JML Direct Ltd v Freesat UK Ltd

JML Direct Ltd v Freesat UK Ltd

Freesat did not breach its contractual obligations; it was entitled to exercise discretion in allocating EPG numbers, including attaching no weight to certain criteria, provided it acted rationally and in good faith. The use of BARB ratings and Freeview presence was not irrational or discriminatory. JML failed to prove any breach by Freesat.

Parties
Claimant: JML Direct Ltd; Defendant: Freesat UK Ltd
Jurisdiction
England and Wales
Judgment Date
26 March 2009
Procedural Posture
Commercial Contract Dispute / Judgment After Expedited Trial on Liability
Outcome
Claim dismissed
Legal Topics
Breach of Contract, Electronic Programme Guide (epg) Allocation, Ofcom Code Compliance, Discretion in Contractual Performance

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Parties

JML Direct Ltd

Claimant

Freesat UK Ltd

Defendant

Procedural Posture

Commercial Contract Dispute / Judgment After Expedited Trial on Liability

  1. 1 Whether Freesat breached its contractual obligations in allocating EPG numbers to JML's channels
  2. 2 Whether Freesat failed to comply with its Listing Policy and the Ofcom Code
  3. 3 Whether Freesat acted irrationally or arbitrarily in exercising its discretion under the contract

Ratio Decidendi

Freesat did not breach its contractual obligations; it was entitled to exercise discretion in allocating EPG numbers, including attaching no weight to certain criteria, provided it acted rationally and in good faith. The use of BARB ratings and Freeview presence was not irrational or discriminatory. JML failed to prove any breach by Freesat.

Court Disposition

Claim dismissed