In the 1920s, a hydroelectric dam was built at the outlet of Lac Seul in northwestern Ontario, raising the level of the lake by about three metres. This caused extensive, permanent flooding to the Lac Seul First Nation's (LSFN) reserve that had been set aside pursuant to Treaty 3 (1873), destroying homes, gardens, haylands, wild rice fields, and grave sites. The LSFN did not consent to this unlawful destruction and only received inadequate compensation years later. The LSFN brought an action in the Federal Court seeking compensation for breach of the Crown's fiduciary, treaty, and Indian Act obligations. The trial judge decided that the Crown had breached its fiduciary obligations and awarded equitable damages based on the value of the land in the 1920s, excluding its value for hydroelectricity generation. An appeal to the Supreme Court on the quantum of damages was successful. The Court sent the case back to the Federal Court to determine equitable compensation based on the value of the land for hydroelectricity generation.