms of the loan and the ascertainment of the items of property by which it was to be secured, and it was pointed out that, in order to carry on the business, some parts of the transactions must necessarily take place elsewhere than at the lender's headquarters. I am unable to see that the decision can, in the slightest way, assist in the construction of the Rates Act.
Ex
The case of Swedish Central Railway Co. v. Thompson is of some interest in presenting another aspect of the question decided in De Beers. There the company was J.
incorporated under The Companies' Act, 1862 and 1867, with the object of constructing and working a railway in Sweden. The railway had been leased for 50 years at an annual rent. The central control and management of the business originlly in England was later transferred to Sweden, and in that state of things the taxation was claimed.
A committee had been appointed to transact formal administrative matters in the United Kingdom, such as the transfer of shares, affixing the seal to certificates, and signing cheques on the London bank account. All dividends were declared in Sweden and the only moneys transmitted to the United Kingdom were for dividends to the shareholders living there. The annual rent was paid to the company in Sweden. It was held, notwithstanding the central direction in Sweden, that there was a sufficient corporate activity in the United Kingdom to establish a residence for the purposes of taxation. The clause of the schedule applied covered the case where, the central management and control of the business not being carried on in whole or part in the United Kingdom, but a residence for limited purposes being there, tax was chargeable on the amount of profits actually received in that country. What was held, in short, was that a company for different categories of tax could have two residences.
In Mitchell v. Egyptian Hotels Limited (2), a case of similar facts, Lord Parker, at p. 1037, in the course of his speech, cited the decision of the House in San Paulo v. Carter (3), to the effect that "a trade or business cannot be said to be wholly carried on abroad if it be under the control and management of persons resident in the United Kingdom, although such persons act wholly through agents and messengers resident abroad.
Where the brain which controls the operations from which the profits and gains arise is in this country, the trade or busines is, at any rate partly, carried on in this country."
It is obvious that in these cases there was no thought that the business in its entirety was being carried on in the United Kingdom, and likewise it cannot be said that because the head office of the company in this appeal is in Fairville, its total business is to be deemed concentrated at that point. Paragraph (b) of 20(1) contemplates any Rad J. number of shops, offices, factories or other places of business in different parishes which can constitute, in many forms, branches of one provincial activity, and in interpreting the legislation the difference between ascertaining the conditions upon which personal property can be taxed by a local administration and those by which a company with a highly ramified organization is to be subject to income tax must be kept in mind.
What s. 20 envisages is a business localized at a place in a parish which attracts to itself certain personal property to which it gives a local habitation: a taxation based on the presence of personal property in a parish other than that of the owner's residence but associated with a place of business.
Carrying on a business cannot be intended to include every act of management or related to performance which affects it. A business to be conducted in its entirety within a specific local area can, in these days, embrace only the simplest body of simple transactions.
S. 20 clearly extends to businesses that are branch activities of a central organization: and the facts here indicate that the company has other units of plant and other groups of equipment elsewhere in the province. Once a complex of repeated or systematized business operations becomes localized about a place and presents its moveable property in more than a mere unfixed or transient employment in the parish, then the precise period of its presence there becomes of minor importance.
One can imagine, for example, a special sale of a bankrupt stock conducted in a parish, say, for three months and in premises rented for that period only. How could it be maintained that that was not a business carried on at a shop or place in the parish? Yet its duration would be only a fraction of what was involved in the facts before us. The situation must be visualized from the standpoint of the community. Here, for well over a year, these operations of preparing roadbed, gathering and treating gravel, making surfacing material and applying it to the roads, storing and repairing the machines used, hiring, paying and discharging workmen, employing truckers with their vehicles, all under an immediate superintendence centralized at a headquarters, aggregate to what in the ordinary meaning of the words is roadmaking business. The business of the company here lies not in negotiating or making contracts but in performing them: contracts are or may be necessary, no doubt; financing and account books, likewise; but these are formal elements of the operating activities of the company. The question on certiorari is whether on the facts before us the assessors could properly find the existence of a business carried on at a "place" in the parish, and in my opinion they could have done so.
But a further question arises of the scope of the business so centered at Bathurst. It was contended that only the work done in the parish could be taken into account: but that misconceives the statute. The business is what is carried on, at, and from, the place of business within the parish; its reaches of operation are not restricted. There is no evidence, however, that the work in Kent County was directed from Bathurst. The main road from Bathurst to Douglastown in Northumberland County I take to have been under that direction.
