======================================================================= == Date: Sun, 1 Oct 2006 17:07:42 -0400 Reply-To: Lionel Smith Sender: Enrichment - Restitution & Unjust Enrichment Legal Issues From: Lionel Smith Subject: 11 years on Mime-version: 1.0 Content-type: text/plain; charset="US-ASCII" Content-transfer-encoding: 7bit Last year the ten-year anniversary of the RDG passed somewhat unremarked. To make some amends, I now light eleven candles and append, below, the very first posting, eleven years ago yesterday. We began with about thirty members; as of today, there are 329 subscribers. The geographic and juristic diversity has grown accordingly and the list shows subscribers on just about every continent. You might also notice in the message below that it asks members to "...spread the word about the group to colleagues who use email." Those were the days. The home of the list has moved from Edmonton, to Oxford (in 1996), to Montreal (in 2000). Steve Hedley's web site added an archive in 2000 which goes right back to the start; this is great because the 'official' archive at listserv ( http://list2.mcgill.ca/archives/enrichment.html) starts only at the move to McGill. Steve's archive shows a total of 1,507 postings, up to the end of August 2006. I post less "news" than I used to, in part because the volume of news has risen so much over the last eleven years. But I encourage everyone to feel free to post what they consider news, as well as questions and comments. Happy birthday RDG! Lionel > Sender: Lionel Smith > Date: Sat, 30 Sep 1995 14:40:09 -0700 > Re: Greetings everyone > > > Greetings everyone, and welcome to the restitution discussion group! Thank you > for your interest and for signing up. > > Some weeks ago I chose 30 September as the launch date for this undertaking, > without realizing that it was a Saturday. As a result I am sending out this > welcome message without much hope that anyone will see it until Monday. > > I am happy to report that there has been an enthusiastic response to the idea > of a restitution discussion group. The group begins life with about thirty > members. I am especially pleased to report that the membership includes an > excellent geographical and juristic diversity. There are members from > Australia, New Zealand, the UK, and Canada, including both common and civil > law traditions. I would like to thank those who helped to spread the word > about the group, including Mitchell McInnes in Australia, Don Clark in New > Zealand, and Peter Birks in the UK. I would ask everyone to continue to spread > the word about the group to colleagues who use email. > > Without further ado, then, I would like to open the floor. In case you no > longer have the message you received when you subscribed, the address for > postings is: > > [deleted as outdated] > > Actually there might be a little bit more ado. I will probably follow this > message with a short note about two minor changes to the way the list works, > which the computer people here have been working on this week. > > Thanks again, > > > > Lionel Smith > Faculty of Law > University of Alberta ____________________________________________________________________ This message was delivered through the Restitution Discussion Group, an international internet LISTSERV devoted to all aspects of the law of unjust enrichment. To subscribe, send "subscribe enrichment" in the body of a message to . To unsubscribe, send "signoff enrichment" to the same address. To make a posting to all group members, send to . The list is run by Lionel Smith of McGill University, . ======================================================================= == Date: Mon, 16 Oct 2006 10:17:43 +0100 Reply-To: Charles Mitchell Sender: Enrichment - Restitution & Unjust Enrichment Legal Issues From: Charles Mitchell Subject: Charter plc v City Index Ltd [2006] EWHC 2508 (Ch) MIME-Version: 1.0 Content-Type: text/plain; charset=ISO-8859-1; format="flowed" Content-Disposition: inline Content-Transfer-Encoding: 7bit Do claims for knowing receipt fall within the scope of the Civil Liability (Contribution) Act 1978: i.e. will a contribution claim lie under the statute between a defaulting fiduciary and a knowing recipient of misdirected trust funds? If claims for knowing receipt belong to the law of unjust enrichment, then Royal Brompton NHS Trust v Hammond [2002] 1 WLR 1397 suggests that they do not fall within the scope of the 1978 Act, as Lord Steyn held there that restitutionary claims in UE do not count as claims in respect of 'damage' as required by s 6. Although Lord Steyn does not say so, this is borne out by Hansard, a study of which reveals that Parliament (following the Law Commission's recommendations) intended not to bring claims in 'quasi-contract' within the scope of the 1978 legislation. One could get around this by saying that claims for knowing receipt are in fact wrong-based and not grounded in UE at all. However, in Charter plc v City Index Ltd [2006] EWHC 2508 (Ch), Morritt C more doubtfully holds that Lord Steyn's comments are obiter, and holds that even though claims in KR are 'restitutionary' they are also 'compensatory' in the sense that they are claims in respect of 'damage' as required by s 6. In principle, allowing contribution claims between knowing recipients and other classes of defendant liable for breach of trust is obviously desirable, but I doubt whether it is open to the courts to do this by allowing claims under the 1978 Act, rather than by developing the common law (cf Niru (No 2)). Morritt C also holds (rightly in my view) that as between a knowing recipient and a defaulting fiduciary, it will always be the recipient who should bear the burden of making good the beneficiaries' loss as he is the one who has personally benefited from the transaction. CM -- Charles Mitchell charles.mitchell@kcl.ac.uk ____________________________________________________________________ This message was delivered through the Restitution Discussion Group, an international internet LISTSERV devoted to all aspects of the law of unjust enrichment. To subscribe, send "subscribe enrichment" in the body of a message to . To unsubscribe, send "signoff enrichment" to the same address. To make a posting to all group members, send to . The list is run by Lionel Smith of McGill University, . ======================================================================= == Date: Mon, 16 Oct 2006 10:58:05 +0100 Reply-To: Andrew Tettenborn Sender: Enrichment - Restitution & Unjust Enrichment Legal Issues From: Andrew Tettenborn Subject: Re: Charter plc v City Index Ltd [2006] EWHC 2508 (Ch) Comments: To: Charles Mitchell In-Reply-To: <20061016101743.mocov9bqoo0w8ss8@impmail.kcl.ac.uk> MIME-Version: 1.0 Content-Type: text/plain; charset=ISO-8859-1; format=flowed Content-Transfer-Encoding: 7bit Charles Mitchell wrote: > Do claims for knowing receipt fall within the scope of the Civil > Liability (Contribution) Act 1978: i.e. will a contribution claim lie > under the statute between a defaulting fiduciary and a knowing > recipient of misdirected trust funds? If claims for knowing receipt > belong to the law of unjust enrichment, then Royal Brompton NHS Trust > v Hammond [2002] 1 WLR 1397 suggests that they do not fall within the > scope of the 1978 Act, as Lord Steyn held there that restitutionary > claims in UE do not count as claims in respect of 'damage' as required > by s 6. Although Lord Steyn does not say so, this is borne out by > Hansard, a study of which reveals that Parliament (following the Law > Commission's recommendations) intended not to bring claims in > 'quasi-contract' within the scope of the 1978 legislation. > > One could get around this by saying that claims for knowing receipt > are in fact wrong-based and not grounded in UE at all. However, in > Charter plc v City Index Ltd [2006] EWHC 2508 (Ch), Morritt C more > doubtfully holds that Lord Steyn's comments are obiter, and holds that > even though claims in KR are 'restitutionary' they are also > 'compensatory' in the sense that they are claims in respect of > 'damage' as required by s 6. > > In principle, allowing contribution claims between knowing recipients > and other classes of defendant liable for breach of trust is obviously > desirable, but I doubt whether it is open to the courts to do this by > allowing claims under the 1978 Act, rather than by developing the > common law (cf Niru (No 2)). > > Morritt C also holds (rightly in my view) that as between a knowing > recipient > and a defaulting fiduciary, it will always be the recipient who should > bear the burden of making good the beneficiaries' loss as he is the > one who has personally benefited from the transaction. > > CM I can't see the problem about City Index. Admittedly this is partly because I've always had difficulties with the idea that knowing receipt is about UE rather than wrongs. But even discounting this point, I don't think there's any doubt that a beneficiary suffering loss as a result of knowing receipt can recover that loss from the receiver. And if this is right, whyever not say that this is a liability for "damage?" The undeserving contribution claimant can always be dealt with as Morritt dealt with the claimant in City Index: but there may be situations where a receiver ought to get contribution (e.g. where there is a technical receipt but the receiver is then defrauded of whatever he received without having a chance to benefit from it). Andrew -- Andrew Tettenborn MA LLB Bracton Professor of Law University of Exeter, England Tel: 01392-263189 / +44-392-263189 (outside UK) Cellphone: 07870-130528 / +44-7870-130528 (outside UK) Fax: 01392-263196 / +44-392-263196 (outside UK) Snailmail: School of Law, University of Exeter, Amory Building, Rennes Drive, Exeter EX4 4RJ England Exeter Law School homepage: http://www.law.ex.ac.uk My homepage: http://www.law.ex.ac.uk/staff/tettenborn.shtml LAWYER, n. One skilled in circumvention of the law (Ambrose Bierce, 1906). ____________________________________________________________________ This message was delivered through the Restitution Discussion Group, an international internet LISTSERV devoted to all aspects of the law of unjust enrichment. To subscribe, send "subscribe enrichment" in the body of a message to . To unsubscribe, send "signoff enrichment" to the same address. To make a posting to all group members, send to . The list is run by Lionel Smith of McGill University, . ======================================================================= == Date: Mon, 16 Oct 2006 12:02:39 +0100 Reply-To: Charles Mitchell Sender: Enrichment - Restitution & Unjust Enrichment Legal Issues From: Charles Mitchell Subject: Re: Charter plc v City Index Ltd [2006] EWHC 2508 (Ch) Comments: To: Andrew Tettenborn In-Reply-To: <453357AD.3080403@ex.ac.uk> MIME-Version: 1.0 Content-Type: text/plain; charset=ISO-8859-1; format="flowed" Content-Disposition: inline Content-Transfer-Encoding: 7bit Dear Andrew I think there are 2 issues here. The first is whether we can meaningfully say, as a matter of everyday language, that a restitutionary claim grounded in UE is a claim 'in respect of damage'. You say that we can, and I agree, since I subscribe to the view that the law of UE has a corresponding loss requirement - i.e. I don't believe that a claimant can recover on the ground of UE without showing a loss (or 'damage') in his hands which corresponds to the gain in the defendant's hands which is the subject matter of his claim. Others disagree with this analysis (notably PB), but laying the point to one side, there is anyway a second issue in play, namely whether Parliament intended the 'same damage' requirement in the 1978 Act to bear the same meaning as its everyday meaning. You implicitly suggest that it did, but this is incorrect. The purpose of the 1978 Act was to widen out the scope of statutory contribution claims between wrongdoers, and Parliament, following the Law Commission, specifically excluded from the scope of the 1978 Act, claims in contract for debt, and claims in 'quasi-contract', which are not wrong-based claims. If your reading of the 'damage' requirement in the 1978 Act were correct, then a claim would lie between common debtors under the statute, since they could meaningfully be said to cause their creditor 'damage' if they failed to pay their debt. But we know that they are NOT covered by the statute, and this tells us that 'damage' has a specialised meaning in the context of the Act that enquiries into everyday usage will not help us discover. Best wishes Charles Quoting Andrew Tettenborn : > Charles Mitchell wrote: >> Do claims for knowing receipt fall within the scope of the Civil >> Liability (Contribution) Act 1978: i.e. will a contribution claim >> lie under the statute between a defaulting fiduciary and a knowing >> recipient of misdirected trust funds? If claims for knowing receipt >> belong to the law of unjust enrichment, then Royal Brompton NHS >> Trust v Hammond [2002] 1 WLR 1397 suggests that they do not fall >> within the scope of the 1978 Act, as Lord Steyn held there that >> restitutionary claims in UE do not count as claims in respect of >> 'damage' as required by s 6. Although Lord Steyn does not say so, >> this is borne out by Hansard, a study of which reveals that >> Parliament (following the Law Commission's recommendations) intended >> not to bring claims in 'quasi-contract' within the scope of the 1978 >> legislation. >> >> One could get around this by saying that claims for knowing receipt >> are in fact wrong-based and not grounded in UE at all. However, in >> Charter plc v City Index Ltd [2006] EWHC 2508 (Ch), Morritt C more >> doubtfully holds that Lord Steyn's comments are obiter, and holds >> that even though claims in KR are 'restitutionary' they are also >> 'compensatory' in the sense that they are claims in respect of >> 'damage' as required by s 6. >> >> In principle, allowing contribution claims between knowing >> recipients and other classes of defendant liable for breach of trust >> is obviously desirable, but I doubt whether it is open to the courts >> to do this by allowing claims under the 1978 Act, rather than by >> developing the common law (cf Niru (No 2)). >> >> Morritt C also holds (rightly in my view) that as between a knowing >> recipient >> and a defaulting fiduciary, it will always be the recipient who >> should bear the burden of making good the beneficiaries' loss as he >> is the one who has personally benefited from the transaction. >> >> CM > I can't see the problem about City Index. Admittedly this is partly > because I've always had difficulties with the idea that knowing > receipt is about UE rather than wrongs. But even discounting this > point, I don't think there's any doubt that a beneficiary suffering > loss as a result of knowing receipt can recover that loss from the > receiver. And if this is right, whyever not say that this is a > liability for "damage?" The undeserving contribution claimant can > always be dealt with as Morritt dealt with the claimant in City > Index: but there may be situations where a receiver ought to get > contribution (e.g. where there is a technical receipt but the > receiver is then defrauded of whatever he received without having a > chance to benefit from it). > > > Andrew > > > > -- > Andrew Tettenborn MA LLB > Bracton Professor of Law > University of Exeter, England > > > Tel: 01392-263189 / +44-392-263189 (outside UK) > Cellphone: 07870-130528 / +44-7870-130528 (outside UK) > Fax: 01392-263196 / +44-392-263196 (outside UK) > > Snailmail: School of Law, > University of Exeter, > Amory Building, > Rennes Drive, > Exeter EX4 4RJ > England > > Exeter Law School homepage: http://www.law.ex.ac.uk My homepage: > http://www.law.ex.ac.uk/staff/tettenborn.shtml > > > > > > LAWYER, n. One skilled in circumvention of the law (Ambrose Bierce, 1906). > > -- Charles Mitchell charles.mitchell@kcl.ac.uk ____________________________________________________________________ This message was delivered through the Restitution Discussion Group, an international internet LISTSERV devoted to all aspects of the law of unjust enrichment. To subscribe, send "subscribe enrichment" in the body of a message to . To unsubscribe, send "signoff enrichment" to the same address. To make a posting to all group members, send to . The list is run by Lionel Smith of McGill University, . ======================================================================= == Date: Mon, 16 Oct 2006 13:25:16 +0100 Reply-To: Andrew Tettenborn Sender: Enrichment - Restitution & Unjust Enrichment Legal Issues From: Andrew Tettenborn Subject: Re: Charter plc v City Index Ltd [2006] EWHC 2508 (Ch) Comments: To: Charles Mitchell In-Reply-To: <20061016120239.0y2sf9sog04kksso@impmail.kcl.ac.uk> MIME-Version: 1.0 Content-Type: text/plain; charset=ISO-8859-1; format=flowed Content-Transfer-Encoding: 7bit Charles Mitchell wrote: > Dear Andrew > > I think there are 2 issues here. The first is whether we can > meaningfully say, as a matter of everyday language, that a > restitutionary claim grounded in UE is a claim 'in respect of > damage'. You say that we can, and I agree, since I subscribe to the > view that the law of UE has a corresponding loss requirement - i.e. I > don't believe that a claimant can recover on the ground of UE without > showing a loss (or 'damage') in his hands which corresponds to the > gain in the defendant's hands which is the subject matter of his claim. > > Others disagree with this analysis (notably PB), but laying the point > to one side, there is anyway a second issue in play, namely whether > Parliament intended the 'same damage' requirement in the 1978 Act to > bear the same meaning as its everyday meaning. You implicitly suggest > that it did, but this is incorrect. The purpose of the 1978 Act was > to widen out the scope of statutory contribution claims between > wrongdoers, and Parliament, following the Law Commission, specifically > excluded from the scope of the 1978 Act, claims in contract for debt, > and claims in 'quasi-contract', which are not wrong-based claims. If > your reading of the 'damage' requirement in the 1978 Act were correct, > then a claim would lie between common debtors under the statute, since > they could meaningfully be said to cause their creditor 'damage' if > they failed to pay their debt. But we know that they are NOT covered > by the statute, and this tells us that 'damage' has a specialised > meaning in the context of the Act that enquiries into everyday usage > will not help us discover. > > Best wishes > Charles > > > > > > Quoting Andrew Tettenborn : > >> Charles Mitchell wrote: >>> Do claims for knowing receipt fall within the scope of the Civil >>> Liability (Contribution) Act 1978: i.e. will a contribution claim >>> lie under the statute between a defaulting fiduciary and a knowing >>> recipient of misdirected trust funds? If claims for knowing receipt >>> belong to the law of unjust enrichment, then Royal Brompton NHS >>> Trust v Hammond [2002] 1 WLR 1397 suggests that they do not fall >>> within the scope of the 1978 Act, as Lord Steyn held there that >>> restitutionary claims in UE do not count as claims in respect of >>> 'damage' as required by s 6. Although Lord Steyn does not say so, >>> this is borne out by Hansard, a study of which reveals that >>> Parliament (following the Law Commission's recommendations) intended >>> not to bring claims in 'quasi-contract' within the scope of the 1978 >>> legislation. >>> >>> One could get around this by saying that claims for knowing receipt >>> are in fact wrong-based and not grounded in UE at all. However, in >>> Charter plc v City Index Ltd [2006] EWHC 2508 (Ch), Morritt C more >>> doubtfully holds that Lord Steyn's comments are obiter, and holds >>> that even though claims in KR are 'restitutionary' they are also >>> 'compensatory' in the sense that they are claims in respect of >>> 'damage' as required by s 6. >>> >>> In principle, allowing contribution claims between knowing >>> recipients and other classes of defendant liable for breach of trust >>> is obviously desirable, but I doubt whether it is open to the courts >>> to do this by allowing claims under the 1978 Act, rather than by >>> developing the common law (cf Niru (No 2)). >>> >>> Morritt C also holds (rightly in my view) that as between a knowing >>> recipient >>> and a defaulting fiduciary, it will always be the recipient who >>> should bear the burden of making good the beneficiaries' loss as he >>> is the one who has personally benefited from the transaction. >>> >>> CM >> I can't see the problem about City Index. Admittedly this is partly >> because I've always had difficulties with the idea that knowing >> receipt is about UE rather than wrongs. But even discounting this >> point, I don't think there's any doubt that a beneficiary suffering >> loss as a result of knowing receipt can recover that loss from the >> receiver. And if this is right, whyever not say that this is a >> liability for "damage?" The undeserving contribution claimant can >> always be dealt with as Morritt dealt with the claimant in City >> Index: but there may be situations where a receiver ought to get >> contribution (e.g. where there is a technical receipt but the >> receiver is then defrauded of whatever he received without having a >> chance to benefit from it). >> >> >> Andrew >> >> >> >> -- >> Andrew Tettenborn MA LLB >> Bracton Professor of Law >> University of Exeter, England >> >> >> Tel: 01392-263189 / +44-392-263189 (outside UK) >> Cellphone: 07870-130528 / +44-7870-130528 (outside UK) >> Fax: 01392-263196 / +44-392-263196 (outside UK) >> >> Snailmail: School of Law, >> University of Exeter, >> Amory Building, >> Rennes Drive, >> Exeter EX4 4RJ >> England >> >> Exeter Law School homepage: http://www.law.ex.ac.uk My homepage: >> http://www.law.ex.ac.uk/staff/tettenborn.shtml >> >> >> >> >> >> LAWYER, n. One skilled in circumvention of the law (Ambrose Bierce, >> 1906). >> >> > > > Dear Charles, I absolutely accept that claims for money paid by mistake and for payment of debts weren't meant to be, and aren't, covered by the 1978 Act. But I'm not sure the claim for knowing receipt can be lumped together with them. As regards mistaken payments and claims in debt it is simply beside the point that the claimant suffered a reduced loss, or no loss at all. Not so, I suggest, with knowing receipt. Suppose in Target Holdings v Redferns [1996] AC 421 the money wrongly paid away by the solicitors had passed through the hands of some party X, and X (having paid it away) had been sued for knowing receipt. It seems self-evident that if the solicitors could pray in aid the fact that the claimants' loss had not been caused by their paying the money to X, X must be allowed to say the same about his receiving it from them. If so, then whatever noises people may make about restitution, I think that in this connection we're talking about liability for damage of the kind the 1978 Act was meant to address. Best wishes Andrew -- Andrew Tettenborn MA LLB Bracton Professor of Law University of Exeter, England Tel: 01392-263189 / +44-392-263189 (outside UK) Cellphone: 07870-130528 / +44-7870-130528 (outside UK) Fax: 01392-263196 / +44-392-263196 (outside UK) Snailmail: School of Law, University of Exeter, Amory Building, Rennes Drive, Exeter EX4 4RJ England Exeter Law School homepage: http://www.law.ex.ac.uk My homepage: http://www.law.ex.ac.uk/staff/tettenborn.shtml LAWYER, n. One skilled in circumvention of the law (Ambrose Bierce, 1906). ____________________________________________________________________ This message was delivered through the Restitution Discussion Group, an international internet LISTSERV devoted to all aspects of the law of unjust enrichment. To subscribe, send "subscribe enrichment" in the body of a message to . To unsubscribe, send "signoff enrichment" to the same address. To make a posting to all group members, send to . The list is run by Lionel Smith of McGill University, . ======================================================================= == Date: Tue, 17 Oct 2006 16:04:44 +0100 Reply-To: Charles Mitchell Sender: Enrichment - Restitution & Unjust Enrichment Legal Issues From: Charles Mitchell Subject: Sir Robert Megarry Comments: cc: obligations@uwo.ca Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii"; format=flowed Members of the RDG and ODG may both want to know that Sir Robert Megarry has died, aged 96. There are obituaries at: http://www.timesonline.co.uk/article/0,,60-2405449.html and http://www.telegraph.co.uk/news/main.jhtml?xml=/news/2006/10/17/db1701. xml CM Professor Charles Mitchell School of Law King's College London Strand London WC2R 2LS tel: 020 7848 2290 fax: 020 7848 2465 ____________________________________________________________________ This message was delivered through the Restitution Discussion Group, an international internet LISTSERV devoted to all aspects of the law of unjust enrichment. To subscribe, send "subscribe enrichment" in the body of a message to . To unsubscribe, send "signoff enrichment" to the same address. To make a posting to all group members, send to . The list is run by Lionel Smith of McGill University, . ======================================================================= == Date: Tue, 17 Oct 2006 17:03:30 +0100 Reply-To: Charles Mitchell Sender: Enrichment - Restitution & Unjust Enrichment Legal Issues From: Charles Mitchell Subject: Re: ODG: Sir Robert Megarry Comments: To: Hector MacQueen Comments: cc: obligations@uwo.ca In-Reply-To: <20061017165011.6zhq8n9t44osw4ow@www.staffmail.ed.ac.uk> Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii"; format=flowed Dear Hector You'll see that the Telegraph obituarist quotes him as saying that: >"One of the examiners congratulated me on my economy of effort," he >recalled. "If I'd got one mark less I'd have failed. As it was I came away >with a Third." I wonder about this, though: would he not have got a Fourth if he'd got one mark less? I don't know how the degree classification rules worked at Cambridge in the 30s. Best wishes Charles At 16:50 17/10/2006 +0100, Hector MacQueen wrote: >The Times obit was rather good, but disappointingly didn't mention either >Coco v Clark or Ross v Caunters which are surely among Megarry's more >distinctive claims to fame. Also, I have a memory of a story told to me >long ago by the late Alf Donaldson, former Parliamentary draftsman at >Stormont and a younger contemporary of Megarry in Northern Ireland, that >Megarry got a pass or fourth class degree. The Times rather glosses over >his student career, and I wonder if anyone can confirm the truth or >otherwise of the story. > >Hector > >-- >Hector L MacQueen >Professor of Private Law >Director, AHRC Research Centre Intellectual Property and Technology Law >Edinburgh Law School >University of Edinburgh >Edinburgh EH8 9YL >UK >Tel: (0)131-650-2060; Fax: (0)131-662-6317 > > >Quoting Charles Mitchell : > >>Members of the RDG and ODG may both want to know that Sir Robert Megarry >>has died, aged 96. There are obituaries at: >>http://www.timesonline.co.uk/article/0,,60-2405449.html and >>http://www.telegraph.co.uk/news/main.jhtml?xml=/news/2006/10/17/db170 1.xml >> >>CM >> >> >> >>Professor Charles Mitchell >>School of Law >>King's College London >>Strand >>London WC2R 2LS >> >>tel: 020 7848 2290 >>fax: 020 7848 2465 >> >>-- >> >>This message was delivered through the Obligations Discussion Group, an >>international mailing list devoted to all aspects of the law of >>obligations. To be added or deleted from the list please send a message >>to . To make a posting to all group members, >>send a message to . The list is run by Jason Neyers >>of the University of Western Ontario, tel. (+1) 519 661-2111 x. >>88435,email . The list is archived at >>. Archived messages are not to be >>cited in published works without prior approval of the author. > > ____________________________________________________________________ This message was delivered through the Restitution Discussion Group, an international internet LISTSERV devoted to all aspects of the law of unjust enrichment. To subscribe, send "subscribe enrichment" in the body of a message to . To unsubscribe, send "signoff enrichment" to the same address. To make a posting to all group members, send to . The list is run by Lionel Smith of McGill University, . ======================================================================= == Date: Tue, 17 Oct 2006 13:34:17 -0400 Reply-To: Lionel Smith Sender: Enrichment - Restitution & Unjust Enrichment Legal Issues From: Lionel Smith Subject: Sir Robert Megarry In-Reply-To: <20061017172412.p0ugyf9r4ggw4ww4@www.staffmail.ed.ac.uk> Mime-version: 1.0 Content-type: text/plain; charset="US-ASCII" Content-transfer-encoding: 7bit Interesting. Alf was a great raconteur, as befitted a parliamentary draftsman, and the story may have developed a little over the years! Hector -- Hector L MacQueen Professor of Private Law Director, AHRC Research Centre Intellectual Property and Technology Law Edinburgh Law School University of Edinburgh Edinburgh EH8 9YL UK Tel: (0)131-650-2060; Fax: (0)131-662-6317 Quoting Charles Mitchell : > Dear Hector > > You'll see that the Telegraph obituarist quotes him as saying that: > >> "One of the examiners congratulated me on my economy of effort," he >> recalled. "If I'd got one mark less I'd have failed. As it was I >> came away with a Third." > > I wonder about this, though: would he not have got a Fourth if he'd got one > mark less? I don't know how the degree classification rules worked at > Cambridge in the 30s. > > Best wishes > Charles > > At 16:50 17/10/2006 +0100, Hector MacQueen wrote: >> The Times obit was rather good, but disappointingly didn't mention >> either Coco v Clark or Ross v Caunters which are surely among >> Megarry's more distinctive claims to fame. Also, I have a memory of >> a story told to me long ago by the late Alf Donaldson, former >> Parliamentary draftsman at Stormont and a younger contemporary of >> Megarry in Northern Ireland, that Megarry got a pass or fourth class >> degree. The Times rather glosses over his student career, and I >> wonder if anyone can confirm the truth or otherwise of the story. >> >> Hector >> >> -- >> Hector L MacQueen >> Professor of Private Law >> Director, AHRC Research Centre Intellectual Property and Technology Law >> Edinburgh Law School >> University of Edinburgh >> Edinburgh EH8 9YL >> UK >> Tel: (0)131-650-2060; Fax: (0)131-662-6317 >> >> >> Quoting Charles Mitchell : >> >>> Members of the RDG and ODG may both want to know that Sir Robert Megarry >>> has died, aged 96. There are obituaries at: >>> http://www.timesonline.co.uk/article/0,,60-2405449.html and >>> http://www.telegraph.co.uk/news/main.jhtml?xml=/news/2006/10/17/db1701. xml >>> >>> CM >>> >>> >>> >>> Professor Charles Mitchell >>> School of Law >>> King's College London >>> Strand >>> London WC2R 2LS >>> >>> tel: 020 7848 2290 >>> fax: 020 7848 2465 >>> >>> -- >>> >>> This message was delivered through the Obligations Discussion >>> Group, an international mailing list devoted to all aspects of the >>> law of obligations. To be added or deleted from the list please >>> send a message to . To make a posting >>> to all group members, send a message to . The >>> list is run by Jason Neyers of the University of Western Ontario, >>> tel. (+1) 519 661-2111 x. 88435,email . The list is >>> archived at . Archived messages >>> are not to be cited in published works without prior approval of >>> the author. >> >> > > -- This message was delivered through the Obligations Discussion Group, an international mailing list devoted to all aspects of the law of obligations. To be added or deleted from the list please send a message to . To make a posting to all group members, send a message to . The list is run by Jason Neyers of the University of Western Ontario, tel. (+1) 519 661-2111 x. 88435,email . The list is archived at . Archived messages are not to be cited in published works without prior approval of the author. ------ End of Forwarded Message ____________________________________________________________________ This message was delivered through the Restitution Discussion Group, an international internet LISTSERV devoted to all aspects of the law of unjust enrichment. To subscribe, send "subscribe enrichment" in the body of a message to . To unsubscribe, send "signoff enrichment" to the same address. To make a posting to all group members, send to . The list is run by Lionel Smith of McGill University, . ======================================================================= == Date: Fri, 20 Oct 2006 03:37:01 +0100 Reply-To: Michael Rush Sender: Enrichment - Restitution & Unjust Enrichment Legal Issues From: Michael Rush Subject: Unjust Enrichment in Australia In-Reply-To: <45337A2C.9000600@ex.ac.uk> Content-Type: text/plain Content-Disposition: inline Content-Transfer-Encoding: 7bit MIME-Version: 1.0 I'm pleased to report that the latest authoritative text on the law of Unjust Enrichment in Australia has recently been published: Edelman and Bant, "Unjust Enrichment in Australia" (OUP 2006). I note that the ever efficient Steve Hedley has a link to it on his site: http://www.dadirect.com/Books/Frame_Detail.asp?OneItem=1&isbn=019551719 9 With it being available for purchase here (although you have to undertake a search to get to it): http://au.oup.com/content/general.asp?Content=welcomeAU&SetCountry=AU Michael ____________________________________________________________________ This message was delivered through the Restitution Discussion Group, an international internet LISTSERV devoted to all aspects of the law of unjust enrichment. To subscribe, send "subscribe enrichment" in the body of a message to . To unsubscribe, send "signoff enrichment" to the same address. To make a posting to all group members, send to . The list is run by Lionel Smith of McGill University, . ======================================================================= == Date: Mon, 23 Oct 2006 12:25:00 +0100 Reply-To: Charles Mitchell Sender: Enrichment - Restitution & Unjust Enrichment Legal Issues From: Charles Mitchell Subject: Re: Charter plc v City Index Ltd [2006] EWHC 2508 (Ch) Comments: To: Andrew Tettenborn In-Reply-To: <45337A2C.9000600@ex.ac.uk> Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii"; format=flowed >Dear Charles, > >I absolutely accept that claims for money paid by mistake and for payment >of debts weren't meant to be, and aren't, covered by the 1978 Act. But I'm >not sure the claim for knowing receipt can be lumped together with them. >As regards mistaken payments and claims in debt it is simply beside the >point that the claimant suffered a reduced loss, or no loss at all. Not >so, I suggest, with knowing receipt. Suppose in Target Holdings v Redferns >[1996] AC 421 the money wrongly paid away by the solicitors had passed >through the hands of some party X, and X (having paid it away) had been >sued for knowing receipt. It seems self-evident that if the solicitors >could pray in aid the fact that the claimants' loss had not been caused by >their paying the money to X, X must be allowed to say the same about his >receiving it from them. > >If so, then whatever noises people may make about restitution, I think >that in this connection we're talking about liability for damage of the >kind the 1978 Act was meant to address. > > >Best wishes > >Andrew Dear Andrew I'm afraid I have some problems with this. For the reasons set out in Hayton & Marshall at 707-711 (following Lord Millett and Steven Elliott) Lord B-W made a false move when he dragged causation into Target as the claim made against the trustee was not wrong-based. But even if that were not so, I still wouldn't agree that it is 'self-evident' that a knowing recipient should escape liability because the trustee who has paid him can rely on a causation argument to escape his own liability to the beneficiaries. One might as well say that the recipient of a mistaken payment should not have to repay the money because a solicitor who carelessly advised the mistaken payor to pay the money is not liable in negligence because the payor would have paid the money anyway. Whether or not the solicitor's negligence causes the payor's loss, the payor is still out of pocket, and the recipient correspondingly enriched, as a result of the payor's mistake. The recipient must repay regardless of the solicitor's position. Why is this not also true of the KR? Best wishes Charles ____________________________________________________________________ This message was delivered through the Restitution Discussion Group, an international internet LISTSERV devoted to all aspects of the law of unjust enrichment. To subscribe, send "subscribe enrichment" in the body of a message to . To unsubscribe, send "signoff enrichment" to the same address. To make a posting to all group members, send to . The list is run by Lionel Smith of McGill University, . ======================================================================= == Date: Mon, 23 Oct 2006 17:01:47 +0100 Reply-To: Andrew Tettenborn Sender: Enrichment - Restitution & Unjust Enrichment Legal Issues From: Andrew Tettenborn Subject: Re: Charter plc v City Index Ltd [2006] EWHC 2508 (Ch) Comments: To: Charles Mitchell In-Reply-To: <5.1.0.14.2.20061023115607.01eb8008@pop.kcl.ac.uk> MIME-Version: 1.0 Content-Type: text/plain; charset=ISO-8859-1; format=flowed Content-Transfer-Encoding: 7bit Charles Mitchell wrote: > >> Dear Charles, >> >> I absolutely accept that claims for money paid by mistake and for >> payment of debts weren't meant to be, and aren't, covered by the 1978 >> Act. But I'm not sure the claim for knowing receipt can be lumped >> together with them. As regards mistaken payments and claims in debt >> it is simply beside the point that the claimant suffered a reduced >> loss, or no loss at all. Not so, I suggest, with knowing receipt. >> Suppose in Target Holdings v Redferns [1996] AC 421 the money wrongly >> paid away by the solicitors had passed through the hands of some >> party X, and X (having paid it away) had been sued for knowing >> receipt. It seems self-evident that if the solicitors could pray in >> aid the fact that the claimants' loss had not been caused by their >> paying the money to X, X must be allowed to say the same about his >> receiving it from them. >> >> If so, then whatever noises people may make about restitution, I >> think that in this connection we're talking about liability for >> damage of the kind the 1978 Act was meant to address. >> >> >> Best wishes >> >> Andrew > > > Dear Andrew > > I'm afraid I have some problems with this. For the reasons set out in > Hayton & Marshall at 707-711 (following Lord Millett and Steven > Elliott) Lord B-W made a false move when he dragged causation into > Target as the claim made against the trustee was not wrong-based. But > even if that were not so, I still wouldn't agree that it is > 'self-evident' that a knowing recipient should escape liability > because the trustee who has paid him can rely on a causation argument > to escape his own liability to the beneficiaries. One might as well > say that the recipient of a mistaken payment should not have to repay > the money because a solicitor who carelessly advised the mistaken > payor to pay the money is not liable in negligence because the payor > would have paid the money anyway. Whether or not the solicitor's > negligence causes the payor's loss, the payor is still out of pocket, > and the recipient correspondingly enriched, as a result of the payor's > mistake. The recipient must repay regardless of the solicitor's > position. Why is this not also true of the KR? > > Best wishes > Charles > > Dear Charles, You make 2 beguiling points: (a) The correctness / desirability of the Target solution. On this I'm afraid I just differ with Hayton & Marshall: despite some rather confused C19 dicta, a claim against a defendant trustee that she make good the claimant for a sum she no longer has in her hands but ought to have seems to me to bear all the hallmarks of a claim for a wrong. In my view we should recognise this fact. (b) The equiparation of the KR and the recipient of a mistaken payment. This depends on the correctness of the assertion that the KR's liability depends (or ought to depend) on UE. A lot of people regard this as axiomatic: I don't. We have two liabilities in the English law of trusts: that of the non-BFP defendant who still has the trust property, and that of the defendant who once had it but doesn't have it any more, otherwise known as the KR. My own view is that the most natural way of looking at the latter's liability is wrong-based. It seems to me perverse to take a liability specifically aimed at a defendant who no longer has an asset, say it's UE-based and then start arguing how far she should be allowed to pray in aid the fact that she's got rid of it. I suspect any European lawyer from outside the British Isles would regard this as a sensible approach, and for once I think they'd be right. Best wishes Andrew -- Andrew Tettenborn MA LLB Bracton Professor of Law University of Exeter, England Tel: 01392-263189 / +44-392-263189 (outside UK) Cellphone: 07870-130528 / +44-7870-130528 (outside UK) Fax: 01392-263196 / +44-392-263196 (outside UK) Snailmail: School of Law, University of Exeter, Amory Building, Rennes Drive, Exeter EX4 4RJ England Exeter Law School homepage: http://www.law.ex.ac.uk My homepage: http://www.law.ex.ac.uk/staff/tettenborn.shtml LAWYER, n. One skilled in circumvention of the law (Ambrose Bierce, 1906). ____________________________________________________________________ This message was delivered through the Restitution Discussion Group, an international internet LISTSERV devoted to all aspects of the law of unjust enrichment. To subscribe, send "subscribe enrichment" in the body of a message to . To unsubscribe, send "signoff enrichment" to the same address. To make a posting to all group members, send to . The list is run by Lionel Smith of McGill University, . ======================================================================= == Date: Mon, 23 Oct 2006 17:36:35 +0100 Reply-To: Charles Mitchell Sender: Enrichment - Restitution & Unjust Enrichment Legal Issues From: Charles Mitchell Subject: Re: Charter plc v City Index Ltd [2006] EWHC 2508 (Ch) Comments: To: Andrew Tettenborn In-Reply-To: <453CE76B.5030906@ex.ac.uk> Mime-Version: 1.0 Content-Type: multipart/alternative; boundary="=====================_1089152218==_.ALT" --=====================_1089152218==_.ALT Content-Type: text/plain; charset="us-ascii"; format=flowed At 17:01 23/10/2006 +0100, Andrew Tettenborn wrote: >Charles Mitchell wrote: >> >>>Dear Charles, >>> >>>I absolutely accept that claims for money paid by mistake and for >>>payment of debts weren't meant to be, and aren't, covered by the 1978 >>>Act. But I'm not sure the claim for knowing receipt can be lumped >>>together with them. As regards mistaken payments and claims in debt it >>>is simply beside the point that the claimant suffered a reduced loss, or >>>no loss at all. Not so, I suggest, with knowing receipt. Suppose in >>>Target Holdings v Redferns [1996] AC 421 the money wrongly paid away by >>>the solicitors had passed through the hands of some party X, and X >>>(having paid it away) had been sued for knowing receipt. It seems >>>self-evident that if the solicitors could pray in aid the fact that the >>>claimants' loss had not been caused by their paying the money to X, X >>>must be allowed to say the same about his receiving it from them. >>> >>>If so, then whatever noises people may make about restitution, I think >>>that in this connection we're talking about liability for damage of the >>>kind the 1978 Act was meant to address. >>> >>> >>>Best wishes >>> >>>Andrew >> >> >>Dear Andrew >> >>I'm afraid I have some problems with this. For the reasons set out in >>Hayton & Marshall at 707-711 (following Lord Millett and Steven Elliott) >>Lord B-W made a false move when he dragged causation into Target as the >>claim made against the trustee was not wrong-based. But even if that >>were not so, I still wouldn't agree that it is 'self-evident' that a >>knowing recipient should escape liability because the trustee who has >>paid him can rely on a causation argument to escape his own liability to >>the beneficiaries. One might as well say that the recipient of a >>mistaken payment should not have to repay the money because a solicitor >>who carelessly advised the mistaken payor to pay the money is not liable >>in negligence because the payor would have paid the money >>anyway. Whether or not the solicitor's negligence causes the payor's >>loss, the payor is still out of pocket, and the recipient correspondingly >>enriched, as a result of the payor's mistake. The recipient must repay >>regardless of the solicitor's position. Why is this not also true of the KR? >> >>Best wishes >>Charles >> >Dear Charles, > >You make 2 beguiling points: > >(a) The correctness / desirability of the Target solution. On this I'm >afraid I just differ with Hayton & Marshall: despite some rather confused >C19 dicta, a claim against a defendant trustee that she make good the >claimant for a sum she no longer has in her hands but ought to have seems >to me to bear all the hallmarks of a claim for a wrong. In my view we >should recognise this fact. > >(b) The equiparation of the KR and the recipient of a mistaken payment. >This depends on the correctness of the assertion that the KR's liability >depends (or ought to depend) on UE. A lot of people regard this as >axiomatic: I don't. We have two liabilities in the English law of trusts: >that of the non-BFP defendant who still has the trust property, and that >of the defendant who once had it but doesn't have it any more, otherwise >known as the KR. My own view is that the most natural way of looking at >the latter's liability is wrong-based. It seems to me perverse to take a >liability specifically aimed at a defendant who no longer has an asset, >say it's UE-based and then start arguing how far she should be allowed to >pray in aid the fact that she's got rid of it. >I suspect any European lawyer from outside the British Isles would regard >this as a sensible approach, and for once I think they'd be right. > > >Best wishes > >Andrew Dear Andrew I think we've arrived at the point where we'll have to agree to disagree! On (a) I understand where you're coming from, and you have Andy Burrows and Rob Chambers on your side, but in my view your position is historically inaccurate (as I explain in forthcoming CLP). On (b) it's not clear to me why you think a defendant who still has the money wouldn't owe a personal liability as a knowing recipient as well as a proprietary liability in respect of the money - i.e. your characterization of liability for knowing receipt as a liability which is 'specifically aimed at a defendant who no longer has an asset' strikes me as peculiar. Incidentally, while we're on the subject, you may be interested to read the HCA transcripts relating to the appeal in Say-Dee, which suggest a certain keenness on the part of Gummow and Heydon JJ to disseminate their own (Tettenbornian?) views on the point, notwithstanding counsel's difficulties in pulling the grounds of appeal together: http://www.austlii.edu.au//cgi- bin/disp.pl/au/other/HCATrans/2006/425.html and http://www.austlii.edu.au//cgi- bin/disp.pl/au/other/HCATrans/2006/517.html Best wishes Charles ____________________________________________________________________ This message was delivered through the Restitution Discussion Group, an international internet LISTSERV devoted to all aspects of the law of unjust enrichment. To subscribe, send "subscribe enrichment" in the body of a message to . To unsubscribe, send "signoff enrichment" to the same address. To make a posting to all group members, send to . The list is run by Lionel Smith of McGill University, . --=====================_1089152218==_.ALT Content-Type: text/html; charset="iso-8859-1" Content-Transfer-Encoding: quoted-printable At 17:01 23/10/2006 +0100, Andrew Tettenborn wrote:
Charles Mitchell wrote:

