England and Wales Case Law

Dr Manori Balachandra v NHS Commissioning Board

The defendant was not entitled to withhold, set-off, or recover monies for UDAs actually performed by the claimant's practice in 2019-2020 solely due to late submission of FP17 forms; compliance with the two-month submission period is not a precondition for payment under the GDS Contract. For 2020-2021, the outcome depends on whether the claimant actually performed the required patient contacts to meet the 20% threshold under the Covid-19 modified scheme, pending further investigation.

Source excerpt

• General dental services contract
• Payment for dental services
• Covid-19 modified contractual arrangements
• Administrative compliance
• Clawback of payments

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Balachandra (t/a Manor Dental Surgery) v NHS Commissioning Board (Known As NHS England) (Rev1)

Balachandra (t/a Manor Dental Surgery) v NHS Commissioning Board (Known As NHS England) (Rev1) [2026] EWHC 294 (KB) (13 February 2026)

High Court dispute over unpaid NHS dental UDAs and Covid-era contract arrangements, with late FP17 and etriage submissions central to the issues.

• Nhs dental services
• General dental services contract
• Contractual interpretation
• Reasonableness in public contracts
• Covid-19 emergency measures
• Withholding of payment

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Tomkins v Knowsley Primary Care Trust

The High Court held that a binding NHS dental contract existed and that the Trust breached it by refusing to pay the agreed £100,000 Cross Lane value.

• General dental services contract
• Nhs contractual obligations
• Dispute resolution
• Entire agreement clause
• Statutory interpretation
• Public body financial duties

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Tomkins v Knowsley Primary Care Trust

Tomkins v Knowsley Primary Care Trust [2010] EWHC 1194 (QB) (25 May 2010)

The High Court held that a binding NHS dental contract existed and that the Trust could not set off a disputed £100,000 against sums due after arbitration.

• Nhs contracts
• General dental services contract
• Dispute resolution
• Contract formation
• Variation of contract
• Public sector contracting

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