Mainstream Properties Ltd v Young & Ors

Mainstream Properties Ltd v Young & Ors

The tort of inducing breach of contract is not satisfied by showing that the defendant was reckless or mistaken as to whether his conduct interfered with the claimant’s contractual rights. Actual, subjective intention to interfere is required, and the trial judge's finding that the respondent did not have such intention is upheld. The appeal is dismissed.

Parties
Appellant: Mainstream Properties Ltd; Respondent: Young & Others
Jurisdiction
England and Wales
Judgment Date
13 July 2005
Procedural Posture
Civil Appeal / Appeal From High Court Judgment
Outcome
Appeal dismissed
Legal Topics
Inducing Breach of Contract, Economic Torts, Intention in Tort, Mistake of Law, Direct and Indirect Interference With Contractual Relations
Tort Law Contract Law Inducing Breach of Contract Economic Torts Intention in Tort Mistake of Law Direct and Indirect Interference With Contractual Relations

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Parties

Mainstream Properties Ltd

Appellant

Young & Others

Respondent

Procedural Posture

Civil Appeal / Appeal From High Court Judgment

Legal Issues

  1. 1 What is the requisite intention for the tort of inducing breach of contract?
  2. 2 Does recklessness or mistake of law suffice to establish liability for inducing breach of contract?
  3. 3 Is there a distinction between direct and indirect interference with contractual relations regarding intention?

Ratio Decidendi

The tort of inducing breach of contract is not satisfied by showing that the defendant was reckless or mistaken as to whether his conduct interfered with the claimant’s contractual rights. Actual, subjective intention to interfere is required, and the trial judge's finding that the respondent did not have such intention is upheld. The appeal is dismissed.

Court Disposition

Appeal dismissed

Orders

  • The appeal is dismissed.
  • The order of the High Court is affirmed.