Dear Charles,

I absolutely accept that claims for money paid by mistake and for payment of debts weren't meant to be, and aren't, covered by the 1978 Act. But I'm not sure the claim for knowing receipt can be lumped together with them. As regards mistaken payments and claims in debt it is simply beside the point that the claimant suffered a reduced loss, or no loss at all. Not so, I suggest, with knowing receipt. Suppose in Target Holdings v Redferns [1996] AC 421 the money wrongly paid away by the solicitors had passed through the hands of some party X, and X (having paid it away) had been sued for knowing receipt. It seems self-evident that if the solicitors could pray in aid the fact that the claimants' loss had not been caused by their paying the money to X, X must be allowed to say the same about his receiving it from them.

If so, then whatever noises people may make about restitution, I think that in this connection we're talking about liability for damage of the kind the 1978 Act was meant to address.


Best wishes

Andrew


Dear Andrew

I'm afraid I have some problems with this.  For the reasons set out in Hayton & Marshall at 707-711 (following Lord Millett and Steven Elliott) Lord B-W made a false move when he dragged causation into Target as the claim made against the trustee was not wrong-based.  But even if that were not so, I still wouldn't agree that it is 'self-evident' that a knowing recipient should escape liability because the trustee who has paid him can rely on a causation argument to escape his own liability to the beneficiaries.  One might as well say that the recipient of a mistaken payment should not have to repay the money because a solicitor who carelessly advised the mistaken payor to pay the money is not liable in negligence because the payor would have paid the money anyway.  Whether or not the solicitor's negligence causes the payor's loss, the payor is still out of pocket, and the recipient correspondingly enriched, as a result of the payor's mistake.  The recipient must repay regardless of the solicitor's position.  Why is this not also true of the KR?

Best wishes
Charles

Dear Charles,

You make 2 beguiling points:

(a) The correctness / desirability of the Target solution. On this I'm afraid I just differ with Hayton & Marshall: despite some rather confused C19 dicta, a claim against a defendant trustee that she make good the claimant for a sum she no longer has in her hands but ought to have seems to me to bear all the hallmarks of a claim for a wrong. In my view we should recognise this fact.

(b) The equiparation of the KR and the recipient of a mistaken payment. This depends on the correctness of the assertion that the KR's liability depends (or ought to depend) on UE. A lot of people regard this as axiomatic: I don't. We have two liabilities in the English law of trusts: that of the non-BFP defendant who still has the trust property, and that of the defendant who once had it but doesn't have it any more, otherwise known as the KR. My own view is that the most natural way of looking at the latter's liability is wrong-based. It seems to me perverse to take a liability specifically aimed at a defendant who no longer has an asset, say it's UE-based and then start arguing how far she should be allowed to pray in aid the fact that she's got rid of it. 
I suspect any European lawyer from outside the British Isles would regard this as a sensible approach, and for once I think they'd be right.


Best wishes

Andrew

Dear Andrew

I think we've arrived at the point where we'll have to agree to disagree!  On (a) I understand where you're coming from, and you have Andy Burrows and Rob Chambers on your side, but in my view your position is historically inaccurate (as I explain in forthcoming CLP).  On (b) it's not clear to me why you think a defendant who still has the money wouldn't owe a personal liability as a knowing recipient as well as a proprietary liability in respect of the money - i.e. your characterization of liability for knowing receipt as a liability which is 'specifically aimed at a defendant who no longer has an asset' strikes me as peculiar.

