Miles Platt Ltd. v Townroe Ltd. & Anor

Miles Platt Ltd. v Townroe Ltd. & Anor

The judicial expertise process in France was not substantive litigation between the same parties and did not trigger Article 21. The English and French proceedings were not so closely connected as to require a stay under Article 22. The Judge was correct to refuse a stay under both articles.

Parties
Appellant: Miles Platt Limited; Respondent: Townroe Limited
Jurisdiction
England and Wales
Judgment Date
13 February 2003
Procedural Posture
Civil Appeal / Appeal From High Court Judge
Outcome
Appeal dismissed
Legal Topics
Brussels Convention, Jurisdiction, Stay of Proceedings, Related Actions

Case Brief

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Parties

Miles Platt Limited

Appellant

Townroe Limited

Respondent

Procedural Posture

Civil Appeal / Appeal From High Court Judge

  1. 1 Whether the judicial expertise process in France constitutes proceedings involving the same cause of action and between the same parties under Article 21 of the 1968 Brussels Convention
  2. 2 Whether a stay should be imposed under Article 22 of the 1968 Brussels Convention due to related actions

Ratio Decidendi

The judicial expertise process in France was not substantive litigation between the same parties and did not trigger Article 21. The English and French proceedings were not so closely connected as to require a stay under Article 22. The Judge was correct to refuse a stay under both articles.

Court Disposition

Appeal dismissed

Orders

  • Appeal dismissed with costs agreed in the sum of £5,300.