Benfield (Trading As Autoroute Circuits) v Life Racing Ltd [2007] EWHC 1505 (TCC) (13 July 2007)

Benfield (Trading As Autoroute Circuits) v Life Racing Ltd [2007] EWHC 1505 (TCC) (13 July 2007)

Autoroute, through Mr Benfield, owed and breached a duty to exercise reasonable skill and care in the design of the PCB layout for LRL's ECUs. The breach consisted of failing to keep up to date with manufacturing advances, failing to consult with the manufacturer regarding design rules, and adopting an unnecessarily complex and defective design using blind and buried vias, which was not required by the state of the art. There was no implied term as to fitness for purpose, but the conventional duty of skill and care applied. Autoroute was negligent and in breach of contract. The issues of causation, remoteness, and quantum of LRL's losses were reserved for a later trial.

Citation
[2007] EWHC 1505 (TCC)
Parties
Claimant: Roger Benfield (trading as Autoroute Circuits); Defendant: Life Racing Limited
Jurisdiction
England and Wales
Judgment Date
13 July 2007
Procedural Posture
Civil Contract and Negligence / Liability Trial (quantum and Remoteness Reserved for Later)
Outcome
Autoroute found liable in negligence and breach of contract; LRL's counterclaim on liability succeeds; Autoroute's claim for fees dismissed subject to quantum and remoteness to be determined in a later trial.
Legal Topics
Implied Terms, Duty of Care, Fitness for Purpose, Standard of Skill and Care, Manufacturing Defects, Remoteness of Damage
Contract Law Professional Negligence Commercial Law Implied Terms Duty of Care Fitness for Purpose Standard of Skill and Care Manufacturing Defects +1 more

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Parties

Roger Benfield (trading as Autoroute Circuits)

Claimant

Life Racing Limited

Defendant

Procedural Posture

Civil Contract and Negligence / Liability Trial (quantum and Remoteness Reserved for Later)

Legal Issues

  1. 1 What were the relevant terms of the contract between Autoroute and LRL?
  2. 2 Did Autoroute owe and breach a duty of care in the provision of PCB design services?
  3. 3 Was there an implied term as to fitness for purpose?

Ratio Decidendi

Autoroute, through Mr Benfield, owed and breached a duty to exercise reasonable skill and care in the design of the PCB layout for LRL's ECUs. The breach consisted of failing to keep up to date with manufacturing advances, failing to consult with the manufacturer regarding design rules, and adopting an unnecessarily complex and defective design using blind and buried vias, which was not required by the state of the art. There was no implied term as to fitness for purpose, but the conventional duty of skill and care applied. Autoroute was negligent and in breach of contract. The issues of causation, remoteness, and quantum of LRL's losses were reserved for a later trial.

Court Disposition

Autoroute found liable in negligence and breach of contract; LRL's counterclaim on liability succeeds; Autoroute's claim for fees dismissed subject to quantum and remoteness to be determined in a later trial.

Orders

  • Declaration of liability against Autoroute for negligence and breach of contract.
  • Autoroute's claim for outstanding fees dismissed subject to set-off and quantum to be determined.