Newton v Newton [1925] ScotCS CSIH_4 (17 June 1925)

Newton v Newton [1925] ScotCS CSIH_4 (17 June 1925)

A pursuer who expends money on property in the honest but mistaken belief that he is the owner is entitled to recompense from the true owner, even if he never had title, provided the belief was bona fide and the owner has benefited from the expenditure.

Citation
[1925] ScotCS CSIH_4
Parties
Pursuer: Newton; Defender: Newton
Jurisdiction
Scotland
Judgment Date
17 June 1925
Procedural Posture
Civil Appeal / Appeal From Sheriff Substitute to Court of Session Inner House
Outcome
appeal dismissed; interlocutor of Sheriff-substitute affirmed
Legal Topics
Recompense, Bona Fide Expenditure, Parole Evidence, Ownership, Donation, Title to Property

Case Brief

Summary, issues, holding and outcome

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Parties

Newton

Pursuer

Newton

Defender

Procedural Posture

Civil Appeal / Appeal From Sheriff Substitute to Court of Session Inner House

  1. 1 Whether the pursuer is entitled to recompense for expenditure on property held in the defender's name under the mistaken belief of ownership
  2. 2 Whether parole evidence is admissible to prove the pursuer's belief and intention
  3. 3 Whether a claim for recompense requires a bad title or merely a bona fide belief in title

Ratio Decidendi

A pursuer who expends money on property in the honest but mistaken belief that he is the owner is entitled to recompense from the true owner, even if he never had title, provided the belief was bona fide and the owner has benefited from the expenditure.

Court Disposition

appeal dismissed; interlocutor of Sheriff-substitute affirmed

Orders

  • Defender to pay £250 to pursuer as recompense for expenditure on the house