Ham v Bell & Ors

Ham v Bell & Ors

There was no express or implied agreement to make the farm and milk quota assets of the new partnership; their inclusion in earlier accounts was a mistake, later corrected. John Ham always knew his parents' intention and was not misled or deprived of information. The partnership accounts do not evidence an agreement to transfer ownership, and rectification is not warranted.

Parties
Claimant: John Ronald Ham; Defendant: Jeremy Bevan Bell; Defendant: Keith Harden Turner; Defendant: Lorna Jean Ham
Jurisdiction
England and Wales
Judgment Date
11 April 2016
Procedural Posture
Civil / Judgment
Outcome
Claim dismissed
Legal Topics
Partnership Assets, Implied Agreements, Rectification of Accounts, Inheritance, Farming Partnerships

Case Brief

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Parties

John Ronald Ham

Claimant

Jeremy Bevan Bell

Defendant

Keith Harden Turner

Defendant

Lorna Jean Ham

Defendant

Procedural Posture

Civil / Judgment

  1. 1 Whether the farm and milk quota became assets of the new partnership
  2. 2 Effect of partnership accounts on asset ownership
  3. 3 Rectification of partnership accounts

Ratio Decidendi

There was no express or implied agreement to make the farm and milk quota assets of the new partnership; their inclusion in earlier accounts was a mistake, later corrected. John Ham always knew his parents' intention and was not misled or deprived of information. The partnership accounts do not evidence an agreement to transfer ownership, and rectification is not warranted.

Court Disposition

Claim dismissed

Orders

  • The farm and milk quota are not assets of the new partnership.
  • No rectification of partnership accounts is ordered.