Is there an invariable rule that a cell phone will connect to the closest tower to it?

It is not an invariable rule that a cell phone (in sending or receiving a call or text message) will connect to the closest tower to it because electromagnetic waves can reflect or refract or “fade” depending on the terrain, land use clutter, etc., or because, as mentioned, the tower itself is beyond its capacity at the particular time. Again, R v. Hamilton supra decants: The witnesses also testified that the general rule is subject to certain exceptions, including that a cell phone will not register at the closest tower if: (1) the closest tower is at capacity; (2) there is a body of water between the cell phone and the closest tower; and (3) there is a large obstruction (for example a multi-storey building) between the cell phone and the closest tower, and an unobstructed line of sight or flat area between the cell phone and a more distant tower. … In brief then, it is possible that a cell phone will not register at the nearest tower if a more distant tower gives out a stronger signal or if any of the exceptions apply. Thus, though cell phone records assist in determining the approximate location of a particular cell phone at a particular time, these records reflect probabilities, not certainties. (At paras 239-240)