Goldman Sachs International v Videocon Global Ltd & Anor [2014] EWHC 4267 (Comm) (19 December 2014)

Goldman Sachs International v Videocon Global Ltd & Anor [2014] EWHC 4267 (Comm) (19 December 2014)

A late but adequate notice under clause 6(d) of the ISDA Master Agreement is effective for payment purposes; the claimant is entitled to summary judgment as the contractual purpose of the notice has been fulfilled, and lateness only gives rise to a claim for damages if loss is caused.

Citation
[2014] EWHC 4267 (Comm)
Parties
Claimant: Goldman Sachs International; Defendant: Videocon Global Limited; Defendant: Videocon Industries Limited
Jurisdiction
England and Wales
Judgment Date
19 December 2014
Procedural Posture
Commercial Claim / Summary Judgment Application
Outcome
Summary judgment granted for the claimant
Legal Topics
ISDA Master Agreement, Currency Swaps, Summary Judgment, Notice Requirements

Case Brief

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Parties

Goldman Sachs International

Claimant

Videocon Global Limited

Defendant

Videocon Industries Limited

Defendant

Procedural Posture

Commercial Claim / Summary Judgment Application

  1. 1 Whether late provision of calculation details under clause 6(d) of ISDA Master Agreement renders the sum claimed unpayable
  2. 2 Whether the claimant is entitled to summary judgment despite late notice

Ratio Decidendi

A late but adequate notice under clause 6(d) of the ISDA Master Agreement is effective for payment purposes; the claimant is entitled to summary judgment as the contractual purpose of the notice has been fulfilled, and lateness only gives rise to a claim for damages if loss is caused.

Court Disposition

Summary judgment granted for the claimant

Orders

  • Claimant awarded US$4,066,542.90 plus interest and costs