Standard Life Assurance Company v Egan Lawson Ltd [2000] EWCA Civ 293 (21 November 2000)

Standard Life Assurance Company v Egan Lawson Ltd [2000] EWCA Civ 293 (21 November 2000)

Egan Lawson's introduction was not the effective cause of Standard Life's purchase of the property. Their involvement ended in September 1997, and the transaction was initiated and completed as a result of a later introduction by Richard Ellis in November 1997. The chain of causation from Egan Lawson's introduction was broken, and the transaction would have occurred without their involvement. Therefore, Egan Lawson is not entitled to commission.

Citation
[2000] EWCA Civ 293
Parties
Claimant: Egan Lawson Limited; Defendant/appellant: Standard Life Assurance Company
Jurisdiction
England and Wales
Judgment Date
21 November 2000
Procedural Posture
Civil Appeal / Appeal Judgment
Outcome
appeal allowed
Legal Topics
Estate Agent Commission, Effective Cause, Introduction of Purchaser, Causation in Contract, Commercial Property Transactions
Contract Law Commercial Law Estate Agent Commission Effective Cause Introduction of Purchaser Causation in Contract Commercial Property Transactions

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Parties

Egan Lawson Limited

Claimant

Standard Life Assurance Company

Defendant/appellant

Procedural Posture

Civil Appeal / Appeal Judgment

Legal Issues

  1. 1 Whether Egan Lawson's introduction was the effective cause of Standard Life's purchase of the property
  2. 2 Whether Egan Lawson is entitled to commission for the transaction

Ratio Decidendi

Egan Lawson's introduction was not the effective cause of Standard Life's purchase of the property. Their involvement ended in September 1997, and the transaction was initiated and completed as a result of a later introduction by Richard Ellis in November 1997. The chain of causation from Egan Lawson's introduction was broken, and the transaction would have occurred without their involvement. Therefore, Egan Lawson is not entitled to commission.

Court Disposition

appeal allowed

Orders

  • Order of Hallett J set aside
  • Costs of the action, including the appeal, to be paid by Egan Lawson to Standard Life, to be assessed if not agreed