John Brown & Co., Ltd v. Orr [1910] ScotLR 437 (10 February 1910)

John Brown & Co., Ltd v. Orr [1910] ScotLR 437 (10 February 1910)

The action for reduction was incompetent because statutory remedies under the Workmen's Compensation Act 1906 and Act of Sederunt provide the exclusive means to challenge the recording of a memorandum, thereby excluding common law remedies.

Citation
[1910] ScotLR 437
Parties
Pursuer: John Brown & Company, Limited; Defender: Christopher Orr
Jurisdiction
Scotland
Judgment Date
10 February 1910
Procedural Posture
Action for Reduction and Declarator / Appeal From Lord Ordinary's Interlocutor
Outcome
action dismissed
Legal Topics
Workmen's Compensation, Competency of Action, Statutory Remedies, Reduction of Memorandum

Case Brief

Summary, issues, holding and outcome

More case intelligence is available

Unlock the full research layer for this judgment.

Full judgment text Downloadable case file Legal principles 3 Authorities cited 9 Party arguments 2 Amounts and remedies 1
Sign in to unlock

Parties

John Brown & Company, Limited

Pursuer

Christopher Orr

Defender

Procedural Posture

Action for Reduction and Declarator / Appeal From Lord Ordinary's Interlocutor

  1. 1 Whether an action for reduction of a recorded memorandum of agreement under the Workmen's Compensation Act 1906 is competent when statutory remedies exist
  2. 2 Whether the Sheriff acts judicially or ministerially in recording such memorandum
  3. 3 Whether common law remedies are excluded by statutory remedies

Ratio Decidendi

The action for reduction was incompetent because statutory remedies under the Workmen's Compensation Act 1906 and Act of Sederunt provide the exclusive means to challenge the recording of a memorandum, thereby excluding common law remedies.

Court Disposition

action dismissed

Orders

  • Lord Ordinary's interlocutor recalled
  • plea of incompetency sustained