Incidentally, while we're on the subject, you may be interested to read the HCA transcripts relating to the appeal in Say-Dee, which suggest a certain keenness on the part of Gummow and Heydon JJ to disseminate their own (Tettenbornian?) views on the point, notwithstanding counsel's difficulties in pulling the grounds of appeal together: http://www.austlii.edu.au//cgi- bin/disp.pl/au/ot= her/HCATrans/2006/425.html and http://www.austlii.edu.au//cgi- bin/disp.pl/au/other/HCAT= rans/2006/517.html

Best wishes
Charles ____________________________________________________________________ This message was delivered through the Restitution Discussion Group, an international internet LISTSERV devoted to all aspects of the law of unjust enrichment. To subscribe, send "subscribe enrichment" in the body of a message to <listserv@lists.mcgill.ca>. To unsubscribe, send "signoff enrichment" to the same address. To make a posting to all group members, send to <enrichment@lists.mcgill.ca>. The list is run by Lionel Smith of McGill University, <lionel.smith@mcgill.ca>. --=====================_1089152218==_.ALT-- ======================================================================= == Date: Tue, 24 Oct 2006 14:38:07 +0800 Reply-To: Chris Pearce Sender: Enrichment - Restitution & Unjust Enrichment Legal Issues From: Chris Pearce Subject: A mistaken payment MIME-Version: 1.0 Content-Type: multipart/alternative; boundary="----=_NextPart_000_0034_01C6F77A.05A6DC10" This is a multi-part message in MIME format. ------=_NextPart_000_0034_01C6F77A.05A6DC10 Content-Type: text/plain; charset="iso-8859-1" Content-Transfer-Encoding: quoted-printable RDG members may be interested in some recent happenings at the = University of Western Australia. A fellow student received the Peter Birks Prize for the top mark in the = unit 'Unjust Enrichment and Restitution'. The award included a small = amount of prize money. I've copy and pasted (with his permission) an = email he received a while ago from the University Administration. ---------------------------- From: Harvey Von Bergheim Sent: 26 June 2006 14:56 To: Andrew Nicol Subject: PETER BIRKS PRIZE Dear Andrew, It has been brought to my attention that we have paid you twice for the Peter Birks Prize, can you please return email me or call me. It would be most appreciated. Regards Harvey ---------------------------- Oh the irony. Kind regards, Chris Pearce ____________________________________________________________________ This message was delivered through the Restitution Discussion Group, an international internet LISTSERV devoted to all aspects of the law of unjust enrichment. To subscribe, send "subscribe enrichment" in the body of a message to . To unsubscribe, send "signoff enrichment" to the same address. To make a posting to all group members, send to . The list is run by Lionel Smith of McGill University, . ------=_NextPart_000_0034_01C6F77A.05A6DC10 Content-Type: text/html; charset="iso-8859-1" Content-Transfer-Encoding: quoted-printable
RDG members may be interested in some = recent=20 happenings at the University of Western Australia.
 
A fellow student received the Peter = Birks Prize for=20 the top mark in the unit 'Unjust Enrichment and Restitution'.  The = award=20 included a small amount of prize money.  I've copy and pasted (with = his=20 permission) an email he received a while ago from the University=20 Administration.
 
----------------------------
From: Harvey Von Bergheim
Sent: 26 June 2006 14:56
To: Andrew Nicol
Subject: PETER = BIRKS=20 PRIZE
 
Dear Andrew,

It has been brought to my attention that we = have paid=20 you twice for the
Peter Birks Prize, can you please return email me = or call=20 me.

It would be most = appreciated.

Regards

Harvey
----------------------------
 
Oh the irony.
 
Kind regards,
 
Chris Pearce
____________________________________________________________________ This message was delivered through the Restitution Discussion Group, an international internet LISTSERV devoted to all aspects of the law of unjust enrichment. To subscribe, send "subscribe enrichment" in the body of a message to <listserv@lists.mcgill.ca>. To unsubscribe, send "signoff enrichment" to the same address. To make a posting to all group members, send to <enrichment@lists.mcgill.ca>. The list is run by Lionel Smith of McGill University, <lionel.smith@mcgill.ca>. ------=_NextPart_000_0034_01C6F77A.05A6DC10-- ======================================================================= == Date: Tue, 24 Oct 2006 15:45:57 +0100 Reply-To: Charles Mitchell Sender: Enrichment - Restitution & Unjust Enrichment Legal Issues From: Charles Mitchell Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii"; format=flowed Judgment in DMG is due tomorrow: http://www.parliament.uk/documents/upload/JudicialSittingsNWP.pdf. Hold onto your hats! Charles Professor Charles Mitchell School of Law King's College London Strand London WC2R 2LS tel: 020 7848 2290 fax: 020 7848 2465 ____________________________________________________________________ This message was delivered through the Restitution Discussion Group, an international internet LISTSERV devoted to all aspects of the law of unjust enrichment. To subscribe, send "subscribe enrichment" in the body of a message to . To unsubscribe, send "signoff enrichment" to the same address. To make a posting to all group members, send to . The list is run by Lionel Smith of McGill University, . ======================================================================= == Date: Tue, 24 Oct 2006 16:53:26 +0100 Reply-To: Charles Mitchell Sender: Enrichment - Restitution & Unjust Enrichment Legal Issues From: Charles Mitchell Comments: To: Jason Neyers In-Reply-To: Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii"; format=flowed Hi Jason The claim is to recover money paid as tax which turned out not to have been due. D said that C was out of time. C said no because it paid by mistake and so could rely on a special limitation rule for mistaken payers. CA held that limitation rule didn't apply because C not allowed to rely on mistake and could only rely on Woolwich as ground for recovery. So potentially there are 3 issues: (1) does limitation rule apply only where C relying on mistake as his ground of recovery, or is it available whatever ground of recovery is relied on, provided that mistake present on facts - this depends on wording of limitation statute; (2) are claimants restricted to Woolwich as their ground of recovery where it is available on facts, or should they be allowed to rely on some alternative ground which is also available, e.g. mistake or duress - this looks like a question that can only be answered by proceeding from first principles but in CA Jonathan Parker LJ weirdly treated it as an issue that fell to be determined by construing Lord Goff's speeches in Woolwich and KB v Lincoln, in neither of which was the question expressly in point - his decision reads like one of those exam scripts where the candidate writes out everything he can remember in the hope that some of it must be relevant; (3) does the English law of UE require claimants to establish a positive ground for restitution, or does it require them to establish an absence of legal ground for the transfer to D - HL might conceivably give us a ruling on this question; but on the other hand it might say nothing about it all and leave us to guess what it thinks from its treatment of (1) and (2); then again, their Lordships may all say different things while simultaneously agreeing with each other ... no, relax - that could never happen. Best wishes Charles At 11:14 24/10/2006 -0400, you wrote: >What is at issue in DMG again? > >----- Original Message ----- >From: Charles Mitchell >Date: Tuesday, October 24, 2006 11:10 am >Subject: [RDG] >To: ENRICHMENT@LISTS.MCGILL.CA > > > Judgment in DMG is due tomorrow: > > http://www.parliament.uk/documents/upload/JudicialSittingsNWP.pdf. Hold > > onto your hats! > > > > Charles > > > > > > Professor Charles Mitchell > > School of Law > > King's College London > > Strand > > London WC2R 2LS > > > > tel: 020 7848 2290 > > fax: 020 7848 2465 > > > > ____________________________________________________________________ > > This message was delivered through the Restitution > > Discussion Group, > > an international internet LISTSERV devoted to all aspects > > of the law > > of unjust enrichment. To subscribe, send "subscribe > > enrichment" in > > the body of a message to . To > > unsubscribe, send "signoff enrichment" to the same address. > > To make a posting to > > all group members, send to > > . The list is > > run by Lionel Smith of McGill University, > > . > > >-- >Jason Neyers >January Term Director >Associate Professor of Law >Faculty of Law >University of Western Ontario >N6A 3K7 >(519) 661-2111 x. 88435 ____________________________________________________________________ This message was delivered through the Restitution Discussion Group, an international internet LISTSERV devoted to all aspects of the law of unjust enrichment. To subscribe, send "subscribe enrichment" in the body of a message to . To unsubscribe, send "signoff enrichment" to the same address. To make a posting to all group members, send to . The list is run by Lionel Smith of McGill University, . ======================================================================= == Date: Wed, 25 Oct 2006 10:12:04 +1000 Reply-To: Simone Degeling Sender: Enrichment - Restitution & Unjust Enrichment Legal Issues From: Simone Degeling Subject: Journal of Equity Comments: cc: obligations@uwo.ca MIME-Version: 1.0 Content-Type: multipart/mixed; boundary="---- _=_NextPart_001_01C6F7CA.3396A8B4" This is a multi-part message in MIME format. ------_=_NextPart_001_01C6F7CA.3396A8B4 Content-Type: multipart/alternative; boundary="----_=_NextPart_002_01C6F7CA.3396A8B4" ------_=_NextPart_002_01C6F7CA.3396A8B4 Content-Type: text/plain; charset="us-ascii" Content-Transfer-Encoding: quoted-printable Apologies for cross posting. =20 List members might be interested in a new journal published by Butterworths/Lexis Nexis entitled the Journal of Equity. The General Editor is Chris Rossiter and Associate Editors are Simone Degeling and Brendan Edgeworth. The Journal was recently launched by the Hon Murray Gleeson, Chief Justice of the High Court of Australia and the first issue has been published with contributions from Mark Leeming, Richard Nolan, Peter Radan, P G Turner and James Edelman. =20 =20 The journal would welcome contributions from scholars dealing with equity and topics that are related to or have implications for current themes in equity. Analytical, theoretical and empirical approaches are welcome, as are contributions detailing and analysing recent developments or dealing with issues of policy and law reform. =20 =20 Further information about the journal is attached. =20 Best wishes Simone Degeling This email and any attachment(s) transmitted with it are intended solely for the use of the addressee(s) and may contain information that is confidential or subject to legal privilege. If you receive this email in error, please disregard the contents of the email and attachment(s), delete them and notify the sender immediately. Please note that any copying, distribution or use of this email is prohibited. Any views expressed in this message are those of the individual sender, except where the sender expressly, and with authority, states them to be the view of The University of New South Wales. Before opening any attachments, please check for viruses. UNSW ABN 57 195 873 179. CRICOS Provider No: 00098G =20 =20 ____________________________________________________________________ This message was delivered through the Restitution Discussion Group, an international internet LISTSERV devoted to all aspects of the law of unjust enrichment. To subscribe, send "subscribe enrichment" in the body of a message to . To unsubscribe, send "signoff enrichment" to the same address. To make a posting to all group members, send to . The list is run by Lionel Smith of McGill University, . ------_=_NextPart_002_01C6F7CA.3396A8B4 Content-Type: text/html; charset="us-ascii" Content-Transfer-Encoding: quoted-printable

Apologies for cross = posting.

 

List members might be interested in a new = journal published by Butterworths/Lexis Nexis entitled the Journal of Equity. The General Editor is Chris = Rossiter and Associate Editors are Simone = Degeling and Brendan Edgeworth.  The Journal was recently launched by the = Hon Murray Gleeson, Chief Justice of the High Court of Australia and the = first issue has been published with contributions from Mark Leeming, Richard = Nolan, Peter Radan, P G Turner and James Edelman.  =

 

The journal would welcome contributions from = scholars dealing with equity and topics that are related to or have implications = for current themes in equity.  Analytical, theoretical and empirical approaches are welcome, as are contributions detailing and analysing = recent developments or dealing with issues of policy and law reform.  =

 

Further information about the journal is = attached.

 

