Indiana Code

Ind. Code § 8-1-2-4 (2026)

Services to public; rates and charges

✓ current as of May 2026
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     Sec. 4. Every public utility is required to furnish reasonably adequate service and facilities. The charge made by any public utility for any service rendered or to be rendered either directly or in connection therewith shall be reasonable and just, and every unjust or unreasonable charge for such service is prohibited and declared unlawful. The commission, in order to expedite the determination of rate questions, or to avoid unnecessary and unreasonable expense, or to avoid discrimination in rates between classes of customers, or, whenever in the judgment of the commission public interest so requires, may, for ratemaking and accounting purposes, or either of them, consider a single municipality and/or two (2) or more municipalities and/or the adjacent and/or intervening rural territory as a regional unit where the same utility serves such region, and may within such region prescribe uniform rates for consumers or patrons of the same class. Nothing in this chapter contained shall authorize any public utility during the remainder of the term of any grant or franchise under which it may be acting on May 1, 1913, to charge for any service, in such grant or franchise contracted, exceeding the maximum rate or rates therefor, if any, that may be fixed in such grant or franchise.

Formerly: Acts 1913, c.76, s.7; Acts 1933, c.190, s.2. As amended by P.L.59-1984, SEC.10.

 

Notes of Decisions
Cited in 33 cases (2 in the last 5 years), 1979–2024 · leading case: Citizens Action Coalition of Indiana, Inc. v. N. Indiana Pub. Serv. Co., 485 N.E.2d 610 (Ind. 1985).
Citizens Action Coalition of Indiana, Inc. v. N. Indiana Pub. Serv. Co., 485 N.E.2d 610 (Ind. 1985). · cites it 25× “" The majority then quotes from Ind. Code § 8-1-2-4 which states "[t]he charge made by any public utility for any service rendered or to be rendered either directly or in connection therewith shall be reasonable and just.”
Prior v. GTE North Inc., 681 N.E.2d 768 (Ind. Ct. App. 1997). · cites it 22× “In particular, he contends that the tariff's limitation of liability clause is invalid for the following reasons: 1) the tariff abrogates GTE's statutory duty under I.C. § 8-1-2-4 to provide "reasonably adequate service and facilities;" 2) the IURC exceeded its legislative…”
South E. Indiana Nat. Gas Co. v. Ingram, 617 N.E.2d 943 (Ind. Ct. App. 1993). · cites it 3× “Indiana Code 8-1-2-4 imposes upon South Eastern a statutory duty to furnish reasonably adequate service and facilities.”
Bamberger & Feibleman v. Indianapolis Power & Light Co., 665 N.E.2d 933 (Ind. Ct. App. 1996). · cites it 2× “Indiana Code § 8-1-2-4 imposes upon IPL a duty to furnish reasonably adequate service and facilities.”
United States Gypsum, Inc. v. Indiana Gas Co., 735 N.E.2d 790 (Ind. 2000). · cites it 2× “” Ind.Code § 8-1-2-4. “This service includes the product itself, the use or accommodation afforded the customers and the equipment employed by the utility in performing the service.”
United States Steel Corp. v. N. Indiana Pub. Serv. Co., 951 N.E.2d 542 (Ind. Ct. App. 2011). · cites it 2× “2d at 127 ; Ind.Code § 8-1-2-4 (2010). Because the state has mandated that such public utilities use their private assets in the public interest, the state has, for constitutional purposes, taken private property and must therefore provide reasonable compensation.”
Citizens Action Coalition of Indiana, Inc. v. N. Indiana Pub. Serv. Co. NIPSCO Indus. Grp. & United States Steel Corp., 76 N.E.3d 144 (Ind. Ct. App. 2017). · cites it 2× “” Ind. Code § 8-1-2-4 , Here, CAC contends that the rate design included in the Settlement Agreement (and the IURC Order), which incorporates an increase in the fixed charge for residential and small commercial consumers, is unjust and unreasonable.”
RAM Broad. of Indiana, Inc. v. MCI Airsignal of Indiana, Inc., 484 N.E.2d 26 (Ind. Ct. App. 1985). · cites it 4× “" *36 All public utilities are required by Indiana Code § 8-1-2-4 to furnish "reasonably adequate services and facilities.”
United Rural Elec. Membership Corp. v. Indiana Michigan Power Co., 648 N.E.2d 1194 (Ind. Ct. App. 1995). · cites it 2× “Indeed, failure to comply with the Commission's order would have subjected I & M to potential penalty, IND. CODE § 8-1-2-109, potential liability to General Motors for injury caused by its wrongful actions, IND.”
Indiana Bell Tel. Co., Inc. v. O'BRYAN, 408 N.E.2d 178 (Ind. Ct. App. 1980). “Even were this not so Ind. Code 8-1-2-4 saddles Bell with a statutory duty to furnish reasonably adequate service and facilities.”
Citizens Action Coalition of Indiana, Inc. v. S. Indiana Gas & Elec. Co. d/b/a Vectren Energy Delivery of Indiana, Inc., 120 N.E.3d 198 (Ind. Ct. App. 2019). · cites it 4× “12 CAC posits that the approval of lost revenues is subject to a "just and reasonable" rates standard under Indiana Code § 8-1-2-4 (1984), the general rate statute, which provides in relevant part that "[t]he charge made by any public utility for any service rendered or to be…”
Citizens Action Coalition of Indiana, Inc. v. Pub. Serv. Co. of Indiana, Inc., 612 N.E.2d 199 (Ind. Ct. App. 1993). · cites it 2× “CODE § 8-1-2-4 (1984). This Court and our Supreme Court have noted that a "simple mathematical formula for the expression of a utility's total revenue requirement" can be stated as: "R = O + (V - D) r where R is the total revenue required, O is the operating costs, V is the…”
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