Cargill International Trading Pte Ltd v Uttam Galva Steels Ltd

Cargill International Trading Pte Ltd v Uttam Galva Steels Ltd

The Seller's defences based on the prevention principle and estoppel by convention have no real prospect of success due to the express contractual terms requiring repayment regardless of any breach by the Buyer, and the absence of any enforceable common assumption obliging the Buyer to renew facilities.

Parties
Claimant: Cargill International Trading Pte Ltd; Defendant: Uttam Galva Steels Limited
Jurisdiction
England and Wales
Judgment Date
09 November 2018
Procedural Posture
Commercial Claim / Summary Judgment Application
Outcome
Summary judgment granted for the Claimant
Legal Topics
Summary Judgment, Advance Payment Agreements, No Set Off Clauses, Estoppel by Convention, Prevention Principle

Case Brief

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Parties

Cargill International Trading Pte Ltd

Claimant

Uttam Galva Steels Limited

Defendant

Procedural Posture

Commercial Claim / Summary Judgment Application

  1. 1 Whether the Seller has a real prospect of defending the claim for repayment under Advance Payment and Steel Supply Agreements
  2. 2 Whether the prevention principle or estoppel by convention can defeat the Buyer's claim for repayment

Ratio Decidendi

The Seller's defences based on the prevention principle and estoppel by convention have no real prospect of success due to the express contractual terms requiring repayment regardless of any breach by the Buyer, and the absence of any enforceable common assumption obliging the Buyer to renew facilities.

Court Disposition

Summary judgment granted for the Claimant

Orders

  • Seller to pay US$61.8 million to Buyer
  • Interest to be determined