The proper use of the term public utility as the legalists use it would perhaps restrict it to such businesses as are regu lated primarily under the common law duties to serve. These may be determined by the courts. Used in this way, the term would not extend to businesses which are regulated under the legislative police powers and not under the common law rule. It is clear, however, that legislative statutes may narrow com mon law rule and that public utilities may be subjected to legislative as well as common law regulations.
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