Best wishes

Simone Degeling


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MDAgbg0KMDAwMDA3MTg2NiAwMDAwMCBuDQowMDAwMDcxOTQyIDAwMDAwIG4NCjAwMDAwNzI wMTMg MDAwMDAgbg0KMDAwMDA3NTU1MCAwMDAwMCBuDQp0cmFpbGVyDQo8PC9TaXplIDM2Pj4NCnN 0YXJ0 eHJlZg0KMTE2DQolJUVPRg0K ------_=_NextPart_001_01C6F7CA.3396A8B4-- ======================================================================= == Date: Wed, 25 Oct 2006 10:46:29 +0100 Reply-To: Charles Mitchell Sender: Enrichment - Restitution & Unjust Enrichment Legal Issues From: Charles Mitchell Subject: DMG Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii"; format=flowed Judgment has been released: http://www.publications.parliament.uk/pa/ld/ldjudgmt.htm There is much of interest. Perhaps unsurprisingly the HL rejects the CA's view that you cannot rely on mistake where Woolwich is available on facts - though it's a pity that Rebecca Williams' arguments supporting the CA did not get more of an airing: (2005) 16 KCLJ 194. The limitation rule for mistaken payors applies whether or not mistake is the cause of action (obiter in light of previous finding, I think). Lord Scott dissents on basis that even if DMG made a mistake the money was still due, drawing on Rob Stevens (2005) 5 OUCLJ 141. And the answer to the big question is ... >at any rate for the moment ... that unlike civilian systems, English law >has no general principle that to retain money paid without any legal basis >(such as debt, gift, compromise, etc) is unjust enrichment. per Lord Hoffmann at [21]. He and Lord Walker both acknowledge that it is an open question whether English law might develop in this direction the future, and at [158] Lord Walker expresses enthusiasm for PB's pyramid. But no decision on the point necessary to resolve this case - which perhaps raises the question of what a set of facts would look like where a decision on the point is going to be necessary. PB would have replied 'read Sandwell and Guinness Mahon'! Charles Professor Charles Mitchell School of Law King's College London Strand London WC2R 2LS tel: 020 7848 2290 fax: 020 7848 2465 ____________________________________________________________________ This message was delivered through the Restitution Discussion Group, an international internet LISTSERV devoted to all aspects of the law of unjust enrichment. To subscribe, send "subscribe enrichment" in the body of a message to . To unsubscribe, send "signoff enrichment" to the same address. To make a posting to all group members, send to . The list is run by Lionel Smith of McGill University, . ======================================================================= == Date: Wed, 25 Oct 2006 15:43:57 +0100 Reply-To: hectorm@staffmail.ed.ac.uk Sender: Enrichment - Restitution & Unjust Enrichment Legal Issues From: Hector MacQueen Subject: DMG MIME-Version: 1.0 Content-Type: multipart/mixed; boundary="----=_NextPart_000_0631_01C6F84C.6768EB50" This is a multi-part message in MIME format. ------=_NextPart_000_0631_01C6F84C.6768EB50 Content-Type: text/plain; charset="us-ascii" Content-Transfer-Encoding: 7bit Scots enrichment lawyers pleased to see the following in this case, not from Lord Hope, but from Lord Walker of Gestingthorpe - "158. Nevertheless I would add that my tentative inclination is to welcome any tendency of the English law of unjust enrichment to align itself more closely with Scottish law, and so to civilian roots." Hector ************************ Hector L MacQueen Professor of Private Law Director, AHRC Research Centre for Studies in Intellectual Property and Technology Law University of Edinburgh Old College South Bridge Edinburgh EH8 9YL UK Tel (UK)-(0)131-650-2060 Fax (UK)-(0)131-650-6317 Email: hector.macqueen@ed.ac.uk Web: http://www.law.ed.ac.uk/ Distance Learning at the AHRC Centre http://www.law.ed.ac.uk/ahrb/distancelearning ************************ ____________________________________________________________________ This message was delivered through the Restitution Discussion Group, an international internet LISTSERV devoted to all aspects of the law of unjust enrichment. To subscribe, send "subscribe enrichment" in the body of a message to . To unsubscribe, send "signoff enrichment" to the same address. To make a posting to all group members, send to . The list is run by Lionel Smith of McGill University, . ------=_NextPart_000_0631_01C6F84C.6768EB50 Content-Type: text/x-vcard; name="MACQUEEN Hector.vcf" Content-Transfer-Encoding: 7bit Content-Disposition: attachment; filename="MACQUEEN Hector.vcf" BEGIN:VCARD VERSION:2.1 N:MacQueen;Hector FN:MACQUEEN Hector ORG:The University of Edinburgh;Edinburgh Law School TITLE:PROFESSOR ADR;WORK:;Edinburgh Law School LABEL;WORK:Edinburgh Law School EMAIL;PREF;INTERNET:hectorm@uun.ed.ac.uk REV:20050407T142014Z END:VCARD ------=_NextPart_000_0631_01C6F84C.6768EB50-- ======================================================================= == Date: Wed, 25 Oct 2006 17:30:48 +0100 Reply-To: Robert Stevens Sender: Enrichment - Restitution & Unjust Enrichment Legal Issues From: Robert Stevens Subject: Re: DMG In-Reply-To: <5.1.0.14.2.20061025102513.0134cbc0@pop.kcl.ac.uk> Content-Type: text/plain Content-Disposition: inline Content-Transfer-Encoding: 7bit MIME-Version: 1.0 A first response to DMG. (1) Unsurprisingly, I think Lord Scott, a judge I have always held in the highest esteem, gets it right. That said, I think counsel for the Revenue dropped the ball. Badly. It seems to have been conceded by counsel that a claim for restitution was available but only under Woolwich (see Lord Hoffmann at [7], Lord Walker at [117], [135]). Lord Scott seems to have taken the view he did without the assistance of argument on the point. Normally, it is a good tactic when seeking to resist an appeal to the House of Lords to simply maintain that the Court of Appeal were right for the reasons they gave. However, in this case the arguments for an 'exclusive regime' in relation to ultra vires tax demands were so hopeless, and dependent upon a strained reading of the speeches of Lord Goff which the House of Lords were not bound by, that to seek to defend the result in the Court of Appeal based upon the reasons they gave was a serious mistake. Unsurprisingly, the Revenue went down 5-0 on this point. Only Lord Hoffmann in the majority in what he describes as a footnote, briefly alludes to the point that the money was still payable, although the UK had behaved unlawfully as a matter of Community law. He agrees with the Court of Appeal, rejecting Park J's view, that there was no liability to pay, but gives no substantive reasons [32]. The Scot in the court, Lord Hope, very disappointingly agrees with Park J's interpretation of the legislation at [62], concluding that there was liability to pay but that this didn't matter as there was a causative mistake. The latter view cannot be right. (2) Lord Walker seems to think that neither the correct interpretation of section 32(1)(c) nor the question of whether the claim was based upon mistake or absence of legal ground arose for resolution. However if we accept, as he seems to do at [146]-[147] that a mistake must be an essential element of the cause of action under section 32(1)(c), it is hard to see how the second question does not arise. In DMG the absence of legal ground, if there was one, was not triggered by the mistake but by the contravention of European Union law. If restitution follows where there is an absence of legal ground, the mistake made was not an essential element of the cause of action and section 32(1)(c) is not triggered. Whilst Lord Walker's toying with Peter's 'Pyramid' at [158] is interesting, I wonder whether it is consistent with the result he reaches. Only if the mistake, at the base of the pyramid, triggers the absence of legal ground higher up is it an essential part of the cause of action (eg a contract of sale where the price has been paid but th subject matter does not exist.) Lord Hoffmann sees the point, I think, but I am puzzling over his answer, at [22] "That does not seem to me inconsistent with the existence of the mistake not being essential to the cause of action but merely one example of a case which falls within a more general principle, just as one could have (say, for the purposes of limitation) a category called "clinical negligence" without implying that it is a cause of action different in nature from other kinds of negligence." He is saying, I think, that mistake need not be an essential part of the cause of action for the purposes of section 32(1)(c), but I am not sure I follow his reasoning as to why not. If anyone can help me out I'd be grateful. (3) On whether there was a mistake the differences between Lords Hoffmann and Hope are those which where ascertainable from KB v Lincoln. Hoffmann is quite explicit in deeming there to be a mistake where the law has changed because of judicial decision ([23]) as he admits, this can be read as supporting the Birks view ([28]) that it is better not to try and square this with the orthodox approach that the transfer is vitiated by any mistake present in the claimant's mind, but rather to accept that the true basis of recovery is absence of legal ground. Lords Hope and Walker seem to me to place more emphasis on finding a real mistake. (4) Lord Brown's point will have to be paid for by some litigant in the future. (5) The shame is that a lot of time and effort has been spent rebutting the argument from 'exclusivity' which deservedly went down 5-0, when counsel's time, and their Lordships lengthy speeches, would more profitably have been spent focusing on other issues. Robert Stevens Barrister Fellow and Tutor in Law Lady Margaret Hall University of Oxford In message <5.1.0.14.2.20061025102513.0134cbc0@pop.kcl.ac.uk> Charles Mitchell writes: > Judgment has been released: > http://www.publications.parliament.uk/pa/ld/ldjudgmt.htm There is much of > interest. Perhaps unsurprisingly the HL rejects the CA's view that you > cannot rely on mistake where Woolwich is available on facts - though it's a > pity that Rebecca Williams' arguments supporting the CA did not get more of > an airing: (2005) 16 KCLJ 194. The limitation rule for mistaken payors > applies whether or not mistake is the cause of action (obiter in light of > previous finding, I think). Lord Scott dissents on basis that even if DMG > made a mistake the money was still due, drawing on Rob Stevens (2005) 5 > OUCLJ 141. And the answer to the big question is ... > > >at any rate for the moment ... that unlike civilian systems, English law > >has no general principle that to retain money paid without any legal basis > >(such as debt, gift, compromise, etc) is unjust enrichment. > > per Lord Hoffmann at [21]. > > He and Lord Walker both acknowledge that it is an open question whether > English law might develop in this direction the future, and at [158] Lord > Walker expresses enthusiasm for PB's pyramid. But no decision on the point > necessary to resolve this case - which perhaps raises the question of what > a set of facts would look like where a decision on the point is going to be > necessary. PB would have replied 'read Sandwell and Guinness Mahon'! > > Charles > > > > Professor Charles Mitchell > School of Law > King's College London > Strand > London WC2R 2LS > > tel: 020 7848 2290 > fax: 020 7848 2465 > > ____________________________________________________________________ > This message was delivered through the Restitution Discussion Group, > an international internet LISTSERV devoted to all aspects of the law > of unjust enrichment. To subscribe, send "subscribe enrichment" in > the body of a message to . To unsubscribe, > send "signoff enrichment" to the same address. To make a posting to > all group members, send to . The list is > run by Lionel Smith of McGill University, . > > ____________________________________________________________________ This message was delivered through the Restitution Discussion Group, an international internet LISTSERV devoted to all aspects of the law of unjust enrichment. To subscribe, send "subscribe enrichment" in the body of a message to . To unsubscribe, send "signoff enrichment" to the same address. To make a posting to all group members, send to . The list is run by Lionel Smith of McGill University, . ======================================================================= == Date: Wed, 25 Oct 2006 09:41:03 -0700 Reply-To: Kenneth R Sender: Enrichment - Restitution & Unjust Enrichment Legal Issues From: Kenneth R Subject: Identification of two French UE cases MIME-Version: 1.0 Content-Type: text/plain; charset=iso-8859-1 Content-Transfer-Encoding: 8bit I wonder if anyone can identify the two French UE cases described -- rather thinly, I must admit -- by the following sets of detail found in my source. Both are post-Boudier, and could date from as late as the 1960s though likely they go back much earlier: 1. A father goes broke without paying the teacher of his children, who shortly afterwards receive a large inheritance. 2. A women who lived many years with a man out of wedlock and helped his business grow prosperous, receives nothing upon his death (or their separation). It's possible the second description just refers to a category of cases, though the language used by my source suggests he is speaking of a particular one. Thanks in advance. K. Rivkin __________________________________________________ Do You Yahoo!? Tired of spam? Yahoo! Mail has the best spam protection around http://mail.yahoo.com ____________________________________________________________________ This message was delivered through the Restitution Discussion Group, an international internet LISTSERV devoted to all aspects of the law of unjust enrichment. To subscribe, send "subscribe enrichment" in the body of a message to . To unsubscribe, send "signoff enrichment" to the same address. To make a posting to all group members, send to . The list is run by Lionel Smith of McGill University, . ======================================================================= == Date: Thu, 26 Oct 2006 16:18:17 +1000 Reply-To: Jonathon Moore Sender: Enrichment - Restitution & Unjust Enrichment Legal Issues From: Jonathon Moore Subject: Re: DMG MIME-Version: 1.0 Content-Type: text/plain; format=flowed; charset="iso-8859-1"; reply-type=original Content-Transfer-Encoding: 7bit This responds to Robert's second point, and in particular para [22] of Lord Hoffman's judgment. Robert said "He is saying, I think, that mistake need not be an essential part of the cause of action for the purposes of section 32(1)(c) ...". In my view, that is precisely what he was saying. Robert went on to query Lord Hoffman's reasoning. I agree that it is difficult to understand, or at least see much force in, the "clinical negligence" example. But the general proposition seems reasonable enough. The specific question in issue was whether a claim under Woolwich met the description of being "for relief from the consequences of mistake". As a matter of construing those words, it seems to me to be is possible to say that at least in some circumstances, of which the present case was an example, both a Woolwich claim, and a claim expressly asserting a right to recover a mistaken payment, are "for relief from the consequences of mistake". Mistake may not be an essential to the Woolwich cause of action, but it still can be seen as fitting that description. Best regards Jonathon ================================ JONATHON MOORE Barrister, Victorian Bar jpmoore@vicbar.com.au Chambers: Room 26, 16th floor Owen Dixon Chambers West Phone: 03 9225 8946 Fax: 03 9225 6221 Mobile: 0401 712 737 Clerk and Mail: C/- Clerk Dever 205 William Street Melbourne, Victoria, 3000 DX 96, Melbourne Clerk's phone: 03 - 9225 7999 ----- Original Message ----- From: "Robert Stevens" To: Sent: Thursday, October 26, 2006 2:30 AM Subject: Re: [RDG] DMG >A first response to DMG. > > (1) Unsurprisingly, I think Lord Scott, a judge I have always held in the > highest esteem, gets it right. > > That said, I think counsel for the Revenue dropped the ball. Badly. It > seems to have been conceded by counsel that a claim for restitution was > available but only under Woolwich (see Lord Hoffmann at [7], Lord Walker > at [117], [135]). Lord Scott seems to have taken the view he did without > the assistance of argument on the point. > > Normally, it is a good tactic when seeking to resist an appeal to the > House of Lords to simply maintain that the Court of Appeal were right for > the reasons they gave. However, in this case the arguments for an > 'exclusive regime' in relation to ultra vires tax demands were so > hopeless, and dependent upon a strained reading of the speeches of Lord > Goff which the House of Lords were not bound by, that to seek to defend > the result in the Court of Appeal based upon the reasons they gave was a > serious mistake. Unsurprisingly, the Revenue went down 5-0 on this point. > > Only Lord Hoffmann in the majority in what he describes as a footnote, > briefly alludes to the point that the money was still payable, although > the UK had behaved unlawfully as a matter of Community law. He agrees with > the Court of Appeal, rejecting Park J's view, that there was no liability > to pay, but gives no substantive reasons [32]. The Scot in the court, Lord > Hope, very disappointingly agrees with Park J's interpretation of the > legislation at [62], concluding that there was liability to pay but that > this didn't matter as there was a causative mistake. The latter view > cannot be right. > > (2) Lord Walker seems to think that neither the correct interpretation of > section 32(1)(c) nor the question of whether the claim was based upon > mistake or absence of legal ground arose for resolution. However if we > accept, as he seems to do at [146]-[147] that a mistake must be an > essential element of the cause of action under section 32(1)(c), it is > hard to see how the second question does not arise. In DMG the absence of > legal ground, if there was one, was not triggered by the mistake but by > the contravention of European Union law. If restitution follows where > there is an absence of legal ground, the mistake made was not an essential > element of the cause of action and section 32(1)(c) is not triggered. > > Whilst Lord Walker's toying with Peter's 'Pyramid' at [158] is > interesting, I wonder whether it is consistent with the result he reaches. > Only if the mistake, at the base of the pyramid, triggers the absence of > legal ground higher up is it an essential part of the cause of action (eg > a contract of sale where the price has been paid but th subject matter > does not exist.) > > Lord Hoffmann sees the point, I think, but I am puzzling over his answer, > at [22] > > "That does not seem to me inconsistent with the existence of the mistake > not being essential to the cause of action but merely one example of a > case which falls within a more general principle, just as one could have > (say, for the purposes of limitation) a category called "clinical > negligence" without implying that it is a cause of action different in > nature from other kinds of negligence." > > He is saying, I think, that mistake need not be an essential part of the > cause of action for the purposes of section 32(1)(c), but I am not sure I > follow his reasoning as to why not. If anyone can help me out I'd be > grateful. > > (3) On whether there was a mistake the differences between Lords Hoffmann > and Hope are those which where ascertainable from KB v Lincoln. Hoffmann > is quite explicit in deeming there to be a mistake where the law has > changed because of judicial decision ([23]) as he admits, this can be read > as supporting the Birks view ([28]) that it is better not to try and > square this with the orthodox approach that the transfer is vitiated by > any mistake present in the claimant's mind, but rather to accept that the > true basis of recovery is absence of legal ground. Lords Hope and Walker > seem to me to place more emphasis on finding a real mistake. > > (4) Lord Brown's point will have to be paid for by some litigant in the > future. > > (5) The shame is that a lot of time and effort has been spent rebutting > the argument from 'exclusivity' which deservedly went down 5-0, when > counsel's time, and their Lordships lengthy speeches, would more > profitably have been spent focusing on other issues. > > Robert Stevens > Barrister > Fellow and Tutor in Law > Lady Margaret Hall > University of Oxford > In message <5.1.0.14.2.20061025102513.0134cbc0@pop.kcl.ac.uk> Charles > Mitchell writes: >> Judgment has been released: >> http://www.publications.parliament.uk/pa/ld/ldjudgmt.htm There is much >> of >> interest. Perhaps unsurprisingly the HL rejects the CA's view that you >> cannot rely on mistake where Woolwich is available on facts - though it's >> a >> pity that Rebecca Williams' arguments supporting the CA did not get more >> of >> an airing: (2005) 16 KCLJ 194. The limitation rule for mistaken payors >> applies whether or not mistake is the cause of action (obiter in light of >> previous finding, I think). Lord Scott dissents on basis that even if DMG >> made a mistake the money was still due, drawing on Rob Stevens (2005) 5 >> OUCLJ 141. And the answer to the big question is ... >> >> >at any rate for the moment ... that unlike civilian systems, English law >> >has no general principle that to retain money paid without any legal >> >basis >> >(such as debt, gift, compromise, etc) is unjust enrichment. >> >> per Lord Hoffmann at [21]. >> >> He and Lord Walker both acknowledge that it is an open question whether >> English law might develop in this direction the future, and at [158] Lord >> Walker expresses enthusiasm for PB's pyramid. But no decision on the >> point >> necessary to resolve this case - which perhaps raises the question of >> what >> a set of facts would look like where a decision on the point is going to >> be >> necessary. PB would have replied 'read Sandwell and Guinness Mahon'! >> >> Charles >> >> >> >> Professor Charles Mitchell >> School of Law >> King's College London >> Strand >> London WC2R 2LS >> >> tel: 020 7848 2290 >> fax: 020 7848 2465 >> >> ____________________________________________________________________ >> This message was delivered through the Restitution Discussion Group, >> an international internet LISTSERV devoted to all aspects of the law >> of unjust enrichment. To subscribe, send "subscribe enrichment" in >> the body of a message to . To unsubscribe, >> send "signoff enrichment" to the same address. To make a posting to >> all group members, send to . The list is >> run by Lionel Smith of McGill University, . >> >> > > ____________________________________________________________________ > This message was delivered through the Restitution Discussion Group, > an international internet LISTSERV devoted to all aspects of the law > of unjust enrichment. To subscribe, send "subscribe enrichment" in > the body of a message to . To unsubscribe, > send "signoff enrichment" to the same address. To make a posting to > all group members, send to . The list is > run by Lionel Smith of McGill University, . > ____________________________________________________________________ This message was delivered through the Restitution Discussion Group, an international internet LISTSERV devoted to all aspects of the law of unjust enrichment. To subscribe, send "subscribe enrichment" in the body of a message to . To unsubscribe, send "signoff enrichment" to the same address. To make a posting to all group members, send to . The list is run by Lionel Smith of McGill University, . ======================================================================= == Date: Thu, 26 Oct 2006 14:27:17 +0100 Reply-To: Charles Mitchell Sender: Enrichment - Restitution & Unjust Enrichment Legal Issues From: Charles Mitchell Subject: Re: DMG In-Reply-To: <20061025163048.1EC9F5A078@webmail218.herald.ox.ac.uk> Mime-Version: 1.0 Content-Type: multipart/alternative; boundary="=====================_1336997406==_.ALT" --=====================_1336997406==_.ALT Content-Type: text/plain; charset="us-ascii"; format=flowed Stimulated by Rob's comments I have a few further thoughts about the case: (1) The "cause of action" issue: does English law recognise a restitutionary claim for tax paid under a mistake of law? I share Rob's view that the CA's treatment of this issue was weak and unconvincing. Jonathan Parker LJ's methodology was very strange. However, it doesn't follow from the fact that the CA did a poor job that no respectable arguments can be marshalled to support the proposition that recovery of ultra vires tax payments should be governed by an 'exclusive regime'. The public character of tax authorities, and the special nature of the relationship between citizen and state, might lead one to conclude that such claims are sufficiently different from claims between private individuals that they should be fenced off and treated differently. Rebecca Williams has developed this line of thought more eloquently and expertly than I can manage, and I'm not sure that I find it completely convincing: it troubles me, for example, that the public/private borderline is so fuzzy that cases would often arise where it was unclear whether or not the claim fell within the scope of an exclusive regime. Without pursuing this any further, though, I would just say that it may not be entirely fair to counsel for the IRC to suggest that they relied solely on the CA's narrow textual approach: at [131]ff Lord Walker indicates that arguments from principle were also made, albeit that he and the others seem to have found these unconvincing. (2) The "mistake" issue: did DMG make the payments of ACT under a mistake of law? (a) Do judicial decisions changing the law retrospectively render payments made in line with the old law mistaken? The HL were obliged to say yes in light of KB v Lincoln. In my view, however, the majority's reasoning in KB was deeply flawed because the reach of legal fictions cannot be determined by taking them at face value and discovering in them an 'inherent logic' which they do not possess. In KB the majority started with the fiction that the effect of a case reversing a previous decision is retrospectively to make the law governing the relationship between the parties different from the law which actually governed their relationship at the time when they entered it. It can be argued that this fiction is defensible because without it, the court could not adjust the parties' relationship in a way that ex hypothesi the court now considers appropriate; moreover, litigants would otherwise have no incentive to press for changes to the law, as they would be unable to take personal advantage of such changes. But these reasons do not necessarily hold good when it asked whether the fiction of retrospective legal change also affects the relationship between other people who were not parties to the case. If the pursuer in Donoghue had had an auntie who paid her money because she felt sorry for her and correctly believed at the time when she made the gift that the pursuer had no claim in tort against the defender, the question whether the auntie should be allowed to recover the money because she should retrospectively be deemed to have made a mistake can be sensibly answered only by starting from first principles: it won't do simply to say 'one fiction fits all' and that the auntie must have been mistaken because retrospective changes to the law must affect everybody if they are going to affect anybody. But if the majority in KB had a better reason than this for its findings on retrospective mistakes then I can't find them; nor can I find anything in DMG which makes me feel better, notwithstanding Lord Hoffmann's attempt to cheer me up at [23] by saying that the mistake in a retrospective mistake case is a 'deemed' mistake. I guessed that! The question is why should the claimant be deemed to have made a mistake? Answer: 'practical considerations of fairness'. Hey ho. (b) Was DMG mistaken in its belief that the money was due? I agree with Rob that this was the IRC's best point and that counsel seems to have blown it. As Lord Scott holds (and as Monica Chowdry and I observed in [2005] RLR 1, at 16-18) DMG was not mistaken in its belief that a taxpayer which failed to make a group income election was liable to pay ACT: its mistake was to think that it was not entitled to make such an election. This mistake led DMG not to make an election, with the inexorable result that the money was due. This suggests that DMG's mistake was neither here nor there and that it shouldn't have been allowed to recover. Otherwise a taxpayer who pays money pursuant to a completely valid tax regime might just as well say 'Oh I didn't realise that if I put my assets offshore I wouldn't have had to pay this tax, so now that my friendly accountant has explained this to me I should be entitled to a rebate because I paid under a mistake'. At first instance Park J recognised the problem at [25] but sought to get round it by holding that DMG 'would have made' an election if it had known that it was entitled to do so, and then asserting that it followed from this that the money wasn't due. This was a non sequitur. In the CA Jonathan Parker LJ mistook the facts when he held at [231] that 'the regime gave rise to no obligation to pay' because it was unlawful the only bit of the statute which was unlawful was the bit which disabled DMG from making an election; DMG's liability to pay MCT in the event that it failed to make an election arose under a statutory section that was not unlawful at all. In the HL Lord Hoffmann agrees with Jonathan Parker LJ at [32] and is wrong for the same reason. He also dismisses Park J's recognition of the problem as 'rather sophisticated', a criticism echoed by Lord Walker at [143] ('over-analytical'). Given the general expertise in tax law which they both undoubtedly possess (especially Lord Walker) I find this language surprising; they would have done better to heed the philosopher's advice endorsed by Lord Hope at [41]: 'Seek simplicity and distrust it.' However, at [62] while Lord Hope correctly rejects Jonathan Parker LJ's analysis, he also agrees with Park J, and is wrong for the same reason: the fact that there was 'an unbroken causative link between the mistake and the payment' is true, but it still doesn't mean that the payment wasn't due (as Lord Scott correctly observes at [89]). So I agree with Rob that much more should have been made of this - but still, I wonder whether there isn't an answer which the majority of the HL might have given in response to Lord Scott - namely that the English courts were required by the ECJ in Metallgesellschaft at [96] to award restitution to parties in DMG's position in order to give full effect to its Article 52 rights, and that this direction mandated a departure from the rule that normally governs restitutionary claims in UE, that they are debarred by the existence of valid statutory rules requiring the claimant to pay the defendant. I'm afraid that my EC law isn't good enough to answer this question, but perhaps there is someone out there who knows the answer: where a statutory tax regime is made up of several interconnected sections, some of which are expressly declared void for incompatibility with the Treaty, but some of which are not, can an English court override the tax authority's right to keep money paid under one of the surviving valid sections on the basis that one of the void sections would otherwise be indirectly effective, contrary to the declaration of incompatibility? (At [82] Lord Scott indicates that the answer is 'no'!) Charles At 17:30 25/10/2006 +0100, Robert Stevens wrote: >A first response to DMG. > >(1) Unsurprisingly, I think Lord Scott, a judge I have always held in the >highest esteem, gets it right. > >That said, I think counsel for the Revenue dropped the ball. Badly. It >seems to have been conceded by counsel that a claim for restitution was >available but only under Woolwich (see Lord Hoffmann at [7], Lord Walker >at [117], [135]). Lord Scott seems to have taken the view he did without >the assistance of argument on the point. > >Normally, it is a good tactic when seeking to resist an appeal to the >House of Lords to simply maintain that the Court of Appeal were right for >the reasons they gave. However, in this case the arguments for an >'exclusive regime' in relation to ultra vires tax demands were so >hopeless, and dependent upon a strained reading of the speeches of Lord >Goff which the House of Lords were not bound by, that to seek to defend >the result in the Court of Appeal based upon the reasons they gave was a >serious mistake. Unsurprisingly, the Revenue went down 5-0 on this point. > >Only Lord Hoffmann in the majority in what he describes as a footnote, >briefly alludes to the point that the money was still payable, although >the UK had behaved unlawfully as a matter of Community law. He agrees with >the Court of Appeal, rejecting Park J's view, that there was no liability >to pay, but gives no substantive reasons [32]. The Scot in the court, Lord >Hope, very disappointingly agrees with Park J's interpretation of the >legislation at [62], concluding that there was liability to pay but that >this didn't matter as there was a causative mistake. The latter view >cannot be right. > >(2) Lord Walker seems to think that neither the correct interpretation of >section 32(1)(c) nor the question of whether the claim was based upon >mistake or absence of legal ground arose for resolution. However if we >accept, as he seems to do at [146]-[147] that a mistake must be an >essential element of the cause of action under section 32(1)(c), it is >hard to see how the second question does not arise. In DMG the absence of >legal ground, if there was one, was not triggered by the mistake but by >the contravention of European Union law. If restitution follows where >there is an absence of legal ground, the mistake made was not an essential >element of the cause of action and section 32(1)(c) is not triggered. > >Whilst Lord Walker's toying with Peter's 'Pyramid' at [158] is >interesting, I wonder whether it is consistent with the result he reaches. >Only if the mistake, at the base of the pyramid, triggers the absence of >legal ground higher up is it an essential part of the cause of action (eg >a contract of sale where the price has been paid but th subject matter >does not exist.) > >Lord Hoffmann sees the point, I think, but I am puzzling over his answer, >at [22] > >"That does not seem to me inconsistent with the existence of the mistake >not being essential to the cause of action but merely one example of a >case which falls within a more general principle, just as one could have >(say, for the purposes of limitation) a category called "clinical >negligence" without implying that it is a cause of action different in >nature from other kinds of negligence." > >He is saying, I think, that mistake need not be an essential part of the >cause of action for the purposes of section 32(1)(c), but I am not sure I >follow his reasoning as to why not. If anyone can help me out I'd be grateful. > >(3) On whether there was a mistake the differences between Lords Hoffmann >and Hope are those which where ascertainable from KB v Lincoln. Hoffmann >is quite explicit in deeming there to be a mistake where the law has >changed because of judicial decision ([23]) as he admits, this can be read >as supporting the Birks view ([28]) that it is better not to try and >square this with the orthodox approach that the transfer is vitiated by >any mistake present in the claimant's mind, but rather to accept that the >true basis of recovery is absence of legal ground. Lords Hope and Walker >seem to me to place more emphasis on finding a real mistake. > >(4) Lord Brown's point will have to be paid for by some litigant in the >future. > >(5) The shame is that a lot of time and effort has been spent rebutting >the argument from 'exclusivity' which deservedly went down 5-0, when >counsel's time, and their Lordships lengthy speeches, would more >profitably have been spent focusing on other issues. > >Robert Stevens >Barrister >Fellow and Tutor in Law >Lady Margaret Hall >University of Oxford Professor Charles Mitchell School of Law King's College London Strand London WC2R 2LS tel: 020 7848 2290 fax: 020 7848 2465 ____________________________________________________________________ This message was delivered through the Restitution Discussion Group, an international internet LISTSERV devoted to all aspects of the law of unjust enrichment. To subscribe, send "subscribe enrichment" in the body of a message to . To unsubscribe, send "signoff enrichment" to the same address. To make a posting to all group members, send to . The list is run by Lionel Smith of McGill University, . --=====================_1336997406==_.ALT Content-Type: text/html; charset="iso-8859-1" Content-Transfer-Encoding: quoted-printable Stimulated by Rob=92s comments I have a few further thoughts about the case:

(1) The "cause of action" issue: does English law recognise a restitutionary claim for tax paid under a mistake of law?

I share Rob=92s view that the CA=92s treatment of this issue was weak and unconvincing.  Jonathan Parker LJ=92s methodology was very strange.  However, it doesn=92t follow from the fact that the CA did a poor job that no respectable arguments can be marshalled to support the proposition that recovery of ultra vires tax payments should be governed by an =91exclusive regime=92.  The public character of tax authorities, and the special nature of the relationship between citizen and state, might lead one to conclude that such claims are sufficiently different from claims between private individuals that they should be fenced off and treated differently.  Rebecca Williams has developed this line of thought more eloquently and expertly than I can manage, and I=92m not sure that I find it completely convincing: it troubles me, for example, that the public/private borderline is so fuzzy that cases would often arise where it was unclear whether or not the claim fell within the scope of an exclusive regime.  Without pursuing this any further, though, I would just say that it may not be entirely fair to counsel for the IRC to suggest that they relied solely on the CA=92s narrow textual approach: at [131]ff Lord Walker indicates that arguments from principle were also made, albeit that he and the others seem to have found these unconvincing.


(2) The "mistake" issue: did DMG make the payments of ACT under a mistake of law?

(a) Do judicial decisions changing the law retrospectively render payments made in line with the old law mistaken? 

The HL were obliged to say yes in light of KB v Lincoln.  In my view, however, the majority=92s reasoning in KB was deeply flawed because the reach of legal fictions cannot be determined by taking them at face value and discovering in them an =91inherent logic=92 which they do not possess.  In KB the majority started with the fiction that the effect of a case reversing a previous decision is retrospectively to make the law governing the relationship between the parties different from the law which actually governed their relationship at the time when they entered it.  It can be argued that this fiction is defensible because without it, the court could not adjust the parties=92 relationship in a way that ex hypothesi the court now considers appropriate; moreover, litigants would otherwise have no incentive to press for changes to the law, as they would be unable to take personal advantage of such changes.  But these reasons do not necessarily hold good when it asked whether the fiction of retrospective legal change also affects the relationship between other people who were not parties to the case.  If the pursuer in Donoghue had had an auntie who paid her money because she felt sorry for her and correctly believed at the time when she made the gift that the pursuer had no claim in tort against the defender, the question whether the auntie should be allowed to recover the money because she should retrospectively be deemed to have made a mistake can be sensibly answered only by starting from first principles: it won=92t do simply to say =91one fiction fits all=92 and that the auntie must have been mistaken because retrospective changes to the law must affect everybody if they are going to affect anybody.  But if the majority in KB had a better reason than this for its findings on retrospective mistakes then I can=92t find them; nor can I find anything in DMG which makes me feel better, notwithstanding Lord Hoffmann=92s attempt to cheer me up at [23] by saying that the mistake in a retrospective mistake case is a 'deemed' mistake.  I guessed that!  The question is why should the claimant be deemed to have made a mistake?  Answer: =91practical considerations of fairness=92.  Hey ho.


(b) Was DMG mistaken in its belief that the money was due?

I agree with Rob that this was the IRC=92s best point and that counsel seems to have blown it.  As Lord Scott holds (and as Monica Chowdry and I observed in [2005] RLR 1, at 16-18) DMG was not mistaken in its belief that a taxpayer which failed to make a group income election was liable to pay ACT: its mistake was to think that it was not entitled to make such an election.  This mistake led DMG not to make an election, with the inexorable result that the money was due.  This suggests that DMG=92s mistake was neither here nor there and that it shouldn=92t have been allowed to recover.  Otherwise a taxpayer who pays money pursuant to a completely valid tax regime might just as well say =91Oh I didn=92t realise that if I put my assets offshore I wouldn=92t h= ave had to pay this tax, so now that my friendly accountant has explained this to me I should be entitled to a rebate because I paid under a mistake=92.

At first instance Park J recognised the problem at [25] but sought to get round it by holding that DMG =91would have made=92 an election if it had known that it was entitled to do so, and then asserting that it followed from this that the money wasn=92t due.  This was a non sequitur.  In the CA Jonathan Parker LJ mistook the facts when he held at [231] that =91the regime gave rise to no obligation to pay=92 because it was unlawful  the only bit of the statute which was unlawful was the bit which disabled DMG from making an election; DMG=92s liability to pay MCT in the event that it failed to make an election arose under a statutory section that was not unlawful at all.   In the HL Lord Hoffmann agrees with Jonathan Parker LJ at [32] and is wrong for the same reason.  He also dismisses Park J=92s recognition of the problem as =91rather sophisticated=92, a criticism echoed by Lord Walker at [143] (=91over-analytical=92).  Given the general expertise in tax law which they both undoubtedly possess (especially Lord Walker) I find this language surprising; they would have done better to heed the philosopher=92s advice endorsed by Lord Hope at [41]: =91Seek simplicity and distrust it.=92  However, at [62] while Lord Hope correctly rejects Jonathan Parker LJ=92s analysis, he also agrees with Park J, and is wrong for the same reason: the fact that there was =91an unbroken causative link between the mistake and the payment=92 is true, but it still doesn=92t mean that the payment wasn=92t due (as Lord Scott correctly observes at [89]).

