INTER PIPELINE LTD v TEINE ENERGY LTD, 2024 ABKB 740
FEASBY J
3.72: Consolidation or separation of claims and actions
Case Summary
In this Decision, the Court addressed Applications brought by Inter Pipeline Ltd. (IPL) and Teine Energy Ltd. (Teine) regarding the enforcement and stay of an Arbitral Award issued in favour of Teine. The parties had not formally sought Consolidation under Rule 3.72, which allows separate Actions to be treated as a single proceeding when it is in the interests of justice. Despite this, the Court followed the parties’ approach of treating the matters as consolidated for the purposes of the Hearing, citing efficiency and the absence of a substantive reason to maintain the separation of the two Actions. The Court noted that Rule 3.72 typically requires a formal Application to consolidate proceedings and encouraged the parties to consider whether such an Application or similar procedural step might be necessary for the efficient administration of the Actions moving forward.
View CanLII Details