Consolidated Finance Ltd v MccLuskey & Anor

Consolidated Finance Ltd v MccLuskey & Anor

It is not possible in the circumstances of this case to imply a term into the loan agreement that would satisfy section 11(1)(b) of the Consumer Credit Act 1974; the purpose clause is meaningless, and the agreement is not capable of being interpreted as a restricted-use credit agreement. The loan agreement is therefore a regulated agreement and not exempt.

Parties
Appellant/claimant: Consolidated Finance Limited; Respondent/defendant: McCluskey; Respondent/defendant: McCluskey's brother
Jurisdiction
England and Wales
Judgment Date
01 August 2012
Procedural Posture
Civil Appeal / Judgment on Appeal
Outcome
appeal dismissed
Legal Topics
Implied Terms, Regulated Agreements, Exempt Agreements, Loan Agreements, Statutory Interpretation

Case Brief

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Parties

Consolidated Finance Limited

Appellant/claimant

McCluskey

Respondent/defendant

McCluskey's brother

Respondent/defendant

Procedural Posture

Civil Appeal / Judgment on Appeal

  1. 1 Whether the loan agreement is an exempt agreement under the Consumer Credit Act 1974
  2. 2 Whether a term can be implied into the loan agreement to satisfy section 11(1)(b) of the Act

Ratio Decidendi

It is not possible in the circumstances of this case to imply a term into the loan agreement that would satisfy section 11(1)(b) of the Consumer Credit Act 1974; the purpose clause is meaningless, and the agreement is not capable of being interpreted as a restricted-use credit agreement. The loan agreement is therefore a regulated agreement and not exempt.

Court Disposition

appeal dismissed

Orders

  • no order on the Respondent's Notice