Local time offices are stated to have been kept in both Northumberland and Kent counties but it is not clear whether in the former there was other work than that of the main road or not. The fact that all equipment for the three counties was stored and put into condition at Bathurst during the winter does not annex it, in the sense of the statute, to the business conducted in Bathurst: in that branch of the operations, only the machinery and other property used for repairing and storing purposes could be taken to be "connected with or employed in" the business: what is itself repaired or stored is not within that language.
But the whole of that property was included in the statement submitted by the officers of the company and included in the assessment.
The latter was made, too, certainly in amount, as an entirety: assessed at $600,000 by the assessors and $275,000 by the County Court Judge, it was a single sum for the total property, and not the sum BA'UE of individually valued items. This was not a case for such a mode of valuation: the items are disparate and should have been severally valued. The amount representing the property used otherwise than for the work carried on from ExPARE Bathurst cannot therefore be struck out of the assessment; and that it is not of a "de minimis" character is clear.
The authority for dealing with the appeal on certiorari Rand J. is s. 126 of The Rates Act, s.s. (b) of which reads:- If the Supreme Court, upon any such hearing, is of opinion that any such assessment is not good in law for the reason that the assessors, in making such assessment, proceeded upon a wrong principle in whole or in part, and that a legal and correct assessment could have been made by such assessors, the Court shall remit the assessment to the assessors, and 'he assessors shall proceed de novo to make a new assessment in regard to the particular person or company assessed in and by the assessment so brought before the Court, upon such correct principles as may be set forth or intimated by The Court on the hearing of the matter under the writ of certiorari or the court in quashing or finding wrong said assessment, which new assessment shall relate in law to the time when the assessment so quashed or found wrong, in whole or part, was made, and may be dealt with as if made at the time of making the first assessment, and the same shaK stand as good at law and in fact, as the said first assessment would have stood and been, had it been legally made, and said second assessment may be enforced to the same extent, and in like manner as the first assessment could have been, had it been according to law.
That the assessment proceeded upon a wrong principle
"in whole or part" but that "a legal and correct assessment could have been made by" the assessors follows from the conclusions already expressed.
A remission of the assessment to the assessors as authorized by the subsection should, I think, have been directed by the Appeal Division below and is what this Court should now direct.
That was the view taken by Duff J. (as he was) in The King
Ex Parte Bank of Nova Scotia v. Assessors of Woodstock
(1), in which a somewhat similar error was made in assessment principle.
The appeal should be allowed, the assessment set aside and returned to the assessors for a re-assessment on the principles laid down. The appellants will have one-half of their costs in this Court and the respondents their costs in the Appeal Division and before the County Court Judge.
EsTEY J.:-The Assessors of the Parish of Bathurst, County of Gloucester in the Province of New Brunswick, imposed, in 1948, a tax upon the real and personal property of the Dexter Construction Company Limited (hereinafter referred to as the Company).
These taxes were imposed under the provisions of The Rates and Taxes Act (R.S.N.B. 1927, 190). The Company admits liability for the tax upon its real property, but contends that the provisions of the statute do not authorize the parish to impose a tax upon its personal property.
The assessment of the personal property at $600,000 by the assessors was reduced by the Judge of the County Court to $275,000. The Appellate Division of the Supreme Court held the personal property of the Company was not liable to the imposition of a tax by this parish (1). The Company, contractors with head office at Fairville, Parish of Lancaster in the County of Saint John, constructed roads throughout New Brunswick and, in 1947, was awarded a contract to construct and pave the highway from Bathurst to Douglastown, passing through the Parishes of Bathurst and Allardville in the County of Gloucester, and Alnwick and Newcastle in the County of Northumberland.
The Company brought its equipment and facilities for the execution of its work under this contract from either its head office at Fairville or from other parts of the Province where it had carried on construction work. The superintendent, foremen and those directing the work were employees of the Company directed to this work from the head office at Fairville. Many of the workmen were employed locally.
The Company, in connection with this work, purchased a parcel of land in the Parish of Bathurst and built thereon a building of portable construction, which included an office and sleeping quarters. It was built "in 8 ft. wide sections, so they will fit on a flat-bottom truck to take away." There were other buildings used for the purposes of a kitchen, mess hall, store house, oil house, shovel shop, truck shop, machine shop, welding shop, paint shop and plant stock. Neither the construction nor the particulars of these buildings were given in detail, but the case has been
Cases cited
- A.C. 31 A.C. 31
- The King Ex parte Bank of Nova Scotia v. Assessors of Rates and Taxes of Woodstock, N.B. scr-1924-457 462