Ostfriesische Volksbank EG v Fortis Bank

Ostfriesische Volksbank EG v Fortis Bank

A valid demand made before the expiry date suffices to keep the guarantee alive; the Lloyd’s decision, if triggered by a notice of dispute, need not be provided before the expiry date but must be provided within a reasonable time thereafter. The claimant did not breach any implied term as to timing.

Parties
Claimant: Ostfriesische Volksbank EG; Defendant: Fortis Bank
Jurisdiction
England and Wales
Judgment Date
29 January 2010
Procedural Posture
Commercial Claim (bank Guarantee Enforcement) / Judgment After Trial
Outcome
Judgment for the claimant
Legal Topics
Advance Payment Guarantee, Strict Construction of Guarantees, Implied Terms, Reasonable Time for Performance

Case Brief

Summary, issues, holding and outcome

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Parties

Ostfriesische Volksbank EG

Claimant

Fortis Bank

Defendant

Procedural Posture

Commercial Claim (bank Guarantee Enforcement) / Judgment After Trial

  1. 1 Whether the Lloyd’s decision had to be delivered by the guarantee expiry date for a valid claim
  2. 2 Whether there was an implied term to provide the Lloyd’s decision within a reasonable time
  3. 3 Whether the claimant breached any implied term regarding timing

Ratio Decidendi

A valid demand made before the expiry date suffices to keep the guarantee alive; the Lloyd’s decision, if triggered by a notice of dispute, need not be provided before the expiry date but must be provided within a reasonable time thereafter. The claimant did not breach any implied term as to timing.

Court Disposition

Judgment for the claimant

Orders

  • Defendant to pay the sum claimed under the guarantee