Summary
On an application to set aside permission to serve proceedings out of the jurisdiction, the claimant retains the burden of establishing the jurisdictional requirements. The application is, in substance, a rehearing, and the court assesses the position when permission was originally granted.
The claimant must show a real prospect of success, a good arguable case within an applicable gateway, and that England and Wales is clearly or distinctly the appropriate forum. Forum conveniens is determined through an evaluative assessment of all relevant circumstances, including connections, evidence, witnesses, applicable law and practical justice.
Implied representations and reliance are ordinarily fact-sensitive. They should not be summarily determined where the contractual arrangements and the circumstances of formation require examination at trial.
Factual background
The claimant sought to pursue claims in negligent misrepresentation and restitution against a Welsh businessman concerning the payment of €950,000 for an alleged beneficial interest in a villa in Spain. Permission to serve the claim form out of the jurisdiction had been granted without notice.
The defendant applied to set that order aside, arguing that the negligent-misrepresentation claim had no real prospect of success, Spain was the appropriate forum, and the claimant had failed to make full and frank disclosure. The dispute required consideration of the parties’ agreements, the Spanish property, the evidential connections with England and Spain, and the risk that proceedings in Spain might be time-barred.
Held
- Outcome. The application was dismissed. Permission to serve out of the jurisdiction was confirmed.
- Applicable test. The claimant bore the burden of showing a real prospect of success, a good arguable case within an applicable gateway, and that England and Wales was clearly or distinctly the appropriate forum. The defendant’s application was effectively a rehearing, so the fact that permission had previously been granted placed no persuasive burden on the defendant.
- Negligent misrepresentation. The claim was not summarily hopeless. Whether the defendant’s conduct implied a representation that he had power to deal with the Spanish villa, and whether the claimant relied on it, required examination of the circumstances in which the agreement was made. A representation need only be an operative cause of conduct; it need not be the sole cause. The contractual context might ultimately prevent implication of a representation, but that issue was unsuitable for summary determination on the evidence available.
- The pleaded good-faith representation raised a different issue. A representation that a person held a belief in good faith, if false, was in the nature of an allegation of deceit rather than negligent misrepresentation. The judge invited the parties to consider the consequences, as no claim in deceit had been pleaded.
- Forum conveniens. England and Wales was clearly the most suitable forum. The parties were British, neither was domiciled in Spain, the principal witnesses were English-speaking, and the critical communications had taken place in English. The claimant lived in Wales, the defendant’s asserted inconvenience was unpersuasive, and the parties’ lawyers were already familiar with the dispute. Spanish law and evidence were relevant but not decisive. The risk of limitation in Spain also supported practical justice.
- Full and frank disclosure. The claimant’s failure to refer to earlier agreements and Spanish bank accounts did not amount to a material breach requiring discharge of the order. The agreements did not reasonably create doubt about permission to serve out, and there was no sufficient basis for inferring deliberate non-disclosure.
The court’s approach to earlier authorities
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Appellate history
Not stated in the judgment.
Key cases cited
22 authorities cited.
- VTB Capital plc v Nutritek International Corp and others [2013] UKSC 5
- AK Investment CJSC v Kyrgyz Mobil Tel Limited and others (Isle of Man) [2011] UKPC 7
- Her Majesty's Commissioners of Customs and Excise (Respondents) v. Barclays Bank plc (Appellants) [2006] UKHL 28
- Three Rivers District Council v. Governor and Company of the Bank of England [2001] UKHL 16
- Henderson v Merrett Syndicates Ltd (Feltrim Underwriting Agencies Ltd v Arbuthnott, Gooda Walker Ltd v Deeny, Hughes v Merrett Syndicates Ltd, Hallam-Eames v Merrett Syndicates Ltd, The Lloyd’s Litigation: the Merrett, Gooda Walker and Feltrim Cases) [1995] 2 AC 145
- Spiliada Maritime Corpn v Cansulex Ltd (The Spiliada) [1987] AC 460
- Hedley Byrne & Co Ltd v Heller & Partners Ltd [1964] AC 465
- TFL Management Services Ltd v Lloyds Bank Plc [2013] EWCA Civ 1415
- Mellor & Ors v Partridge & Anor [2013] EWCA Civ 477
- Advanced Industrial Technology Corporation Ltd v Bond Street Jewellers Ltd & Anor [2006] EWCA Civ 923
- PARTCO GROUP LTD. AND ANOTHER v. WRAGG AND SCOTT [2002] EWCA Civ 594 [2002] 2 Lloyd's Rep 343
- Wiggin Osborne Fullerlove (a firm) v Bond [2021] EWHC 1381 (Comm)
- Satfinance Investment Ltd v Athena Art Finance Corp [2020] EWHC 3527 (Ch)
- Punjab National Bank (International) Ltd v Srinivasan & Ors [2019] EWHC 3495 (Ch)
- Idemitsu Kosan Co Ltd v Sumitomo Corporation [2016] EWHC 1909 (Comm)
- Sycamore Bidco Ltd v Breslin & Anor [2012] EWHC 3443 (Ch)
- Easyair Ltd (t/a Openair) v Opal Telecom Ltd [2009] EWHC 339 (Ch)
- Millhouse Capital UK Ltd & Anor v Sibir Energy Plc & Ors [2008] EWHC 2614 (Ch)
- MRG (Japan) Ltd v Engelhard Metals japan Ltd [2003] EWHC 3418 (Comm)
- Microsoft Mobile OY v Sony Europe [2018] 1 All ER (Comm) 419
- The Pioneer Container (The KH Enterprise) [1994] 2 AC 324
- Amin Rasheed Shipping Corpn v Kuwait Insurance Co (The Al Wahab) [1984] AC 50
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Cases citing this case
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