Saleslease Ltd v Davis [1999] EWCA Civ 1138 (30 March 1999)

Saleslease Ltd v Davis [1999] EWCA Civ 1138 (30 March 1999)

The defendant was not sufficiently apprised of the special circumstances that would have enabled him to anticipate the plaintiffs' loss of the lucrative lease opportunity with Mr Gyles. Damages for conversion are limited to the market value of the goods, and no additional loss was recoverable as the defendant could not reasonably foresee the plaintiffs' inability to lease the equipment except to Mr Gyles.

Citation
[1999] EWCA Civ 1138
Parties
Plaintiff/respondent: Saleslease Limited; Defendant/appellant: Robert James Davis
Jurisdiction
England and Wales
Judgment Date
30 March 1999
Procedural Posture
Appeal From High Court (queen's Bench Division, Sheffield District Registry) / Court of Appeal Judgment
Outcome
Appeal allowed; judgment for the defendant
Legal Topics
Damages for Conversion, Remoteness of Damage, Assessment of Damages, Wrongful Detention of Goods
Tort Law Commercial Law Damages for Conversion Remoteness of Damage Assessment of Damages Wrongful Detention of Goods

Case Brief

Summary, issues, holding and outcome

More case intelligence is available

Unlock the full research layer for this judgment.

Full judgment text Downloadable case file Legal principles 3 Authorities cited 6 Party arguments 2 Amounts and remedies 7
Sign in to unlock

Parties

Saleslease Limited

Plaintiff/respondent

Robert James Davis

Defendant/appellant

Procedural Posture

Appeal From High Court (queen's Bench Division, Sheffield District Registry) / Court of Appeal Judgment

Legal Issues

  1. 1 What is the proper measure of damages for conversion where the plaintiff claims loss of a lucrative contract due to wrongful detention of goods?
  2. 2 Is consequential loss recoverable when the defendant was not apprised of special circumstances?

Ratio Decidendi

The defendant was not sufficiently apprised of the special circumstances that would have enabled him to anticipate the plaintiffs' loss of the lucrative lease opportunity with Mr Gyles. Damages for conversion are limited to the market value of the goods, and no additional loss was recoverable as the defendant could not reasonably foresee the plaintiffs' inability to lease the equipment except to Mr Gyles.

Court Disposition

Appeal allowed; judgment for the defendant

Orders

  • Order of the court below set aside
  • Judgment for the defendant