So I agree with Rob that much more should have been made of this - but still, I wonder whether there isn=92t an answer which the majority of the HL might have given in response to Lord Scott  - namely that the English courts were required by the ECJ in Metallgesellschaft at [96] to award restitution to parties in DMG=92s position in order to give full effect to its Article 52 rights, and that this direction mandated a departure from the rule that normally governs restitutionary claims in UE, that they are debarred by the existence of valid statutory rules requiring the claimant to pay the defendant.  I=92m afraid that my EC law isn=92t good enough to answer this question, but perhaps there is someone out there who knows the answer: where a statutory tax regime is made up of several interconnected sections, some of which are expressly declared void for incompatibility with the Treaty, but some of which are not, can an English court override the tax authority=92s right to keep money paid under one of the surviving valid sections on the basis that one of the void sections would otherwise be indirectly effective, contrary to the declaration of incompatibility?  (At [82] Lord Scott indicates that the answer is =91no=92!)

Charles



At 17:30 25/10/2006 +0100, Robert Stevens wrote:
A first response to DMG.

(1) Unsurprisingly, I think Lord Scott, a judge I have always held in the highest esteem, gets it right.

That said, I think counsel for the Revenue dropped the ball. Badly. It seems to have been conceded by counsel that a claim for restitution was available but only under Woolwich (see Lord Hoffmann at [7], Lord Walker at [117], [135]). Lord Scott seems to have taken the view he did without the assistance of argument on the point.

Normally, it is a good tactic when seeking to resist an appeal to the House of Lords to simply maintain that the Court of Appeal were right for the reasons they gave. However, in this case the arguments for an 'exclusive regime' in relation to ultra vires tax demands were so hopeless, and dependent upon a strained reading of the speeches of Lord Goff which the House of Lords were not bound by, that to seek to defend the result in the Court of Appeal based upon the reasons they gave was a serious mistake. Unsurprisingly, the Revenue went down 5-0 on this point.

Only Lord Hoffmann in the majority in what he describes as a footnote, briefly alludes to the point that the money was still payable, although the UK had behaved unlawfully as a matter of Community law. He agrees with the Court of Appeal, rejecting Park J's view, that there was no liability to pay, but gives no substantive reasons [32]. The Scot in the court, Lord Hope, very disappointingly agrees with Park J's interpretation of the legislation at [62], concluding that there was liability to pay but that this didn't matter as there was a causative mistake. The latter view cannot be right.

(2) Lord Walker seems to think that neither the correct interpretation of section 32(1)(c) nor the question of whether the claim was based upon mistake or absence of legal ground arose for resolution. However if we accept, as he seems to do at [146]-[147] that a mistake must be an essential element of the cause of action under section 32(1)(c), it is hard to see how the second question does not arise. In DMG the absence of legal ground, if there was one, was not triggered by the mistake but by the contravention of European Union law. If restitution follows where there is an absence of legal ground, the mistake made was not an essential element of the cause of action and section 32(1)(c) is not triggered.

Whilst Lord Walker's toying with Peter's 'Pyramid' at [158] is interesting, I wonder whether it is consistent with the result he reaches. Only if the mistake, at the base of the pyramid, triggers the absence of legal ground higher up is it an essential part of the cause of action (eg a contract of sale where the price has been paid but th subject matter does not exist.)

Lord Hoffmann sees the point, I think, but I am puzzling over his answer, at [22]

"That does not seem to me inconsistent with the existence of the mistake not being essential to the cause of action but merely one example of a case which falls within a more general principle, just as one could have (say, for the purposes of limitation) a category called "clinical negligence" without implying that it is a cause of action different in nature from other kinds of=20 negligence."

He is saying, I think, that mistake need not be an essential part of the cause of action for the purposes of section 32(1)(c), but I am not sure I follow his reasoning as to why not. If anyone can help me out I'd be grateful.

(3) On whether there was a mistake the differences between Lords Hoffmann and Hope are those which where ascertainable from KB v Lincoln. Hoffmann is quite explicit in deeming there to be a mistake where the law has changed because of judicial decision ([23]) as he admits, this can be read as supporting the Birks view ([28]) that it is better not to try and square this with the orthodox approach that the transfer is vitiated by any mistake present in the claimant's mind, but rather to accept that the true basis of recovery is absence of legal ground. Lords Hope and Walker seem to me to place more emphasis on finding a real mistake.

(4) Lord Brown's point will have to be paid for by some litigant in the future.

(5) The shame is that a lot of time and effort has been spent rebutting the argument from 'exclusivity' which deservedly went down 5-0, when counsel's time, and their Lordships lengthy speeches, would more profitably have been spent focusing on other issues. 

Robert Stevens
Barrister
Fellow and Tutor in Law
Lady Margaret Hall
University of Oxford


Professor Charles Mitchell
School of Law
King's College London
Strand
London WC2R 2LS

tel: 020 7848 2290
fax: 020 7848 2465 ____________________________________________________________________ This message was delivered through the Restitution Discussion Group, an international internet LISTSERV devoted to all aspects of the law of unjust enrichment. To subscribe, send "subscribe enrichment" in the body of a message to <listserv@lists.mcgill.ca>. To unsubscribe, send "signoff enrichment" to the same address. To make a posting to all group members, send to <enrichment@lists.mcgill.ca>. The list is run by Lionel Smith of McGill University, <lionel.smith@mcgill.ca>. --=====================_1336997406==_.ALT-- ======================================================================= == Date: Thu, 26 Oct 2006 16:32:29 +0100 Reply-To: Robert Stevens Sender: Enrichment - Restitution & Unjust Enrichment Legal Issues From: Robert Stevens Subject: Re: DMG Comments: To: Charles Mitchell In-Reply-To: <5.1.0.14.2.20061026141411.013544a8@pop.kcl.ac.uk> Content-Type: text/plain Content-Disposition: inline Content-Transfer-Encoding: 7bit MIME-Version: 1.0 I wonder whether there isn't an answer which the majority of the HL > might have given in response to Lord Scott - namely that the English > courts were required by the ECJ in Metallgesellschaft at [96] to award > restitution to parties in DMG's position in order to give full effect to > its Article 52 rights, and that this direction mandated a departure from > the rule that normally governs restitutionary claims in UE, that they are > debarred by the existence of valid statutory rules requiring the claimant > to pay the defendant. Para 96 of Metallgesellschaft states: "That resident subsidiaries and their non-resident parent companies should have an effective legal remedy in order to obtain reimbursement or reparation of the financial loss which they have sustained and from which the authorities of the Member State concerned have benefited as a result of the advance payment of tax by the subsidiaries." From that, I don't think that the ECJ thought that the UK would only be compliant if a claim for restitution, as opposed to a claim for compensation for loss based upon a tort, was not available. Indeed, the only reason why the claimant wanted such a claim in this case was in order to rely upon the very generous limitation period applicable to such claims. The Advocat General had thought that the claim was 'more naturally' a claim for restitution but the ECJ do not endorse him in that. Looking at the case again, I think the Revenue lost it at the very early stage of the appeal when the parties agreed the issues for the court to resolve. I think this agreed statement goes in with the parties' agreed statement of facts. It is because most of the members of the court stuck rigidly to the list of issues agreed by the parties that it is quite difficult to work out what some of them thought on the issues which should have been decisive. Lords Hoffmann (unsurprsingly) and Scott can be forgiven on this score. Still, if they had given us all the answers what would we have left to argue about? Robert Stevens ____________________________________________________________________ This message was delivered through the Restitution Discussion Group, an international internet LISTSERV devoted to all aspects of the law of unjust enrichment. To subscribe, send "subscribe enrichment" in the body of a message to . To unsubscribe, send "signoff enrichment" to the same address. To make a posting to all group members, send to . The list is run by Lionel Smith of McGill University, . ======================================================================= == Date: Fri, 27 Oct 2006 10:13:13 +1300 Reply-To: Peter Watts Sender: Enrichment - Restitution & Unjust Enrichment Legal Issues From: Peter Watts Subject: DMG - changing the law Mime-version: 1.0 Content-type: text/plain; charset="US-ASCII" Content-transfer-encoding: 7bit In answer to Charles Mitchell's point 2a): Do judicial decisions changing the law retrospectively render payments made in line with the old law mistaken?: It amazes me how readily modern appellate judges think they change the law. Given that their primary function is to APPLY the law not change it, one would expect that they would hesitate long before exercising the constitutional power, if they have it all, to change the law. But not so the modern judiciary who seem to have swallowed Lord Reid's non sequitur (indeed fairytale) that the judge's power to contribute to making law includes the power to unsettle it where it is settled. Hence, I would object strongly to both parts of Lord Hoffmann's statement at para 23: "This seems to me, with respect, to muddle two different questions. One is whether judges change the law or merely declare what it has always been. The answer to this question is clear enough. To say that they never change the law is a fiction and to base any practical decision upon such a fiction would indeed be abstract juridical correctitude. But the other question is whether a judicial decision changes the law retrospectively and here the answer is equally clear." Lord Hoffmann simply elides the notion of making the law with changing it. The truth is that very little law is completely settled (single decisions even of top appellate courts cannot be treated as finally settling a point in a common law system), which gives the judges a lot of leeway, but it is no fiction to say that where they overturn a common understanding of the law they are nonetheless only declaring the law as it always has been, as they now see it. This is particularly true where the question of law involves a question of construction, whether of statute, contract or other instrument, as in DMG. I assume that the ECJ had no jurisdiction to alter the treaties and other laws that the UK had entered into with Europe without the UK's consent, so in ruling that the UK had unlawfully discriminated against Europeans it must have intended to rule that that was what the UK had always undertaken not to do. It may be that there is some ultimate appellate power to alter the law in relation to issues of the common law, where on any constitutional view the law was settled (say a continuous line of appellate judgments over several generations of the judiciary), but it is dangerous territory into which to enter. It is a good discipline for a judge who wishes not to follow a line of earlier cases to have first to apply this test: "The earlier judges were always wrong, even if I can understand the pressures which caused them to fall into error". If the answer to the test is "no", then the judge should think long and hard about why it is necessary to alter the law. Many current judges seem blithely to push directly through the second door. Peter. ____________________________________________________________________ This message was delivered through the Restitution Discussion Group, an international internet LISTSERV devoted to all aspects of the law of unjust enrichment. To subscribe, send "subscribe enrichment" in the body of a message to . To unsubscribe, send "signoff enrichment" to the same address. To make a posting to all group members, send to . The list is run by Lionel Smith of McGill University, . ======================================================================= == Date: Mon, 30 Oct 2006 11:01:00 -0500 Reply-To: Jason Neyers Sender: Enrichment - Restitution & Unjust Enrichment Legal Issues From: Jason Neyers Subject: Re: DMG Comments: To: Charles Mitchell In-Reply-To: <5.1.0.14.2.20061026141411.013544a8@pop.kcl.ac.uk> MIME-version: 1.0 Content-type: multipart/alternative; boundary="Boundary_(ID_IBZHz/0FI1LMBZpTDXga0A)" This is a multi-part message in MIME format. --Boundary_(ID_IBZHz/0FI1LMBZpTDXga0A) Content-type: text/plain; charset=us-ascii; format=flowed Content-transfer-encoding: 7BIT Dear Charles: The difficulties you have with the mistake analysis show why absence of basis is the simplest most coherent view of unjust enrichment. Although the province of UE would be smaller under this view, what was covered would hold together better. Cheers, Charles Mitchell wrote: > Stimulated by Rob's comments I have a few further thoughts about the case: > > (1) The "cause of action" issue: does English law recognise a > restitutionary claim for tax paid under a mistake of law? > > I share Rob's view that the CA's treatment of this issue was weak and > unconvincing. Jonathan Parker LJ's methodology was very strange. > However, it doesn't follow from the fact that the CA did a poor job > that no respectable arguments can be marshalled to support the > proposition that recovery of ultra vires tax payments should be > governed by an 'exclusive regime'. The public character of tax > authorities, and the special nature of the relationship between > citizen and state, might lead one to conclude that such claims are > sufficiently different from claims between private individuals that > they should be fenced off and treated differently. Rebecca Williams > has developed this line of thought more eloquently and expertly than I > can manage, and I'm not sure that I find it completely convincing: it > troubles me, for example, that the public/private borderline is so > fuzzy that cases would often arise where it was unclear whether or not > the claim fell within the scope of an exclusive regime. Without > pursuing this any further, though, I would just say that it may not be > entirely fair to counsel for the IRC to suggest that they relied > solely on the CA's narrow textual approach: at [131]ff Lord Walker > indicates that arguments from principle were also made, albeit that he > and the others seem to have found these unconvincing. > > > (2) The "mistake" issue: did DMG make the payments of ACT under a > mistake of law? > > (a) Do judicial decisions changing the law retrospectively render > payments made in line with the old law mistaken? > > The HL were obliged to say yes in light of KB v Lincoln. In my view, > however, the majority's reasoning in KB was deeply flawed because the > reach of legal fictions cannot be determined by taking them at face > value and discovering in them an 'inherent logic' which they do not > possess. In KB the majority started with the fiction that the effect > of a case reversing a previous decision is retrospectively to make the > law governing the relationship between the parties different from the > law which actually governed their relationship at the time when they > entered it. It can be argued that this fiction is defensible because > without it, the court could not adjust the parties' relationship in a > way that ex hypothesi the court now considers appropriate; moreover, > litigants would otherwise have no incentive to press for changes to > the law, as they would be unable to take personal advantage of such > changes. But these reasons do not necessarily hold good when it asked > whether the fiction of retrospective legal change also affects the > relationship between other people who were not parties to the case. > If the pursuer in Donoghue had had an auntie who paid her money > because she felt sorry for her and correctly believed at the time when > she made the gift that the pursuer had no claim in tort against the > defender, the question whether the auntie should be allowed to recover > the money because she should retrospectively be deemed to have made a > mistake can be sensibly answered only by starting from first > principles: it won't do simply to say 'one fiction fits all' and that > the auntie must have been mistaken because retrospective changes to > the law must affect everybody if they are going to affect anybody. > But if the majority in KB had a better reason than this for its > findings on retrospective mistakes then I can't find them; nor can I > find anything in DMG which makes me feel better, notwithstanding Lord > Hoffmann's attempt to cheer me up at [23] by saying that the mistake > in a retrospective mistake case is a 'deemed' mistake. I guessed > that! The question is why should the claimant be deemed to have made > a mistake? Answer: 'practical considerations of fairness'. Hey ho. > > > (b) Was DMG mistaken in its belief that the money was due? > > I agree with Rob that this was the IRC's best point and that counsel > seems to have blown it. As Lord Scott holds (and as Monica Chowdry > and I observed in [2005] RLR 1, at 16-18) DMG was not mistaken in its > belief that a taxpayer which failed to make a group income election > was liable to pay ACT: its mistake was to think that it was not > entitled to make such an election. This mistake led DMG not to make > an election, with the inexorable result that the money was due. This > suggests that DMG's mistake was neither here nor there and that it > shouldn't have been allowed to recover. Otherwise a taxpayer who pays > money pursuant to a completely valid tax regime might just as well say > 'Oh I didn't realise that if I put my assets offshore I wouldn't have > had to pay this tax, so now that my friendly accountant has explained > this to me I should be entitled to a rebate because I paid under a > mistake'. > > At first instance Park J recognised the problem at [25] but sought to > get round it by holding that DMG 'would have made' an election if it > had known that it was entitled to do so, and then asserting that it > followed from this that the money wasn't due. This was a non > sequitur. In the CA Jonathan Parker LJ mistook the facts when he held > at [231] that 'the regime gave rise to no obligation to pay' because > it was unlawful the only bit of the statute which was unlawful was > the bit which disabled DMG from making an election; DMG's liability to > pay MCT in the event that it failed to make an election arose under a > statutory section that was not unlawful at all. In the HL Lord > Hoffmann agrees with Jonathan Parker LJ at [32] and is wrong for the > same reason. He also dismisses Park J's recognition of the problem as > 'rather sophisticated', a criticism echoed by Lord Walker at [143] > ('over-analytical'). Given the general expertise in tax law which > they both undoubtedly possess (especially Lord Walker) I find this > language surprising; they would have done better to heed the > philosopher's advice endorsed by Lord Hope at [41]: 'Seek simplicity > and distrust it.' However, at [62] while Lord Hope correctly rejects > Jonathan Parker LJ's analysis, he also agrees with Park J, and is > wrong for the same reason: the fact that there was 'an unbroken > causative link between the mistake and the payment' is true, but it > still doesn't mean that the payment wasn't due (as Lord Scott > correctly observes at [89]). > > So I agree with Rob that much more should have been made of this - but > still, I wonder whether there isn't an answer which the majority of > the HL might have given in response to Lord Scott - namely that the > English courts were required by the ECJ in Metallgesellschaft at [96] > to award restitution to parties in DMG's position in order to give > full effect to its Article 52 rights, and that this direction mandated > a departure from the rule that normally governs restitutionary claims > in UE, that they are debarred by the existence of valid statutory > rules requiring the claimant to pay the defendant. I'm afraid that my > EC law isn't good enough to answer this question, but perhaps there is > someone out there who knows the answer: where a statutory tax regime > is made up of several interconnected sections, some of which are > expressly declared void for incompatibility with the Treaty, but some > of which are not, can an English court override the tax authority's > right to keep money paid under one of the surviving valid sections on > the basis that one of the void sections would otherwise be indirectly > effective, contrary to the declaration of incompatibility? (At [82] > Lord Scott indicates that the answer is 'no'!) > > Charles > > > > At 17:30 25/10/2006 +0100, Robert Stevens wrote: > >> A first response to DMG. >> >> (1) Unsurprisingly, I think Lord Scott, a judge I have always held in >> the highest esteem, gets it right. >> >> That said, I think counsel for the Revenue dropped the ball. Badly. >> It seems to have been conceded by counsel that a claim for >> restitution was available but only under Woolwich (see Lord Hoffmann >> at [7], Lord Walker at [117], [135]). Lord Scott seems to have taken >> the view he did without the assistance of argument on the point. >> >> Normally, it is a good tactic when seeking to resist an appeal to the >> House of Lords to simply maintain that the Court of Appeal were right >> for the reasons they gave. However, in this case the arguments for an >> 'exclusive regime' in relation to ultra vires tax demands were so >> hopeless, and dependent upon a strained reading of the speeches of >> Lord Goff which the House of Lords were not bound by, that to seek to >> defend the result in the Court of Appeal based upon the reasons they >> gave was a serious mistake. Unsurprisingly, the Revenue went down 5- 0 >> on this point. >> >> Only Lord Hoffmann in the majority in what he describes as a >> footnote, briefly alludes to the point that the money was still >> payable, although the UK had behaved unlawfully as a matter of >> Community law. He agrees with the Court of Appeal, rejecting Park J's >> view, that there was no liability to pay, but gives no substantive >> reasons [32]. The Scot in the court, Lord Hope, very disappointingly >> agrees with Park J's interpretation of the legislation at [62], >> concluding that there was liability to pay but that this didn't >> matter as there was a causative mistake. The latter view cannot be right. >> >> (2) Lord Walker seems to think that neither the correct >> interpretation of section 32(1)(c) nor the question of whether the >> claim was based upon mistake or absence of legal ground arose for >> resolution. However if we accept, as he seems to do at [146]-[147] >> that a mistake must be an essential element of the cause of action >> under section 32(1)(c), it is hard to see how the second question >> does not arise. In DMG the absence of legal ground, if there was one, >> was not triggered by the mistake but by the contravention of European >> Union law. If restitution follows where there is an absence of legal >> ground, the mistake made was not an essential element of the cause of >> action and section 32(1)(c) is not triggered. >> >> Whilst Lord Walker's toying with Peter's 'Pyramid' at [158] is >> interesting, I wonder whether it is consistent with the result he >> reaches. Only if the mistake, at the base of the pyramid, triggers >> the absence of legal ground higher up is it an essential part of the >> cause of action (eg a contract of sale where the price has been paid >> but th subject matter does not exist.) >> >> Lord Hoffmann sees the point, I think, but I am puzzling over his >> answer, at [22] >> >> "That does not seem to me inconsistent with the existence of the >> mistake not being essential to the cause of action but merely one >> example of a case which falls within a more general principle, just >> as one could have (say, for the purposes of limitation) a category >> called "clinical negligence" without implying that it is a cause of >> action different in nature from other kinds of negligence." >> >> He is saying, I think, that mistake need not be an essential part of >> the cause of action for the purposes of section 32(1)(c), but I am >> not sure I follow his reasoning as to why not. If anyone can help me >> out I'd be grateful. >> >> (3) On whether there was a mistake the differences between Lords >> Hoffmann and Hope are those which where ascertainable from KB v >> Lincoln. Hoffmann is quite explicit in deeming there to be a mistake >> where the law has changed because of judicial decision ([23]) as he >> admits, this can be read as supporting the Birks view ([28]) that it >> is better not to try and square this with the orthodox approach that >> the transfer is vitiated by any mistake present in the claimant's >> mind, but rather to accept that the true basis of recovery is absence >> of legal ground. Lords Hope and Walker seem to me to place more >> emphasis on finding a real mistake. >> >> (4) Lord Brown's point will have to be paid for by some litigant in >> the future. >> >> (5) The shame is that a lot of time and effort has been spent >> rebutting the argument from 'exclusivity' which deservedly went down >> 5-0, when counsel's time, and their Lordships lengthy speeches, would >> more profitably have been spent focusing on other issues. >> >> Robert Stevens >> Barrister >> Fellow and Tutor in Law >> Lady Margaret Hall >> University of Oxford > > > Professor Charles Mitchell > School of Law > King's College London > Strand > London WC2R 2LS > > tel: 020 7848 2290 > fax: 020 7848 > 2465___________________________________________________________________ _ > This message was delivered through the Restitution Discussion Group, > an international internet LISTSERV devoted to all aspects of the law > of unjust enrichment. To subscribe, send "subscribe enrichment" in the > body of a message to . To unsubscribe, send > "signoff enrichment" to the same address. To make a posting to all > group members, send to . The list is run > by Lionel Smith of McGill University, . > -- Jason Neyers January Term Director Associate Professor of Law Faculty of Law University of Western Ontario N6A 3K7 (519) 661-2111 x. 88435 ____________________________________________________________________ This message was delivered through the Restitution Discussion Group, an international internet LISTSERV devoted to all aspects of the law of unjust enrichment. To subscribe, send "subscribe enrichment" in the body of a message to . To unsubscribe, send "signoff enrichment" to the same address. To make a posting to all group members, send to . The list is run by Lionel Smith of McGill University, . --Boundary_(ID_IBZHz/0FI1LMBZpTDXga0A) Content-type: text/html; charset=us-ascii Content-transfer-encoding: 7BIT Dear Charles:

The difficulties you have with the mistake analysis show why absence of basis is the simplest most coherent view of unjust enrichment.  Although the province of  UE would be smaller under this view, what was covered would hold together better.

Cheers,

Charles Mitchell wrote:

Stimulated by Rob’s comments I have a few further thoughts about the case:

(1) The "cause of action" issue: does English law recognise a restitutionary claim for tax paid under a mistake of law?

I share Rob’s view that the CA’s treatment of this issue was weak and unconvincing.  Jonathan Parker LJ’s methodology was very strange.  However, it doesn’t follow from the fact that the CA did a poor job that no respectable arguments can be marshalled to support the proposition that recovery of ultra vires tax payments should be governed by an ‘exclusive regime’.  The public character of tax authorities, and the special nature of the relationship between citizen and state, might lead one to conclude that such claims are sufficiently different from claims between private individuals that they should be fenced off and treated differently.  Rebecca Williams has developed this line of thought more eloquently and expertly than I can manage, and I’m not sure that I find it completely convincing: it troubles me, for example, that the public/private borderline is so fuzzy that cases would often arise where it was unclear whether or not the claim fell within the scope of an exclusive regime.  Without pursuing this any further, though, I would just say that it may not be entirely fair to counsel for the IRC to suggest that they relied solely on the CA’s narrow textual approach: at [131]ff Lord Walker indicates that arguments from principle were also made, albeit that he and the others seem to have found these unconvincing.


