• Facts:
  • Spartan Delta Corp applied for the return (replevin) of a specialized compressor.
  • The compressor was sold by the OWA to Midstream for $20,000.
  • Spartan claimed it had bought the compressor in 2020 through a Sale and Vesting Order in the receivership of Bellatrix Exploration Ltd.
  • The OWA claimed statutory authority under the Oil and Gas Conservation Act (OGCA) to possess and sell the compressor after the Trident Exploration site was abandoned.
• Legal Issue: Whether the OWA knew the compressor belonged to Spartan when it sold the equipment. This affects whether the sale was lawful under OGCA s.102(1).
• Court's Analysis:
  • Replevin: To succeed, Spartan needed to prove wrongful taking. However, OWA’s statutory authority negated any wrongful taking.
  • Statutory Interpretation: The court interpreted "knows" in OGCA s.102(1) to mean actual knowledge, rejecting Spartan’s argument that OWA should have checked ownership records (constructive knowledge).
  • The legislation prioritized the OWA's efficiency in site reclamation, limiting its duty to investigate equipment ownership.
• Conclusion: The court dismissed Spartan's replevin claim, holding that OWA had acted within its authority as it lacked actual knowledge of Spartan’s ownership of the compressor.

Outcome: Spartan's application for replevin was dismissed. No monetary award was specified.