Titan Wealth Services Limited & Anor v Tavistock Investments PLC & Ors

Titan Wealth Services Limited & Anor v Tavistock Investments PLC & Ors

The amendment to plead breach of confidence was neither coherent nor sufficiently particularised to enable the appellants to understand the case against them. The definition of confidential information was broad and undefined, the pleading was self-contradictory, and the inference of misuse was not supported by the pleaded facts. The judge should not have allowed the amendment.

Parties
Claimant: Titan Wealth Services Limited; Appellant/claimant: Titan Asset Management Limited; Respondent/defendant/part 20 Claimant: Tavistock Investments PLC; Respondent/defendant/part 20 Claimant: Tavistock Asset Management Ltd; Defendant: Benjamin Scott Raven; Defendant: Steven Malcolm McGregor; Defendant: Brian Kenneth Raven; Third Party: Titan Wealth Holdings Ltd
Jurisdiction
England and Wales
Judgment Date
24 April 2026
Procedural Posture
Civil Appeal / Appeal From High Court Decision on Amendment of Defence and Counterclaim
Outcome
Appeal allowed
Legal Topics
Breach of Confidence, Copyright Infringement, Pleading Particularity, Amendment of Pleadings, Trade Secrets
Commercial Law Contract Law Intellectual Property Breach of Confidence Copyright Infringement Pleading Particularity Amendment of Pleadings Trade Secrets

Case Brief

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Parties

Titan Wealth Services Limited

Claimant

Titan Asset Management Limited

Appellant/claimant

Tavistock Investments PLC

Respondent/defendant/part 20 Claimant

Tavistock Asset Management Ltd

Respondent/defendant/part 20 Claimant

Benjamin Scott Raven

Defendant

Steven Malcolm McGregor

Defendant

Brian Kenneth Raven

Defendant

Titan Wealth Holdings Ltd

Third Party

Procedural Posture

Civil Appeal / Appeal From High Court Decision on Amendment of Defence and Counterclaim

Legal Issues

  1. 1 Whether the amendment to plead breach of confidence and copyright infringement should have been allowed
  2. 2 Whether the proposed pleading was coherent and sufficiently particularised

Ratio Decidendi

The amendment to plead breach of confidence was neither coherent nor sufficiently particularised to enable the appellants to understand the case against them. The definition of confidential information was broad and undefined, the pleading was self-contradictory, and the inference of misuse was not supported by the pleaded facts. The judge should not have allowed the amendment.

Court Disposition

Appeal allowed

Orders

  • Amendment to plead breach of confidence and copyright infringement disallowed
  • Liberty to apply for further amendment in the Commercial Court if a more focused case can be pleaded