(2) The "mistake" issue: did DMG make the payments of ACT under a mistake of law?

(a) Do judicial decisions changing the law retrospectively render payments made in line with the old law mistaken? 

The HL were obliged to say yes in light of KB v Lincoln.  In my view, however, the majority’s reasoning in KB was deeply flawed because the reach of legal fictions cannot be determined by taking them at face value and discovering in them an ‘inherent logic’ which they do not possess.  In KB the majority started with the fiction that the effect of a case reversing a previous decision is retrospectively to make the law governing the relationship between the parties different from the law which actually governed their relationship at the time when they entered it.  It can be argued that this fiction is defensible because without it, the court could not adjust the parties’ relationship in a way that ex hypothesi the court now considers appropriate; moreover, litigants would otherwise have no incentive to press for changes to the law, as they would be unable to take personal advantage of such changes.  But these reasons do not necessarily hold good when it asked whether the fiction of retrospective legal change also affects the relationship between other people who were not parties to the case.  If the pursuer in Donoghue had had an auntie who paid her money because she felt sorry for her and correctly believed at the time when she made the gift that the pursuer had no claim in tort against the defender, the question whether the auntie should be allowed to recover the money because she should retrospectively be deemed to have made a mistake can be sensibly answered only by starting from first principles: it won’t do simply to say ‘one fiction fits all’ and that the auntie must have been mistaken because retrospective changes to the law must affect everybody if they are going to affect anybody.  But if the majority in KB had a better reason than this for its findings on retrospective mistakes then I can’t find them; nor can I find anything in DMG which makes me feel better, notwithstanding Lord Hoffmann’s attempt to cheer me up at [23] by saying that the mistake in a retrospective mistake case is a 'deemed' mistake.  I guessed that!  The question is why should the claimant be deemed to have made a mistake?  Answer: ‘practical considerations of fairness’.  Hey ho.


(b) Was DMG mistaken in its belief that the money was due?

I agree with Rob that this was the IRC’s best point and that counsel seems to have blown it.  As Lord Scott holds (and as Monica Chowdry and I observed in [2005] RLR 1, at 16-18) DMG was not mistaken in its belief that a taxpayer which failed to make a group income election was liable to pay ACT: its mistake was to think that it was not entitled to make such an election.  This mistake led DMG not to make an election, with the inexorable result that the money was due.  This suggests that DMG’s mistake was neither here nor there and that it shouldn’t have been allowed to recover.  Otherwise a taxpayer who pays money pursuant to a completely valid tax regime might just as well say ‘Oh I didn’t realise that if I put my assets offshore I wouldn’t have had to pay this tax, so now that my friendly accountant has explained this to me I should be entitled to a rebate because I paid under a mistake’.

At first instance Park J recognised the problem at [25] but sought to get round it by holding that DMG ‘would have made’ an election if it had known that it was entitled to do so, and then asserting that it followed from this that the money wasn’t due.  This was a non sequitur.  In the CA Jonathan Parker LJ mistook the facts when he held at [231] that ‘the regime gave rise to no obligation to pay’ because it was unlawful  the only bit of the statute which was unlawful was the bit which disabled DMG from making an election; DMG’s liability to pay MCT in the event that it failed to make an election arose under a statutory section that was not unlawful at all.   In the HL Lord Hoffmann agrees with Jonathan Parker LJ at [32] and is wrong for the same reason.  He also dismisses Park J’s recognition of the problem as ‘rather sophisticated’, a criticism echoed by Lord Walker at [143] (‘over-analytical’).  Given the general expertise in tax law which they both undoubtedly possess (especially Lord Walker) I find this language surprising; they would have done better to heed the philosopher’s advice endorsed by Lord Hope at [41]: ‘Seek simplicity and distrust it.’  However, at [62] while Lord Hope correctly rejects Jonathan Parker LJ’s analysis, he also agrees with Park J, and is wrong for the same reason: the fact that there was ‘an unbroken causative link between the mistake and the payment’ is true, but it still doesn’t mean that the payment wasn’t due (as Lord Scott correctly observes at [89]).

So I agree with Rob that much more should have been made of this - but still, I wonder whether there isn’t an answer which the majority of the HL might have given in response to Lord Scott  - namely that the English courts were required by the ECJ in Metallgesellschaft at [96] to award restitution to parties in DMG’s position in order to give full effect to its Article 52 rights, and that this direction mandated a departure from the rule that normally governs restitutionary claims in UE, that they are debarred by the existence of valid statutory rules requiring the claimant to pay the defendant.  I’m afraid that my EC law isn’t good enough to answer this question, but perhaps there is someone out there who knows the answer: where a statutory tax regime is made up of several interconnected sections, some of which are expressly declared void for incompatibility with the Treaty, but some of which are not, can an English court override the tax authority’s right to keep money paid under one of the surviving valid sections on the basis that one of the void sections would otherwise be indirectly effective, contrary to the declaration of incompatibility?  (At [82] Lord Scott indicates that the answer is ‘no’!)

Charles



At 17:30 25/10/2006 +0100, Robert Stevens wrote:
A first response to DMG.

(1) Unsurprisingly, I think Lord Scott, a judge I have always held in the highest esteem, gets it right.

That said, I think counsel for the Revenue dropped the ball. Badly. It seems to have been conceded by counsel that a claim for restitution was available but only under Woolwich (see Lord Hoffmann at [7], Lord Walker at [117], [135]). Lord Scott seems to have taken the view he did without the assistance of argument on the point.

Normally, it is a good tactic when seeking to resist an appeal to the House of Lords to simply maintain that the Court of Appeal were right for the reasons they gave. However, in this case the arguments for an 'exclusive regime' in relation to ultra vires tax demands were so hopeless, and dependent upon a strained reading of the speeches of Lord Goff which the House of Lords were not bound by, that to seek to defend the result in the Court of Appeal based upon the reasons they gave was a serious mistake. Unsurprisingly, the Revenue went down 5-0 on this point.

Only Lord Hoffmann in the majority in what he describes as a footnote, briefly alludes to the point that the money was still payable, although the UK had behaved unlawfully as a matter of Community law. He agrees with the Court of Appeal, rejecting Park J's view, that there was no liability to pay, but gives no substantive reasons [32]. The Scot in the court, Lord Hope, very disappointingly agrees with Park J's interpretation of the legislation at [62], concluding that there was liability to pay but that this didn't matter as there was a causative mistake. The latter view cannot be right.

(2) Lord Walker seems to think that neither the correct interpretation of section 32(1)(c) nor the question of whether the claim was based upon mistake or absence of legal ground arose for resolution. However if we accept, as he seems to do at [146]-[147] that a mistake must be an essential element of the cause of action under section 32(1)(c), it is hard to see how the second question does not arise. In DMG the absence of legal ground, if there was one, was not triggered by the mistake but by the contravention of European Union law. If restitution follows where there is an absence of legal ground, the mistake made was not an essential element of the cause of action and section 32(1)(c) is not triggered.

Whilst Lord Walker's toying with Peter's 'Pyramid' at [158] is interesting, I wonder whether it is consistent with the result he reaches. Only if the mistake, at the base of the pyramid, triggers the absence of legal ground higher up is it an essential part of the cause of action (eg a contract of sale where the price has been paid but th subject matter does not exist.)

Lord Hoffmann sees the point, I think, but I am puzzling over his answer, at [22]

"That does not seem to me inconsistent with the existence of the mistake not being essential to the cause of action but merely one example of a case which falls within a more general principle, just as one could have (say, for the purposes of limitation) a category called "clinical negligence" without implying that it is a cause of action different in nature from other kinds of negligence."

He is saying, I think, that mistake need not be an essential part of the cause of action for the purposes of section 32(1)(c), but I am not sure I follow his reasoning as to why not. If anyone can help me out I'd be grateful.

(3) On whether there was a mistake the differences between Lords Hoffmann and Hope are those which where ascertainable from KB v Lincoln. Hoffmann is quite explicit in deeming there to be a mistake where the law has changed because of judicial decision ([23]) as he admits, this can be read as supporting the Birks view ([28]) that it is better not to try and square this with the orthodox approach that the transfer is vitiated by any mistake present in the claimant's mind, but rather to accept that the true basis of recovery is absence of legal ground. Lords Hope and Walker seem to me to place more emphasis on finding a real mistake.

(4) Lord Brown's point will have to be paid for by some litigant in the future.

(5) The shame is that a lot of time and effort has been spent rebutting the argument from 'exclusivity' which deservedly went down 5-0, when counsel's time, and their Lordships lengthy speeches, would more profitably have been spent focusing on other issues. 

Robert Stevens
Barrister
Fellow and Tutor in Law
Lady Margaret Hall
University of Oxford


Professor Charles Mitchell
School of Law
King's College London
Strand
London WC2R 2LS

tel: 020 7848 2290
fax: 020 7848 2465___________________________________________________________________ _ This message was delivered through the Restitution Discussion Group, an international internet LISTSERV devoted to all aspects of the law of unjust enrichment. To subscribe, send "subscribe enrichment" in the body of a message to <listserv@lists.mcgill.ca> . To unsubscribe, send "signoff enrichment" to the same address. To make a posting to all group members, send to <enrichment@lists.mcgill.ca >. The list is run by Lionel Smith of McGill University, <lionel.smith@mcgill.ca> . 


--

Jason Neyers

January Term Director

Associate Professor of Law

Faculty of Law

University of Western Ontario

N6A 3K7

(519) 661-2111 x. 88435
____________________________________________________________________ This message was delivered through the Restitution Discussion Group, an international internet LISTSERV devoted to all aspects of the law of unjust enrichment. To subscribe, send "subscribe enrichment" in the body of a message to <listserv@lists.mcgill.ca>. To unsubscribe, send "signoff enrichment" to the same address. To make a posting to all group members, send to <enrichment@lists.mcgill.ca>. The list is run by Lionel Smith of McGill University, <lionel.smith@mcgill.ca>. --Boundary_(ID_IBZHz/0FI1LMBZpTDXga0A)-- ======================================================================= == Date: Mon, 30 Oct 2006 16:12:23 +0000 Reply-To: Charles Mitchell Sender: Enrichment - Restitution & Unjust Enrichment Legal Issues From: Charles Mitchell Subject: Re: DMG Comments: To: Jason Neyers In-Reply-To: <454621BC.9000500@uwo.ca> Mime-Version: 1.0 Content-Type: multipart/alternative; boundary="=====================_1692543796==_.ALT" --=====================_1692543796==_.ALT Content-Type: text/plain; charset="us-ascii"; format=flowed Dear Jason I'm not sure I think that absence of basis reasoning would allow us to avoid either of the difficulties I describe under headings 2a and 2b. So far as 2a is concerned, where C pays correctly believing that a rule of law requires him to do so, and the rule is subsequently overturned by judicial decision, would we not still be faced with the question whether the basis for C's payment should be deemed by application of a legal fiction not to have existed at the time when the payment was made? And so far as 2b is concerned, would we not still be faced with the problem that the payment made by DMG was due under a valid statutory section? Best wishes Charles At 11:01 30/10/2006 -0500, Jason Neyers wrote: >Dear Charles: > >The difficulties you have with the mistake analysis show why absence of >basis is the simplest most coherent view of unjust enrichment. Although >the province of UE would be smaller under this view, what was covered >would hold together better. > >Cheers, > >Charles Mitchell wrote: >>Stimulated by Rob s comments I have a few further thoughts about the case: >> >>(1) The "cause of action" issue: does English law recognise a >>restitutionary claim for tax paid under a mistake of law? >> >>I share Rob s view that the CA s treatment of this issue was weak and >>unconvincing. Jonathan Parker LJ s methodology was very >>strange. However, it doesn t follow from the fact that the CA did a poor >>job that no respectable arguments can be marshalled to support the >>proposition that recovery of ultra vires tax payments should be governed >>by an exclusive regime . The public character of tax authorities, and >>the special nature of the relationship between citizen and state, might >>lead one to conclude that such claims are sufficiently different from >>claims between private individuals that they should be fenced off and >>treated differently. Rebecca Williams has developed this line of thought >>more eloquently and expertly than I can manage, and I m not sure that I >>find it completely convincing: it troubles me, for example, that the >>public/private borderline is so fuzzy that cases would often arise where >>it was unclear whether or not the claim fell within the scope of an >>exclusive regime. Without pursuing this any further, though, I would >>just say that it may not be entirely fair to counsel for the IRC to >>suggest that they relied solely on the CA s narrow textual approach: at >>[131]ff Lord Walker indicates that arguments from principle were also >>made, albeit that he and the others seem to have found these unconvincing. >> >> >>(2) The "mistake" issue: did DMG make the payments of ACT under a mistake >>of law? >> >>(a) Do judicial decisions changing the law retrospectively render >>payments made in line with the old law mistaken? >> >>The HL were obliged to say yes in light of KB v Lincoln. In my view, >>however, the majority s reasoning in KB was deeply flawed because the >>reach of legal fictions cannot be determined by taking them at face value >>and discovering in them an inherent logic which they do not possess. In >>KB the majority started with the fiction that the effect of a case >>reversing a previous decision is retrospectively to make the law >>governing the relationship between the parties different from the law >>which actually governed their relationship at the time when they entered >>it. It can be argued that this fiction is defensible because without it, >>the court could not adjust the parties relationship in a way that ex >>hypothesi the court now considers appropriate; moreover, litigants would >>otherwise have no incentive to press for changes to the law, as they >>would be unable to take personal advantage of such changes. But these >>reasons do not necessarily hold good when it asked whether the fiction of >>retrospective legal change also affects the relationship between other >>people who were not parties to the case. If the pursuer in Donoghue had >>had an auntie who paid her money because she felt sorry for her and >>correctly believed at the time when she made the gift that the pursuer >>had no claim in tort against the defender, the question whether the >>auntie should be allowed to recover the money because she should >>retrospectively be deemed to have made a mistake can be sensibly answered >>only by starting from first principles: it won t do simply to say one >>fiction fits all and that the auntie must have been mistaken because >>retrospective changes to the law must affect everybody if they are going >>to affect anybody. But if the majority in KB had a better reason than >>this for its findings on retrospective mistakes then I can t find them; >>nor can I find anything in DMG which makes me feel better, >>notwithstanding Lord Hoffmann s attempt to cheer me up at [23] by saying >>that the mistake in a retrospective mistake case is a 'deemed' >>mistake. I guessed that! The question is why should the claimant be >>deemed to have made a mistake? Answer: practical considerations of >>fairness . Hey ho. >> >> >>(b) Was DMG mistaken in its belief that the money was due? >> >>I agree with Rob that this was the IRC s best point and that counsel >>seems to have blown it. As Lord Scott holds (and as Monica Chowdry and I >>observed in [2005] RLR 1, at 16-18) DMG was not mistaken in its belief >>that a taxpayer which failed to make a group income election was liable >>to pay ACT: its mistake was to think that it was not entitled to make >>such an election. This mistake led DMG not to make an election, with the >>inexorable result that the money was due. This suggests that DMG s >>mistake was neither here nor there and that it shouldn t have been >>allowed to recover. Otherwise a taxpayer who pays money pursuant to a >>completely valid tax regime might just as well say Oh I didn t realise >>that if I put my assets offshore I wouldn t have had to pay this tax, so >>now that my friendly accountant has explained this to me I should be >>entitled to a rebate because I paid under a mistake . >> >>At first instance Park J recognised the problem at [25] but sought to get >>round it by holding that DMG would have made an election if it had known >>that it was entitled to do so, and then asserting that it followed from >>this that the money wasn t due. This was a non sequitur. In the CA >>Jonathan Parker LJ mistook the facts when he held at [231] that the >>regime gave rise to no obligation to pay because it was unlawful the >>only bit of the statute which was unlawful was the bit which disabled DMG >>from making an election; DMG s liability to pay MCT in the event that it >>failed to make an election arose under a statutory section that was not >>unlawful at all. In the HL Lord Hoffmann agrees with Jonathan Parker LJ >>at [32] and is wrong for the same reason. He also dismisses Park J s >>recognition of the problem as rather sophisticated , a criticism echoed >>by Lord Walker at [143] ( over-analytical ). Given the general expertise >>in tax law which they both undoubtedly possess (especially Lord Walker) I >>find this language surprising; they would have done better to heed the >>philosopher s advice endorsed by Lord Hope at [41]: Seek simplicity and >>distrust it. However, at [62] while Lord Hope correctly rejects >>Jonathan Parker LJ s analysis, he also agrees with Park J, and is wrong >>for the same reason: the fact that there was an unbroken causative link >>between the mistake and the payment is true, but it still doesn t mean >>that the payment wasn t due (as Lord Scott correctly observes at [89]). >> >>So I agree with Rob that much more should have been made of this - but >>still, I wonder whether there isn t an answer which the majority of the >>HL might have given in response to Lord Scott - namely that the English >>courts were required by the ECJ in Metallgesellschaft at [96] to award >>restitution to parties in DMG s position in order to give full effect to >>its Article 52 rights, and that this direction mandated a departure from >>the rule that normally governs restitutionary claims in UE, that they are >>debarred by the existence of valid statutory rules requiring the claimant >>to pay the defendant. I m afraid that my EC law isn t good enough to >>answer this question, but perhaps there is someone out there who knows >>the answer: where a statutory tax regime is made up of several >>interconnected sections, some of which are expressly declared void for >>incompatibility with the Treaty, but some of which are not, can an >>English court override the tax authority s right to keep money paid under >>one of the surviving valid sections on the basis that one of the void >>sections would otherwise be indirectly effective, contrary to the >>declaration of incompatibility? (At [82] Lord Scott indicates that the >>answer is no !) >> >>Charles >> >> >> >>At 17:30 25/10/2006 +0100, Robert Stevens wrote: >>>A first response to DMG. >>> >>>(1) Unsurprisingly, I think Lord Scott, a judge I have always held in >>>the highest esteem, gets it right. >>> >>>That said, I think counsel for the Revenue dropped the ball. Badly. It >>>seems to have been conceded by counsel that a claim for restitution was >>>available but only under Woolwich (see Lord Hoffmann at [7], Lord Walker >>>at [117], [135]). Lord Scott seems to have taken the view he did without >>>the assistance of argument on the point. >>> >>>Normally, it is a good tactic when seeking to resist an appeal to the >>>House of Lords to simply maintain that the Court of Appeal were right >>>for the reasons they gave. However, in this case the arguments for an >>>'exclusive regime' in relation to ultra vires tax demands were so >>>hopeless, and dependent upon a strained reading of the speeches of Lord >>>Goff which the House of Lords were not bound by, that to seek to defend >>>the result in the Court of Appeal based upon the reasons they gave was a >>>serious mistake. Unsurprisingly, the Revenue went down 5-0 on this point. >>> >>>Only Lord Hoffmann in the majority in what he describes as a footnote, >>>briefly alludes to the point that the money was still payable, although >>>the UK had behaved unlawfully as a matter of Community law. He agrees >>>with the Court of Appeal, rejecting Park J's view, that there was no >>>liability to pay, but gives no substantive reasons [32]. The Scot in the >>>court, Lord Hope, very disappointingly agrees with Park J's >>>interpretation of the legislation at [62], concluding that there was >>>liability to pay but that this didn't matter as there was a causative >>>mistake. The latter view cannot be right. >>> >>>(2) Lord Walker seems to think that neither the correct interpretation >>>of section 32(1)(c) nor the question of whether the claim was based upon >>>mistake or absence of legal ground arose for resolution. However if we >>>accept, as he seems to do at [146]-[147] that a mistake must be an >>>essential element of the cause of action under section 32(1)(c), it is >>>hard to see how the second question does not arise. In DMG the absence >>>of legal ground, if there was one, was not triggered by the mistake but >>>by the contravention of European Union law. If restitution follows where >>>there is an absence of legal ground, the mistake made was not an >>>essential element of the cause of action and section 32(1)(c) is not triggered. >>> >>>Whilst Lord Walker's toying with Peter's 'Pyramid' at [158] is >>>interesting, I wonder whether it is consistent with the result he >>>reaches. Only if the mistake, at the base of the pyramid, triggers the >>>absence of legal ground higher up is it an essential part of the cause >>>of action (eg a contract of sale where the price has been paid but th >>>subject matter does not exist.) >>> >>>Lord Hoffmann sees the point, I think, but I am puzzling over his >>>answer, at [22] >>> >>>"That does not seem to me inconsistent with the existence of the mistake >>>not being essential to the cause of action but merely one example of a >>>case which falls within a more general principle, just as one could have >>>(say, for the purposes of limitation) a category called "clinical >>>negligence" without implying that it is a cause of action different in >>>nature from other kinds of negligence." >>> >>>He is saying, I think, that mistake need not be an essential part of the >>>cause of action for the purposes of section 32(1)(c), but I am not sure >>>I follow his reasoning as to why not. If anyone can help me out I'd be >>>grateful. >>> >>>(3) On whether there was a mistake the differences between Lords >>>Hoffmann and Hope are those which where ascertainable from KB v Lincoln. >>>Hoffmann is quite explicit in deeming there to be a mistake where the >>>law has changed because of judicial decision ([23]) as he admits, this >>>can be read as supporting the Birks view ([28]) that it is better not to >>>try and square this with the orthodox approach that the transfer is >>>vitiated by any mistake present in the claimant's mind, but rather to >>>accept that the true basis of recovery is absence of legal ground. Lords >>>Hope and Walker seem to me to place more emphasis on finding a real mistake. >>> >>>(4) Lord Brown's point will have to be paid for by some litigant in the >>>future. >>> >>>(5) The shame is that a lot of time and effort has been spent rebutting >>>the argument from 'exclusivity' which deservedly went down 5-0, when >>>counsel's time, and their Lordships lengthy speeches, would more >>>profitably have been spent focusing on other issues. >>> >>>Robert Stevens >>>Barrister >>>Fellow and Tutor in Law >>>Lady Margaret Hall >>>University of Oxford >> >> >>Professor Charles Mitchell >>School of Law >>King's College London >>Strand >>London WC2R 2LS >> >>tel: 020 7848 2290 >>fax: 020 7848 >>2465_________________________________________________________________ ___ >>This message was delivered through the Restitution Discussion Group, an >>international internet LISTSERV devoted to all aspects of the law of >>unjust enrichment. To subscribe, send "subscribe enrichment" in the body >>of a message to >>. To >>unsubscribe, send "signoff enrichment" to the same address. To make a >>posting to all group members, send to >>. The list >>is run by Lionel Smith of McGill University, >>. > > >-- >Jason Neyers >January Term Director >Associate Professor of Law >Faculty of Law >University of Western Ontario >N6A 3K7 >(519) 661-2111 x. 88435 ____________________________________________________________________ This message was delivered through the Restitution Discussion Group, an international internet LISTSERV devoted to all aspects of the law of unjust enrichment. To subscribe, send "subscribe enrichment" in the body of a message to . To unsubscribe, send "signoff enrichment" to the same address. To make a posting to all group members, send to . The list is run by Lionel Smith of McGill University, . --=====================_1692543796==_.ALT Content-Type: text/html; charset="iso-8859-1" Content-Transfer-Encoding: quoted-printable Dear Jason

I'm not sure I think that absence of basis reasoning would allow us to avoid either of the difficulties I describe under headings 2a and 2b.  So far as 2a is concerned, where C pays correctly believing that a rule of law requires him to do so, and the rule is subsequently overturned by judicial decision, would we not still be faced with the question whether the basis for C's payment should be deemed by application of a legal fiction not to have existed at the time when the payment was made?  And so far as 2b is concerned, would we not still be faced with the problem that the payment made by DMG was due under a valid statutory section?

