SPS Technologies Ltd v Moitt & Ors

SPS Technologies Ltd v Moitt & Ors

The court found compelling evidence that the 1998, 1999 Rules and 2003 Deed did not reflect the true intention of the claimant regarding early retirement provisions for Transferred Members. The error was not intended and was carried forward inadvertently. The requirements for rectification were met, and the court ordered rectification of all three documents.

Parties
Claimant: SPS Technologies Limited; 1st Defendant: Phillex Lovester Moitt; 2nd Defendant: Michael Seitz; 3rd Defendant: Stephen Tachouet; 4th Defendant / Representative Beneficiary: Salim Sidat
Jurisdiction
England and Wales
Judgment Date
11 September 2020
Procedural Posture
Civil (pensions / Equity) / Summary Judgment Application; Final Judgment
Outcome
Summary judgment granted; rectification ordered
Legal Topics
Rectification of Deeds, Mistake in Pension Scheme Rules, Serial Rectification, Unilateral Amendment Powers, Trustee Duties
Equity Pensions Law Trusts Rectification of Deeds Mistake in Pension Scheme Rules Serial Rectification Unilateral Amendment Powers Trustee Duties

Case Brief

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Parties

SPS Technologies Limited

Claimant

Phillex Lovester Moitt

1st Defendant

Michael Seitz

2nd Defendant

Stephen Tachouet

3rd Defendant

Salim Sidat

4th Defendant / Representative Beneficiary

Procedural Posture

Civil (pensions / Equity) / Summary Judgment Application; Final Judgment

Legal Issues

  1. 1 Whether the 1998, 1999 Rules and 2003 Deed governing the SPS Technologies UK Pension Plan should be rectified to correct an error affecting early retirement provisions for Transferred Members
  2. 2 Whether the intention of the claimant at the time of execution supports rectification
  3. 3 Whether serial rectification of successive deeds is permissible

Ratio Decidendi

The court found compelling evidence that the 1998, 1999 Rules and 2003 Deed did not reflect the true intention of the claimant regarding early retirement provisions for Transferred Members. The error was not intended and was carried forward inadvertently. The requirements for rectification were met, and the court ordered rectification of all three documents.

Court Disposition

Summary judgment granted; rectification ordered

Orders

  • Rectification of the 1998, 1999 Rules and 2003 Deed governing the SPS Technologies UK Pension Plan to correct the error affecting early retirement provisions for Transferred Members.