Leeds Rugby Ltd v Harris & Anor [2005] EWHC 1591 (QB) (20 July 2005)

Leeds Rugby Ltd v Harris & Anor [2005] EWHC 1591 (QB) (20 July 2005)

Clause 5 of the Release Contract, while operating as a restraint on Mr Harris, was reasonable in the interests of both parties given the unique circumstances of the interlocking agreements, the benefit to Mr Harris in being released to play for Wales, and the provision for remuneration no less favourable than his Cardiff contract. The clause was not void for uncertainty as the remuneration could be determined by reference to the Cardiff contract, and the contract as a whole was supported by sufficient consideration.

Citation
[2005] EWHC 1591 (QB)
Parties
Claimant: Leeds Rugby Limited; First Defendant: Iestyn Harris; Second Defendant: Bradford Bulls Holdings Limited
Jurisdiction
England and Wales
Judgment Date
20 July 2005
Procedural Posture
Civil Contract / Trial of Preliminary Issues
Outcome
All preliminary issues answered in the negative; clauses 5 and 6 are not void for restraint of trade, lack of consideration, or uncertainty.
Legal Topics
Restraint of Trade, Consideration, Uncertainty in Contract Terms, Inducement of Breach of Contract
Contract Law Employment Law Sports Law Restraint of Trade Consideration Uncertainty in Contract Terms Inducement of Breach of Contract

Case Brief

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Parties

Leeds Rugby Limited

Claimant

Iestyn Harris

First Defendant

Bradford Bulls Holdings Limited

Second Defendant

Procedural Posture

Civil Contract / Trial of Preliminary Issues

Legal Issues

  1. 1 Whether clause 5 and/or 6 of the agreement dated 9 August 2001 are void as being in restraint of trade
  2. 2 Whether clauses 5 and/or 6 of the agreement are void on the grounds of lack of consideration
  3. 3 Whether clause 5 of the agreement is void for uncertainty

Ratio Decidendi

Clause 5 of the Release Contract, while operating as a restraint on Mr Harris, was reasonable in the interests of both parties given the unique circumstances of the interlocking agreements, the benefit to Mr Harris in being released to play for Wales, and the provision for remuneration no less favourable than his Cardiff contract. The clause was not void for uncertainty as the remuneration could be determined by reference to the Cardiff contract, and the contract as a whole was supported by sufficient consideration.

Court Disposition

All preliminary issues answered in the negative; clauses 5 and 6 are not void for restraint of trade, lack of consideration, or uncertainty.