Management Information Centre Limited v Royal Berkshire NHS Foundation Trust

Management Information Centre Limited v Royal Berkshire NHS Foundation Trust

The claim for breach of contract was legally recognisable and not merely speculative, given the information imbalance and potential for disclosure to reveal relevant evidence. The claim survived strike out and summary judgment except for the alternative implied agreement, which was legally inconsistent and must be struck out. The amended pleading cured defects regarding the implied duty of good faith.

Parties
Claimant/respondent: Management Information Centre Limited; Defendant/appellant: Royal Berkshire NHS Foundation Trust
Jurisdiction
England and Wales
Judgment Date
31 January 2025
Procedural Posture
Appeal / Judgment on Appeal Against Strike Out and Summary Judgment Orders
Outcome
Appeal allowed in part; paragraph 5.2 of the Amended Particulars of Claim struck out and/or summary judgment granted for Defendant; remainder of claim survives.
Legal Topics
Strike Out, Summary Judgment, Relational Contracts, Implied Terms, Good Faith, Disclosure
Contract Law Civil Procedure Strike Out Summary Judgment Relational Contracts Implied Terms Good Faith Disclosure

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Parties

Management Information Centre Limited

Claimant/respondent

Royal Berkshire NHS Foundation Trust

Defendant/appellant

Procedural Posture

Appeal / Judgment on Appeal Against Strike Out and Summary Judgment Orders

Legal Issues

  1. 1 Whether the claim disclosed reasonable grounds for breach of contract
  2. 2 Whether the contract pleaded lacked certainty and enforceability
  3. 3 Whether an implied overarching agreement could be inferred

Ratio Decidendi

The claim for breach of contract was legally recognisable and not merely speculative, given the information imbalance and potential for disclosure to reveal relevant evidence. The claim survived strike out and summary judgment except for the alternative implied agreement, which was legally inconsistent and must be struck out. The amended pleading cured defects regarding the implied duty of good faith.

Court Disposition

Appeal allowed in part; paragraph 5.2 of the Amended Particulars of Claim struck out and/or summary judgment granted for Defendant; remainder of claim survives.

Orders

  • Paragraph 5.2 of Amended Particulars of Claim struck out and/or summary judgment granted for Defendant
  • Claim otherwise proceeds