Saab & Anor v Angate Consulting Ltd & Ors

Saab & Anor v Angate Consulting Ltd & Ors

The defendants breached their contractual and equitable confidentiality obligations by disclosing confidential information obtained during their engagement to regulators, law enforcement, and third parties, without consent or notification, and by failing to deliver up confidential documents. The public interest defence failed because the disclosures lacked a sufficient evidence base, were overly broad, and did not meet the necessity threshold, especially as much of the information was already in the public domain or related to past events. The compulsion by law defence failed as the communications from Cypriot authorities were requests, not compulsory orders. Breaches of notification and...

Parties
Claimant: Mr Ayoub-Farid Michel Saab; Claimant: Mr Fadi Michel Saab; Defendant: Dangate Consulting Ltd; Defendant: Barrington London Limited; Defendant: Mr Nigel Brown; Defendant: Mr Alec Leighton
Jurisdiction
England and Wales
Judgment Date
20 June 2019
Procedural Posture
Civil (commercial Court) / Final Judgment After Trial
Outcome
Claim allowed in part; relief granted for breach of confidentiality obligations except as regards media disclosures and account of profits.
Legal Topics
Breach of Confidentiality, Public Interest Defence, Compulsion by Law, Contractual Obligations, Disclosure to Regulators, Remedies for Breach of Confidence
Contract Law Confidentiality Banking Law Breach of Confidentiality Public Interest Defence Compulsion by Law Contractual Obligations Disclosure to Regulators +1 more

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Parties

Mr Ayoub-Farid Michel Saab

Claimant

Mr Fadi Michel Saab

Claimant

Dangate Consulting Ltd

Defendant

Barrington London Limited

Defendant

Mr Nigel Brown

Defendant

Mr Alec Leighton

Defendant

Procedural Posture

Civil (commercial Court) / Final Judgment After Trial

Legal Issues

  1. 1 Whether the defendants breached contractual and equitable confidentiality obligations
  2. 2 Whether disclosures to regulators and third parties were protected by public interest or compulsion by law defences
  3. 3 Whether breaches occurred regarding notification and delivery up obligations

Ratio Decidendi

The defendants breached their contractual and equitable confidentiality obligations by disclosing confidential information obtained during their engagement to regulators, law enforcement, and third parties, without consent or notification, and by failing to deliver up confidential documents. The public interest defence failed because the disclosures lacked a sufficient evidence base, were overly broad, and did not meet the necessity threshold, especially as much of the information was already in the public domain or related to past events. The compulsion by law defence failed as the communications from Cypriot authorities were requests, not compulsory orders. Breaches of notification and...

Court Disposition

Claim allowed in part; relief granted for breach of confidentiality obligations except as regards media disclosures and account of profits.

Orders

  • Declaration of breach of confidentiality obligations by defendants
  • Prohibitory injunction against further unauthorised disclosures