Yes. Several years ago, there was an independent candidate--I believe this was the Nunziata case--who challenged that fact that as an independent he had no place to which to direct or return the surplus funds, and the rule in the Canada Elections Act is that the money goes to the Receiver General of Canada.
That was challenged in the Superior Court of Ontario and that has been struck down, but it's still showing as a current provision in the act. I'll do a little more research on the status of this, but that's really the upshot of the case.