Can estoppel apply in the municipal context?

However, due to the importance of the public interest component, the application of estoppel in the municipal context depends significantly on the particular facts in issue. For example, in Hensrud v. City of Regina (1994), 1994 CanLII 4890 (SK QB), 115 D.L.R. (4th) 69 (SKQB) (affirmed without reasons, (1994), 121 D.L.R. (4th) 188 (SKCA)), the issue was whether the purchaser of a condominium could rely on a tax certificate provided by the City when the certificate did not contain a warning that the property may be subject to a supplementary assessment which the purchaser would be liable to pay. In refusing to apply the doctrine of estoppel, Barclay J. concluded that the payment of the tax at issue was governed by the legislation, which “represents a complete statutory code governing the assessment and taxation of property, including the effect of appeals of assessment and the imposition and payment of taxes resulting from unsuccessful appeals” (page 78).