Best wishes
Charles


At 11:01 30/10/2006 -0500, Jason Neyers wrote:
Dear Charles:

The difficulties you have with the mistake analysis show why absence of basis is the simplest most coherent view of unjust enrichment.  Although the province of  UE would be smaller under this view, what was covered would hold together better.

Cheers,

Charles Mitchell wrote:
Stimulated by Rob s comments I hav= e a few further thoughts about the case:

(1) The "cause of action" issue: does English law recognise a restitutionary claim for tax paid under a mistake of law?

I share Rob s view that the CA s treatment of this issue was weak and unconvincing.  Jonathan Parker LJ s methodology was very strange.  However, it doesn t follow from the fact that the CA did a poor job that no respectable arguments can be marshalled to support the proposition that recovery of ultra vires tax payments should be governed by an exclusive regime .  The public character of tax authorities, and the special nature of the relationship between citizen and state, might lead one to conclude that such claims are sufficiently different from claims between private individuals that they should be fenced off and treated differently.  Rebecca Williams has developed this line of thought more eloquently and expertly than I can manage, and I m not sure that I find it completely convincing: it troubles me, for example, that the public/private borderline is so fuzzy that cases would often arise where it was unclear whether or not the claim fell within the scope of an exclusive regime.  Without pursuing this any further, though, I would just say that it may not be entirely fair to counsel for the IRC to suggest that they relied solely on the CA s narrow textual approach: at [131]ff Lord Walker indicates that arguments from principle were also made, albeit that he and the others seem to have found these unconvincing.


(2) The "mistake" issue: did DMG make the payments of ACT under a mistake of law?

(a) Do judicial decisions changing the law retrospectively render payments made in line with the old law mistaken? 

The HL were obliged to say yes in light of KB v Lincoln.  In my view, however, the majority s reasoning in KB was deeply flawed because the reach of legal fictions cannot be determined by taking them at face value and discovering in them an inherent logic which they do not possess.  In KB the majority started with the fiction that the effect of a case reversing a previous decision is retrospectively to make the law governing the relationship between the parties different from the law which actually governed their relationship at the time when they entered it.  It can be argued that this fiction is defensible because without it, the court could not adjust the parties relationship in a way that ex hypothesi the court now considers appropriate; moreover, litigants would otherwise have no incentive to press for changes to the law, as they would be unable to take personal advantage of such changes.  But these reasons do not necessarily hold good when it asked whether the fiction of retrospective legal change also affects the relationship between other people who were not parties to the case.  If the pursuer in Donoghue had had an auntie who paid her money because she felt sorry for her and correctly believed at the time when she made the gift that the pursuer had no claim in tort against the defender, the question whether the auntie should be allowed to recover the money because she should retrospectively be deemed to have made a mistake can be sensibly answered only by starting from first principles: it won t do simply to say one fiction fits all and that the auntie must have been mistaken because retrospective changes to the law must affect everybody if they are going to affect anybody.  But if the majority in KB had a better reason than this for its findings on retrospective mistakes then I can t find them; nor can I find anything in DMG which makes me feel better, notwithstanding Lord Hoffmann s attempt to cheer me up at [23] by saying that the mistake in a retrospective mistake case is a 'deemed' mistake.  I guessed that!  The question is why should the claimant be deemed to have made a mistake?  Answer: practical considerations of fairness .  Hey ho.


(b) Was DMG mistaken in its belief that the money was due?

I agree with Rob that this was the IRC s best point and that counsel seems to have blown it.  As Lord Scott holds (and as Monica Chowdry and I observed in [2005] RLR 1, at 16-18) DMG was not mistaken in its belief that a taxpayer which failed to make a group income election was liable to pay ACT: its mistake was to think that it was not entitled to make such an election.  This mistake led DMG not to make an election, with the inexorable result that the money was due.  This suggests that DMG s mistake was neither here nor there and that it shouldn t have been allowed to recover.  Otherwise a taxpayer who pays money pursuant to a completely valid tax regime might just as well say Oh I didn t realise that if I put my assets offshore I wouldn t have had to pay this tax, so now that my friendly accountant has explained this to me I should be entitled to a rebate because I paid under a mistake .

At first instance Park J recognised the problem at [25] but sought to get round it by holding that DMG would have made an election if it had known that it was entitled to do so, and then asserting that it followed from this that the money wasn t due.  This was a non sequitur.  In the CA Jonathan Parker LJ mistook the facts when he held at [231] that the regime gave rise to no obligation to pay because it was unlawful  the only bit of the statute which was unlawful was the bit which disabled DMG from making an election; DMG s liability to pay MCT in the event that it failed to make an election arose under a statutory section that was not unlawful at all.   In the HL Lord Hoffmann agrees with Jonathan Parker LJ at [32] and is wrong for the same reason.  He also dismisses Park J s recognition of the problem as rather sophisticated , a criticism echoed by Lord Walker at [143] ( over-analytical ).  Given the general expertise in tax law which they both undoubtedly possess (especially Lord Walker) I find this language surprising; they would have done better to heed the philosopher s advice endorsed by Lord Hope at [41]: Seek simplicity and distrust it.   However, at [62] while Lord Hope correctly rejects Jonathan Parker LJ s analysis, he also agrees with Park J, and is wrong for the same reason: the fact that there was an unbroken causative link between the mistake and the payment is true, but it still doesn t mean that the payment wasn t due (as Lord Scott correctly observes at [89]).

So I agree with Rob that much more should have been made of this - but still, I wonder whether there isn t an answer which the majority of the HL might have given in response to Lord Scott  - namely that the English courts were required by the ECJ in Metallgesellschaft at [96] to award restitution to parties in DMG s position in order to give full effect to its Article 52 rights, and that this direction mandated a departure from the rule that normally governs restitutionary claims in UE, that they are debarred by the existence of valid statutory rules requiring the claimant to pay the defendant.  I m afraid that my EC law isn t good enough to answer this question, but perhaps there is someone out there who knows the answer: where a statutory tax regime is made up of several interconnected sections, some of which are expressly declared void for incompatibility with the Treaty, but some of which are not, can an English court override the tax authority s right to keep money paid under one of the surviving valid sections on the basis that one of the void sections would otherwise be indirectly effective, contrary to the declaration of incompatibility?  (At [82] Lord Scott indicates that the answer is no !)

Charles



At 17:30 25/10/2006 +0100, Robert Stevens wrote:
A first response to DMG.

(1) Unsurprisingly, I think Lord Scott, a judge I have always held in the highest esteem, gets it right.

That said, I think counsel for the Revenue dropped the ball. Badly. It seems to have been conceded by counsel that a claim for restitution was available but only under Woolwich (see Lord Hoffmann at [7], Lord Walker at [117], [135]). Lord Scott seems to have taken the view he did without the assistance of argument on the point.

Normally, it is a good tactic when seeking to resist an appeal to the House of Lords to simply maintain that the Court of Appeal were right for the reasons they gave. However, in this case the arguments for an 'exclusive regime' in relation to ultra vires tax demands were so hopeless, and dependent upon a strained reading of the speeches of Lord Goff which the House of Lords were not bound by, that to seek to defend the result in the Court of Appeal based upon the reasons they gave was a serious mistake. Unsurprisingly, the Revenue went down 5-0 on this point.

Only Lord Hoffmann in the majority in what he describes as a footnote, briefly alludes to the point that the money was still payable, although the UK had behaved unlawfully as a matter of Community law. He agrees with the Court of Appeal, rejecting Park J's view, that there was no liability to pay, but gives no substantive reasons [32]. The Scot in the court, Lord Hope, very disappointingly agrees with Park J's interpretation of the legislation at [62], concluding that there was liability to pay but that this didn't matter as there was a causative mistake. The latter view cannot be right.

(2) Lord Walker seems to think that neither the correct interpretation of section 32(1)(c) nor the question of whether the claim was based upon mistake or absence of legal ground arose for resolution. However if we accept, as he seems to do at [146]-[147] that a mistake must be an essential element of the cause of action under section 32(1)(c), it is hard to see how the second question does not arise. In DMG the absence of legal ground, if there was one, was not triggered by the mistake but by the contravention of European Union law. If restitution follows where there is an absence of legal ground, the mistake made was not an essential element of the cause of action and section 32(1)(c) is not triggered.

Whilst Lord Walker's toying with Peter's 'Pyramid' at [158] is interesting, I wonder whether it is consistent with the result he reaches. Only if the mistake, at the base of the pyramid, triggers the absence of legal ground higher up is it an essential part of the cause of action (eg a contract of sale where the price has been paid but th subject matter does not exist.)

Lord Hoffmann sees the point, I think, but I am puzzling over his answer, at [22]

"That does not seem to me inconsistent with the existence of the mistake not being essential to the cause of action but merely one example of a case which falls within a more general principle, just as one could have (say, for the purposes of limitation) a category called "clinical negligence" without implying that it is a cause of action different in nature from other kinds of=20 negligence."

He is saying, I think, that mistake need not be an essential part of the cause of action for the purposes of section 32(1)(c), but I am not sure I follow his reasoning as to why not. If anyone can help me out I'd be grateful.

(3) On whether there was a mistake the differences between Lords Hoffmann and Hope are those which where ascertainable from KB v Lincoln. Hoffmann is quite explicit in deeming there to be a mistake where the law has changed because of judicial decision ([23]) as he admits, this can be read as supporting the Birks view ([28]) that it is better not to try and square this with the orthodox approach that the transfer is vitiated by any mistake present in the claimant's mind, but rather to accept that the true basis of recovery is absence of legal ground. Lords Hope and Walker seem to me to place more emphasis on finding a real mistake.

(4) Lord Brown's point will have to be paid for by some litigant in the future.

(5) The shame is that a lot of time and effort has been spent rebutting the argument from 'exclusivity' which deservedly went down 5-0, when counsel's time, and their Lordships lengthy speeches, would more profitably have been spent focusing on other issues. 

Robert Stevens
Barrister
Fellow and Tutor in Law
Lady Margaret Hall
University of Oxford


Professor Charles Mitchell
School of Law
King's College London
Strand
London WC2R 2LS

tel: 020 7848 2290
fax: 020 7848 2465___________________________________________________________________ _ This message was delivered through the Restitution Discussion Group, an international internet LISTSERV devoted to all aspects of the law of unjust enrichment. To subscribe, send "subscribe enrichment" in the body of a message to <listserv@lists.mcgill.ca&g t;= . To unsubscribe, send "signoff enrichment" to the same address. To make a posting to all group members, send to <enrichment@lists.mcgill. ca= >. The list is run by Lionel Smith of McGill University, <lionel.smith@mcgill.ca>= . 


--=20

Jason Neyers

January Term Director

Associate Professor of Law

Faculty of Law

University of Western Ontario

N6A 3K7

(519) 661-2111 x. 88435
____________________________________________________________________ This message was delivered through the Restitution Discussion Group, an international internet LISTSERV devoted to all aspects of the law of unjust enrichment. To subscribe, send "subscribe enrichment" in the body of a message to <listserv@lists.mcgill.ca>. To unsubscribe, send "signoff enrichment" to the same address. To make a posting to all group members, send to <enrichment@lists.mcgill.ca>. The list is run by Lionel Smith of McGill University, <lionel.smith@mcgill.ca>. --=====================_1692543796==_.ALT-- ======================================================================= == Date: Mon, 30 Oct 2006 16:36:35 +0000 Reply-To: Robert Stevens Sender: Enrichment - Restitution & Unjust Enrichment Legal Issues From: Robert Stevens Subject: Re: DMG Comments: To: Charles Mitchell In-Reply-To: <5.1.0.14.2.20061030160211.01fad550@pop.kcl.ac.uk> Content-Type: text/plain Content-Disposition: inline Content-Transfer-Encoding: 7bit MIME-Version: 1.0 Charles wrote > I'm not sure I think that absence of basis reasoning would allow us to > avoid either of the difficulties I describe under headings 2a and 2b. So > far as 2a is concerned, where C pays correctly believing that a rule of law > requires him to do so, and the rule is subsequently overturned by judicial > decision, would we not still be faced with the question whether the basis > for C's payment should be deemed by application of a legal fiction not to > have existed at the time when the payment was made? I don't think so. We don't need any fiction on the absence of basis model. There is no doubt that the law can be changed with retrospective effect, indeed this can be done by legislation. (A nice example is Commissioner of State Revenue v Royal Insurance (1994) 182 CLR 51.)If that change means that there is no legal ground, there is recovery. We don't have to worry about the fact that at the time of the payment there was a legal ground. We only need to worry about this if we feel compelled to squeeze the claim into a mistake analysis. And so far as 2b is > concerned, would we not still be faced with the problem that the payment > made by DMG was due under a valid statutory section? Absolutely, indeed the problem is even more obvious. Robert Stevens ____________________________________________________________________ This message was delivered through the Restitution Discussion Group, an international internet LISTSERV devoted to all aspects of the law of unjust enrichment. To subscribe, send "subscribe enrichment" in the body of a message to . To unsubscribe, send "signoff enrichment" to the same address. To make a posting to all group members, send to . The list is run by Lionel Smith of McGill University, . ======================================================================= == Date: Mon, 30 Oct 2006 11:54:43 -0500 Reply-To: Jason Neyers Sender: Enrichment - Restitution & Unjust Enrichment Legal Issues From: Jason Neyers Subject: Re: DMG Comments: To: Charles Mitchell In-Reply-To: <5.1.0.14.2.20061030160211.01fad550@pop.kcl.ac.uk> MIME-version: 1.0 Content-type: multipart/alternative; boundary="Boundary_(ID_1eztAXhZ7TghLyigesUxTA)" This is a multi-part message in MIME format. --Boundary_(ID_1eztAXhZ7TghLyigesUxTA) Content-type: text/plain; charset=us-ascii; format=flowed Content-transfer-encoding: 7BIT Dear Charles: In regard to 2a: I guess I don't accept the legal fiction part of it, the judges are for the most part stating what they think the law always demanded based on what the other rules already say or what constitutional documents already say (including EU law). I agree with Peter Watts when he said: "It amazes me how readily modern appellate judges think they change the law". It only seems fictional when you apply subjective concepts of mistake which are dependent on non-legal facts like common understandings at points in time. In regard to 2b: I think that there was a jurisitic reason/basis for the enrichment so side with Lord Scott. If there is to be recovery it is on the basis that the state committed a legal wrong of some sort (i.e. acted unconstitutionally in a wide sense). That is why I said that UE is smaller but tighter. Cheers, Charles Mitchell wrote: > Dear Jason > > I'm not sure I think that absence of basis reasoning would allow us to > avoid either of the difficulties I describe under headings 2a and 2b. > So far as 2a is concerned, where C pays correctly believing that a > rule of law requires him to do so, and the rule is subsequently > overturned by judicial decision, would we not still be faced with the > question whether the basis for C's payment should be deemed by > application of a legal fiction not to have existed at the time when > the payment was made? And so far as 2b is concerned, would we not > still be faced with the problem that the payment made by DMG was due > under a valid statutory section? > > Best wishes > Charles > > > At 11:01 30/10/2006 -0500, Jason Neyers wrote: > >> Dear Charles: >> >> The difficulties you have with the mistake analysis show why absence >> of basis is the simplest most coherent view of unjust enrichment. >> Although the province of UE would be smaller under this view, what >> was covered would hold together better. >> >> Cheers, >> >> Charles Mitchell wrote: >> >>> Stimulated by Rob s comments I have a few further thoughts about the >>> case: >>> >>> (1) The "cause of action" issue: does English law recognise a >>> restitutionary claim for tax paid under a mistake of law? >>> >>> I share Rob s view that the CA s treatment of this issue was weak >>> and unconvincing. Jonathan Parker LJ s methodology was very >>> strange. However, it doesn t follow from the fact that the CA did a >>> poor job that no respectable arguments can be marshalled to support >>> the proposition that recovery of ultra vires tax payments should be >>> governed by an exclusive regime . The public character of tax >>> authorities, and the special nature of the relationship between >>> citizen and state, might lead one to conclude that such claims are >>> sufficiently different from claims between private individuals that >>> they should be fenced off and treated differently. Rebecca Williams >>> has developed this line of thought more eloquently and expertly than >>> I can manage, and I m not sure that I find it completely convincing: >>> it troubles me, for example, that the public/private borderline is >>> so fuzzy that cases would often arise where it was unclear whether >>> or not the claim fell within the scope of an exclusive regime. >>> Without pursuing this any further, though, I would just say that it >>> may not be entirely fair to counsel for the IRC to suggest that they >>> relied solely on the CA s narrow textual approach: at [131]ff Lord >>> Walker indicates that arguments from principle were also made, >>> albeit that he and the others seem to have found these unconvincing. >>> >>> >>> (2) The "mistake" issue: did DMG make the payments of ACT under a >>> mistake of law? >>> >>> (a) Do judicial decisions changing the law retrospectively render >>> payments made in line with the old law mistaken? >>> >>> The HL were obliged to say yes in light of KB v Lincoln. In my >>> view, however, the majority s reasoning in KB was deeply flawed >>> because the reach of legal fictions cannot be determined by taking >>> them at face value and discovering in them an inherent logic which >>> they do not possess. In KB the majority started with the fiction >>> that the effect of a case reversing a previous decision is >>> retrospectively to make the law governing the relationship between >>> the parties different from the law which actually governed their >>> relationship at the time when they entered it. It can be argued >>> that this fiction is defensible because without it, the court could >>> not adjust the parties relationship in a way that ex hypothesi the >>> court now considers appropriate; moreover, litigants would otherwise >>> have no incentive to press for changes to the law, as they would be >>> unable to take personal advantage of such changes. But these >>> reasons do not necessarily hold good when it asked whether the >>> fiction of retrospective legal change also affects the relationship >>> between other people who were not parties to the case. If the >>> pursuer in Donoghue had had an auntie who paid her money because she >>> felt sorry for her and correctly believed at the time when she made >>> the gift that the pursuer had no claim in tort against the defender, >>> the question whether the auntie should be allowed to recover the >>> money because she should retrospectively be deemed to have made a >>> mistake can be sensibly answered only by starting from first >>> principles: it won t do simply to say one fiction fits all and that >>> the auntie must have been mistaken because retrospective changes to >>> the law must affect everybody if they are going to affect anybody. >>> But if the majority in KB had a better reason than this for its >>> findings on retrospective mistakes then I can t find them; nor can I >>> find anything in DMG which makes me feel better, notwithstanding >>> Lord Hoffmann s attempt to cheer me up at [23] by saying that the >>> mistake in a retrospective mistake case is a 'deemed' mistake. I >>> guessed that! The question is why should the claimant be deemed to >>> have made a mistake? Answer: practical considerations of fairness >>> . Hey ho. >>> >>> >>> (b) Was DMG mistaken in its belief that the money was due? >>> >>> I agree with Rob that this was the IRC s best point and that counsel >>> seems to have blown it. As Lord Scott holds (and as Monica Chowdry >>> and I observed in [2005] RLR 1, at 16-18) DMG was not mistaken in >>> its belief that a taxpayer which failed to make a group income >>> election was liable to pay ACT: its mistake was to think that it was >>> not entitled to make such an election. This mistake led DMG not to >>> make an election, with the inexorable result that the money was >>> due. This suggests that DMG s mistake was neither here nor there >>> and that it shouldn t have been allowed to recover. Otherwise a >>> taxpayer who pays money pursuant to a completely valid tax regime >>> might just as well say Oh I didn t realise that if I put my assets >>> offshore I wouldn t have had to pay this tax, so now that my >>> friendly accountant has explained this to me I should be entitled to >>> a rebate because I paid under a mistake . >>> >>> At first instance Park J recognised the problem at [25] but sought >>> to get round it by holding that DMG would have made an election if >>> it had known that it was entitled to do so, and then asserting that >>> it followed from this that the money wasn t due. This was a non >>> sequitur. In the CA Jonathan Parker LJ mistook the facts when he >>> held at [231] that the regime gave rise to no obligation to pay >>> because it was unlawful the only bit of the statute which was >>> unlawful was the bit which disabled DMG from making an election; DMG >>> s liability to pay MCT in the event that it failed to make an >>> election arose under a statutory section that was not unlawful at >>> all. In the HL Lord Hoffmann agrees with Jonathan Parker LJ at >>> [32] and is wrong for the same reason. He also dismisses Park J s >>> recognition of the problem as rather sophisticated , a criticism >>> echoed by Lord Walker at [143] ( over-analytical ). Given the >>> general expertise in tax law which they both undoubtedly possess >>> (especially Lord Walker) I find this language surprising; they would >>> have done better to heed the philosopher s advice endorsed by Lord >>> Hope at [41]: Seek simplicity and distrust it. However, at [62] >>> while Lord Hope correctly rejects Jonathan Parker LJ s analysis, he >>> also agrees with Park J, and is wrong for the same reason: the fact >>> that there was an unbroken causative link between the mistake and >>> the payment is true, but it still doesn t mean that the payment wasn >>> t due (as Lord Scott correctly observes at [89]). >>> >>> So I agree with Rob that much more should have been made of this - >>> but still, I wonder whether there isn t an answer which the majority >>> of the HL might have given in response to Lord Scott - namely that >>> the English courts were required by the ECJ in Metallgesellschaft at >>> [96] to award restitution to parties in DMG s position in order to >>> give full effect to its Article 52 rights, and that this direction >>> mandated a departure from the rule that normally governs >>> restitutionary claims in UE, that they are debarred by the existence >>> of valid statutory rules requiring the claimant to pay the >>> defendant. I m afraid that my EC law isn t good enough to answer >>> this question, but perhaps there is someone out there who knows the >>> answer: where a statutory tax regime is made up of several >>> interconnected sections, some of which are expressly declared void >>> for incompatibility with the Treaty, but some of which are not, can >>> an English court override the tax authority s right to keep money >>> paid under one of the surviving valid sections on the basis that one >>> of the void sections would otherwise be indirectly effective, >>> contrary to the declaration of incompatibility? (At [82] Lord Scott >>> indicates that the answer is no !) >>> >>> Charles >>> >>> >>> >>> At 17:30 25/10/2006 +0100, Robert Stevens wrote: >>> >>>> A first response to DMG. >>>> >>>> (1) Unsurprisingly, I think Lord Scott, a judge I have always held >>>> in the highest esteem, gets it right. >>>> >>>> That said, I think counsel for the Revenue dropped the ball. Badly. >>>> It seems to have been conceded by counsel that a claim for >>>> restitution was available but only under Woolwich (see Lord >>>> Hoffmann at [7], Lord Walker at [117], [135]). Lord Scott seems to >>>> have taken the view he did without the assistance of argument on >>>> the point. >>>> >>>> Normally, it is a good tactic when seeking to resist an appeal to >>>> the House of Lords to simply maintain that the Court of Appeal were >>>> right for the reasons they gave. However, in this case the >>>> arguments for an 'exclusive regime' in relation to ultra vires tax >>>> demands were so hopeless, and dependent upon a strained reading of >>>> the speeches of Lord Goff which the House of Lords were not bound >>>> by, that to seek to defend the result in the Court of Appeal based >>>> upon the reasons they gave was a serious mistake. Unsurprisingly, >>>> the Revenue went down 5-0 on this point. >>>> >>>> Only Lord Hoffmann in the majority in what he describes as a >>>> footnote, briefly alludes to the point that the money was still >>>> payable, although the UK had behaved unlawfully as a matter of >>>> Community law. He agrees with the Court of Appeal, rejecting Park >>>> J's view, that there was no liability to pay, but gives no >>>> substantive reasons [32]. The Scot in the court, Lord Hope, very >>>> disappointingly agrees with Park J's interpretation of the >>>> legislation at [62], concluding that there was liability to pay but >>>> that this didn't matter as there was a causative mistake. The >>>> latter view cannot be right. >>>> >>>> (2) Lord Walker seems to think that neither the correct >>>> interpretation of section 32(1)(c) nor the question of whether the >>>> claim was based upon mistake or absence of legal ground arose for >>>> resolution. However if we accept, as he seems to do at [146]-[147] >>>> that a mistake must be an essential element of the cause of action >>>> under section 32(1)(c), it is hard to see how the second question >>>> does not arise. In DMG the absence of legal ground, if there was >>>> one, was not triggered by the mistake but by the contravention of >>>> European Union law. If restitution follows where there is an >>>> absence of legal ground, the mistake made was not an essential >>>> element of the cause of action and section 32(1)(c) is not triggered. >>>> >>>> Whilst Lord Walker's toying with Peter's 'Pyramid' at [158] is >>>> interesting, I wonder whether it is consistent with the result he >>>> reaches. Only if the mistake, at the base of the pyramid, triggers >>>> the absence of legal ground higher up is it an essential part of >>>> the cause of action (eg a contract of sale where the price has been >>>> paid but th subject matter does not exist.) >>>> >>>> Lord Hoffmann sees the point, I think, but I am puzzling over his >>>> answer, at [22] >>>> >>>> "That does not seem to me inconsistent with the existence of the >>>> mistake not being essential to the cause of action but merely one >>>> example of a case which falls within a more general principle, just >>>> as one could have (say, for the purposes of limitation) a category >>>> called "clinical negligence" without implying that it is a cause of >>>> action different in nature from other kinds of negligence." >>>> >>>> He is saying, I think, that mistake need not be an essential part >>>> of the cause of action for the purposes of section 32(1)(c), but I >>>> am not sure I follow his reasoning as to why not. If anyone can >>>> help me out I'd be grateful. >>>> >>>> (3) On whether there was a mistake the differences between Lords >>>> Hoffmann and Hope are those which where ascertainable from KB v >>>> Lincoln. Hoffmann is quite explicit in deeming there to be a >>>> mistake where the law has changed because of judicial decision >>>> ([23]) as he admits, this can be read as supporting the Birks view >>>> ([28]) that it is better not to try and square this with the >>>> orthodox approach that the transfer is vitiated by any mistake >>>> present in the claimant's mind, but rather to accept that the true >>>> basis of recovery is absence of legal ground. Lords Hope and Walker >>>> seem to me to place more emphasis on finding a real mistake. >>>> >>>> (4) Lord Brown's point will have to be paid for by some litigant in >>>> the future. >>>> >>>> (5) The shame is that a lot of time and effort has been spent >>>> rebutting the argument from 'exclusivity' which deservedly went >>>> down 5-0, when counsel's time, and their Lordships lengthy >>>> speeches, would more profitably have been spent focusing on other >>>> issues. >>>> >>>> Robert Stevens >>>> Barrister >>>> Fellow and Tutor in Law >>>> Lady Margaret Hall >>>> University of Oxford >>> >>> >>> >>> Professor Charles Mitchell >>> School of Law >>> King's College London >>> Strand >>> London WC2R 2LS >>> >>> tel: 020 7848 2290 >>> fax: 020 7848 >>> 2465___________________________________________________________________ _ >>> This message was delivered through the Restitution Discussion Group, >>> an international internet LISTSERV devoted to all aspects of the law >>> of unjust enrichment. To subscribe, send "subscribe enrichment" in >>> the body of a message to >>> . To unsubscribe, send "signoff >>> enrichment" to the same address. To make a posting to all group >>> members, send to >>> . The list is run by Lionel Smith >>> of McGill University, >>> . >> >> >> >>-- >>Jason Neyers >>January Term Director >>Associate Professor of Law >>Faculty of Law >>University of Western Ontario >>N6A 3K7 >>(519) 661-2111 x. 88435 >> >> -- Jason Neyers January Term Director Associate Professor of Law Faculty of Law University of Western Ontario N6A 3K7 (519) 661-2111 x. 88435 ____________________________________________________________________ This message was delivered through the Restitution Discussion Group, an international internet LISTSERV devoted to all aspects of the law of unjust enrichment. To subscribe, send "subscribe enrichment" in the body of a message to . To unsubscribe, send "signoff enrichment" to the same address. To make a posting to all group members, send to . The list is run by Lionel Smith of McGill University, . --Boundary_(ID_1eztAXhZ7TghLyigesUxTA) Content-type: text/html; charset=us-ascii Content-transfer-encoding: 7BIT Dear Charles:

In regard to 2a: I guess I don't accept the legal fiction part of it, the judges are for the most part stating what they think the law always demanded based on what the other rules already say or what constitutional documents already say (including EU law).  I agree with Peter Watts when he said: "It amazes me how readily modern appellate judges think they change the law".  It only seems fictional when you apply subjective concepts of mistake which are dependent on non-legal facts like common understandings at points in time. 

In regard to 2b:  I think that there was a jurisitic reason/basis for the enrichment so side with Lord Scott.  If there is to be recovery it is on the basis that the state committed a legal wrong of some sort (i.e. acted unconstitutionally in a wide sense).  That is why I said that UE is smaller but tighter.

Cheers,


Charles Mitchell wrote:
Dear Jason

I'm not sure I think that absence of basis reasoning would allow us to avoid either of the difficulties I describe under headings 2a and 2b.  So far as 2a is concerned, where C pays correctly believing that a rule of law requires him to do so, and the rule is subsequently overturned by judicial decision, would we not still be faced with the question whether the basis for C's payment should be deemed by application of a legal fiction not to have existed at the time when the payment was made?  And so far as 2b is concerned, would we not still be faced with the problem that the payment made by DMG was due under a valid statutory section?

Best wishes
Charles


At 11:01 30/10/2006 -0500, Jason Neyers wrote:
Dear Charles:

The difficulties you have with the mistake analysis show why absence of basis is the simplest most coherent view of unjust enrichment.  Although the province of  UE would be smaller under this view, what was covered would hold together better.

Cheers,

Charles Mitchell wrote:
Stimulated by Rob s comments I have a few further thoughts about the case:

(1) The "cause of action" issue: does English law recognise a restitutionary claim for tax paid under a mistake of law?

I share Rob s view that the CA s treatment of this issue was weak and unconvincing.  Jonathan Parker LJ s methodology was very strange.  However, it doesn t follow from the fact that the CA did a poor job that no respectable arguments can be marshalled to support the proposition that recovery of ultra vires tax payments should be governed by an exclusive regime .  The public character of tax authorities, and the special nature of the relationship between citizen and state, might lead one to conclude that such claims are sufficiently different from claims between private individuals that they should be fenced off and treated differently.  Rebecca Williams has developed this line of thought more eloquently and expertly than I can manage, and I m not sure that I find it completely convincing: it troubles me, for example, that the public/private borderline is so fuzzy that cases would often arise where it was unclear whether or not the claim fell within the scope of an exclusive regime.  Without pursuing this any further, though, I would just say that it may not be entirely fair to counsel for the IRC to suggest that they relied solely on the CA s narrow textual approach: at [131]ff Lord Walker indicates that arguments from principle were also made, albeit that he and the others seem to have found these unconvincing.


(2) The "mistake" issue: did DMG make the payments of ACT under a mistake of law?

(a) Do judicial decisions changing the law retrospectively render payments made in line with the old law mistaken? 

The HL were obliged to say yes in light of KB v Lincoln.  In my view, however, the majority s reasoning in KB was deeply flawed because the reach of legal fictions cannot be determined by taking them at face value and discovering in them an inherent logic which they do not possess.  In KB the majority started with the fiction that the effect of a case reversing a previous decision is retrospectively to make the law governing the relationship between the parties different from the law which actually governed their relationship at the time when they entered it.  It can be argued that this fiction is defensible because without it, the court could not adjust the parties relationship in a way that ex hypothesi the court now considers appropriate; moreover, litigants would otherwise have no incentive to press for changes to the law, as they would be unable to take personal advantage of such changes.  But these reasons do not necessarily hold good when it asked whether the fiction of retrospective legal change also affects the relationship between other people who were not parties to the case.  If the pursuer in Donoghue had had an auntie who paid her money because she felt sorry for her and correctly believed at the time when she made the gift that the pursuer had no claim in tort against the defender, the question whether the auntie should be allowed to recover the money because she should retrospectively be deemed to have made a mistake can be sensibly answered only by starting from first principles: it won t do simply to say one fiction fits all and that the auntie must have been mistaken because retrospective changes to the law must affect everybody if they are going to affect anybody.  But if the majority in KB had a better reason than this for its findings on retrospective mistakes then I can t find them; nor can I find anything in DMG which makes me feel better, notwithstanding Lord Hoffmann s attempt to cheer me up at [23] by saying that the mistake in a retrospective mistake case is a 'deemed' mistake.  I guessed that!  The question is why should the claimant be deemed to have made a mistake?  Answer: practical considerations of fairness .  Hey ho.


(b) Was DMG mistaken in its belief that the money was due?

I agree with Rob that this was the IRC s best point and that counsel seems to have blown it.  As Lord Scott holds (and as Monica Chowdry and I observed in [2005] RLR 1, at 16-18) DMG was not mistaken in its belief that a taxpayer which failed to make a group income election was liable to pay ACT: its mistake was to think that it was not entitled to make such an election.  This mistake led DMG not to make an election, with the inexorable result that the money was due.  This suggests that DMG s mistake was neither here nor there and that it shouldn t have been allowed to recover.  Otherwise a taxpayer who pays money pursuant to a completely valid tax regime might just as well say Oh I didn t realise that if I put my assets offshore I wouldn t have had to pay this tax, so now that my friendly accountant has explained this to me I should be entitled to a rebate because I paid under a mistake .

At first instance Park J recognised the problem at [25] but sought to get round it by holding that DMG would have made an election if it had known that it was entitled to do so, and then asserting that it followed from this that the money wasn t due.  This was a non sequitur.  In the CA Jonathan Parker LJ mistook the facts when he held at [231] that the regime gave rise to no obligation to pay because it was unlawful  the only bit of the statute which was unlawful was the bit which disabled DMG from making an election; DMG s liability to pay MCT in the event that it failed to make an election arose under a statutory section that was not unlawful at all.   In the HL Lord Hoffmann agrees with Jonathan Parker LJ at [32] and is wrong for the same reason.  He also dismisses Park J s recognition of the problem as rather sophisticated , a criticism echoed by Lord Walker at [143] ( over-analytical ).  Given the general expertise in tax law which they both undoubtedly possess (especially Lord Walker) I find this language surprising; they would have done better to heed the philosopher s advice endorsed by Lord Hope at [41]: Seek simplicity and distrust it.   However, at [62] while Lord Hope correctly rejects Jonathan Parker LJ s analysis, he also agrees with Park J, and is wrong for the same reason: the fact that there was an unbroken causative link between the mistake and the payment is true, but it still doesn t mean that the payment wasn t due (as Lord Scott correctly observes at [89]).

So I agree with Rob that much more should have been made of this - but still, I wonder whether there isn t an answer which the majority of the HL might have given in response to Lord Scott  - namely that the English courts were required by the ECJ in Metallgesellschaft at [96] to award restitution to parties in DMG s position in order to give full effect to its Article 52 rights, and that this direction mandated a departure from the rule that normally governs restitutionary claims in UE, that they are debarred by the existence of valid statutory rules requiring the claimant to pay the defendant.  I m afraid that my EC law isn t good enough to answer this question, but perhaps there is someone out there who knows the answer: where a statutory tax regime is made up of several interconnected sections, some of which are expressly declared void for incompatibility with the Treaty, but some of which are not, can an English court override the tax authority s right to keep money paid under one of the surviving valid sections on the basis that one of the void sections would otherwise be indirectly effective, contrary to the declaration of incompatibility?  (At [82] Lord Scott indicates that the answer is no !)

Charles



At 17:30 25/10/2006 +0100, Robert Stevens wrote:
A first response to DMG.

(1) Unsurprisingly, I think Lord Scott, a judge I have always held in the highest esteem, gets it right.

That said, I think counsel for the Revenue dropped the ball. Badly. It seems to have been conceded by counsel that a claim for restitution was available but only under Woolwich (see Lord Hoffmann at [7], Lord Walker at [117], [135]). Lord Scott seems to have taken the view he did without the assistance of argument on the point.

Normally, it is a good tactic when seeking to resist an appeal to the House of Lords to simply maintain that the Court of Appeal were right for the reasons they gave. However, in this case the arguments for an 'exclusive regime' in relation to ultra vires tax demands were so hopeless, and dependent upon a strained reading of the speeches of Lord Goff which the House of Lords were not bound by, that to seek to defend the result in the Court of Appeal based upon the reasons they gave was a serious mistake. Unsurprisingly, the Revenue went down 5-0 on this point.

Only Lord Hoffmann in the majority in what he describes as a footnote, briefly alludes to the point that the money was still payable, although the UK had behaved unlawfully as a matter of Community law. He agrees with the Court of Appeal, rejecting Park J's view, that there was no liability to pay, but gives no substantive reasons [32]. The Scot in the court, Lord Hope, very disappointingly agrees with Park J's interpretation of the legislation at [62], concluding that there was liability to pay but that this didn't matter as there was a causative mistake. The latter view cannot be right.

(2) Lord Walker seems to think that neither the correct interpretation of section 32(1)(c) nor the question of whether the claim was based upon mistake or absence of legal ground arose for resolution. However if we accept, as he seems to do at [146]-[147] that a mistake must be an essential element of the cause of action under section 32(1)(c), it is hard to see how the second question does not arise. In DMG the absence of legal ground, if there was one, was not triggered by the mistake but by the contravention of European Union law. If restitution follows where there is an absence of legal ground, the mistake made was not an essential element of the cause of action and section 32(1)(c) is not triggered.

Whilst Lord Walker's toying with Peter's 'Pyramid' at [158] is interesting, I wonder whether it is consistent with the result he reaches. Only if the mistake, at the base of the pyramid, triggers the absence of legal ground higher up is it an essential part of the cause of action (eg a contract of sale where the price has been paid but th subject matter does not exist.)

Lord Hoffmann sees the point, I think, but I am puzzling over his answer, at [22]

"That does not seem to me inconsistent with the existence of the mistake not being essential to the cause of action but merely one example of a case which falls within a more general principle, just as one could have (say, for the purposes of limitation) a category called "clinical negligence" without implying that it is a cause of action different in nature from other kinds of negligence."

He is saying, I think, that mistake need not be an essential part of the cause of action for the purposes of section 32(1)(c), but I am not sure I follow his reasoning as to why not. If anyone can help me out I'd be grateful.

(3) On whether there was a mistake the differences between Lords Hoffmann and Hope are those which where ascertainable from KB v Lincoln. Hoffmann is quite explicit in deeming there to be a mistake where the law has changed because of judicial decision ([23]) as he admits, this can be read as supporting the Birks view ([28]) that it is better not to try and square this with the orthodox approach that the transfer is vitiated by any mistake present in the claimant's mind, but rather to accept that the true basis of recovery is absence of legal ground. Lords Hope and Walker seem to me to place more emphasis on finding a real mistake.

(4) Lord Brown's point will have to be paid for by some litigant in the future.

(5) The shame is that a lot of time and effort has been spent rebutting the argument from 'exclusivity' which deservedly went down 5-0, when counsel's time, and their Lordships lengthy speeches, would more profitably have been spent focusing on other issues. 

Robert Stevens
Barrister
Fellow and Tutor in Law
Lady Margaret Hall
University of Oxford


Professor Charles Mitchell
School of Law
King's College London
Strand
London WC2R 2LS

tel: 020 7848 2290
fax: 020 7848 2465___________________________________________________________________ _ This message was delivered through the Restitution Discussion Group, an international internet LISTSERV devoted to all aspects of the law of unjust enrichment. To subscribe, send "subscribe enrichment" in the body of a message to <listserv@lists.mcgill.ca> . To unsubscribe, send "signoff enrichment" to the same address. To make a posting to all group members, send to <enrichment@lists.mcgill.ca >. The list is run by Lionel Smith of McGill University, <lionel.smith@mcgill.ca> . 


--

Jason Neyers

January Term Director

Associate Professor of Law

Faculty of Law

University of Western Ontario

N6A 3K7

(519) 661-2111 x. 88435

    

--

Jason Neyers

January Term Director

Associate Professor of Law

Faculty of Law

University of Western Ontario

N6A 3K7

(519) 661-2111 x. 88435
____________________________________________________________________ This message was delivered through the Restitution Discussion Group, an international internet LISTSERV devoted to all aspects of the law of unjust enrichment. To subscribe, send "subscribe enrichment" in the body of a message to <listserv@lists.mcgill.ca>. To unsubscribe, send "signoff enrichment" to the same address. To make a posting to all group members, send to <enrichment@lists.mcgill.ca>. The list is run by Lionel Smith of McGill University, <lionel.smith@mcgill.ca>. --Boundary_(ID_1eztAXhZ7TghLyigesUxTA)-- ======================================================================= == Date: Mon, 30 Oct 2006 17:48:20 +0000 Reply-To: Charles Mitchell Sender: Enrichment - Restitution & Unjust Enrichment Legal Issues From: Charles Mitchell Subject: Re: DMG In-Reply-To: <20061030163635.4D8FF9E079@webmail222.herald.ox.ac.uk> Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii"; format=flowed Re 2a: I'm afraid that I disagree with Jason and Robert that the only source of difficulty here is the artificiality of saying that the payor was mistaken. Problems also flow from the fact that the content of law is an objective social fact that can be determined at any given moment. The question whether the law requires X to pay Y in a given situation may sometimes be difficult to answer because the law is uncertain, but suppose that we know the answer because a judicial decision gives us a clear 'yes'. If X pays Y pursuant to the rule and then seeks to recover his payment, then Y can say that the rule established by the case constitutes a legal ground for the transfer. If X pays Y, and then in a different case the rule is overturned, it is fictional to say that X can now recover from Y because there never was a legal ground for X's payment because there never was a rule requiring the payment. To say that there is no fiction 'because the law can be changed with retrospective effect' (Rob) is mere assertion, and to say that 'the judges are for the most part stating what they think the law always demanded' (Jason) does not really meet the point. I don't deny that the courts (and Parliament) have the power to deem there never to have been a legal ground for X's payment if they want to - but I want them to tell me explicitly why they think this is a good idea, and I don't think it's wise to let them off the hook by telling them that repayment just follows 'automatically'. Best wishes Charles At 16:36 30/10/2006 +0000, Robert Stevens wrote: >Charles wrote > > I'm not sure I think that absence of basis reasoning would allow us to > > avoid either of the difficulties I describe under headings 2a and 2b. So > > far as 2a is concerned, where C pays correctly believing that a rule of > law > > requires him to do so, and the rule is subsequently overturned by judicial > > decision, would we not still be faced with the question whether the basis > > for C's payment should be deemed by application of a legal fiction not to > > have existed at the time when the payment was made? > >I don't think so. We don't need any fiction on the absence of basis model. >There is no doubt that the law can be changed with retrospective effect, >indeed this can be done by legislation. (A nice example is Commissioner of >State Revenue v Royal Insurance (1994) 182 CLR 51.)If that change means >that there is no legal ground, there is recovery. We don't have to worry >about the fact that at the time of the payment there was a legal ground. >We only need to worry about this if we feel compelled to squeeze the claim >into a mistake analysis. > > And so far as 2b is > > concerned, would we not still be faced with the problem that the payment > > made by DMG was due under a valid statutory section? > >Absolutely, indeed the problem is even more obvious. >Robert Stevens ____________________________________________________________________ This message was delivered through the Restitution Discussion Group, an international internet LISTSERV devoted to all aspects of the law of unjust enrichment. To subscribe, send "subscribe enrichment" in the body of a message to . To unsubscribe, send "signoff enrichment" to the same address. To make a posting to all group members, send to . The list is run by Lionel Smith of McGill University, . ======================================================================= == Date: Mon, 30 Oct 2006 13:51:59 -0500 Reply-To: Jason Neyers Sender: Enrichment - Restitution & Unjust Enrichment Legal Issues From: Jason Neyers Subject: Re: DMG Comments: To: Charles Mitchell In-Reply-To: <5.1.0.14.2.20061030164318.01329850@pop.kcl.ac.uk> MIME-version: 1.0 Content-type: text/plain; charset=ISO-8859-1; format=flowed Content-transfer-encoding: 7BIT How else could a legal system work in a world where judgment of action must follow those actions--i.e. where they cannot be done at the same time? If there was no retrospective effect there would be no true justice, so it is implicit in the act of judging. From the perspective of social fact, what is done is fictional, from the perspective of justice it is essential and true. I don't see why social fact should trump the juridical view on this point at all. Charles Mitchell wrote: > Re 2a: I'm afraid that I disagree with Jason and Robert that the only > source of difficulty here is the artificiality of saying that the > payor was mistaken. Problems also flow from the fact that the content > of law is an objective social fact that can be determined at any given > moment. The question whether the law requires X to pay Y in a given > situation may sometimes be difficult to answer because the law is > uncertain, but suppose that we know the answer because a judicial > decision gives us a clear 'yes'. If X pays Y pursuant to the rule and > then seeks to recover his payment, then Y can say that the rule > established by the case constitutes a legal ground for the transfer. > If X pays Y, and then in a different case the rule is overturned, it > is fictional to say that X can now recover from Y because there never > was a legal ground for X's payment because there never was a rule > requiring the payment. To say that there is no fiction 'because the > law can be changed with retrospective effect' (Rob) is mere assertion, > and to say that 'the judges are for the most part stating what they > think the law always demanded' (Jason) does not really meet the > point. I don't deny that the courts (and Parliament) have the power > to deem there never to have been a legal ground for X's payment if > they want to - but I want them to tell me explicitly why they think > this is a good idea, and I don't think it's wise to let them off the > hook by telling them that repayment just follows 'automatically'. > > Best wishes > Charles > > > > At 16:36 30/10/2006 +0000, Robert Stevens wrote: > >> Charles wrote >> > I'm not sure I think that absence of basis reasoning would allow us to >> > avoid either of the difficulties I describe under headings 2a and >> 2b. So >> > far as 2a is concerned, where C pays correctly believing that a >> rule of law >> > requires him to do so, and the rule is subsequently overturned by >> judicial >> > decision, would we not still be faced with the question whether the >> basis >> > for C's payment should be deemed by application of a legal fiction >> not to >> > have existed at the time when the payment was made? >> >> I don't think so. We don't need any fiction on the absence of basis >> model. There is no doubt that the law can be changed with >> retrospective effect, indeed this can be done by legislation. (A nice >> example is Commissioner of State Revenue v Royal Insurance (1994) 182 >> CLR 51.)If that change means that there is no legal ground, there is >> recovery. We don't have to worry about the fact that at the time of >> the payment there was a legal ground. We only need to worry about >> this if we feel compelled to squeeze the claim into a mistake analysis. >> >> And so far as 2b is >> > concerned, would we not still be faced with the problem that the >> payment >> > made by DMG was due under a valid statutory section? >> >> Absolutely, indeed the problem is even more obvious. >> Robert Stevens > > > ____________________________________________________________________ > This message was delivered through the Restitution Discussion Group, > an international internet LISTSERV devoted to all aspects of the law > of unjust enrichment. To subscribe, send "subscribe enrichment" in > the body of a message to . To unsubscribe, > send "signoff enrichment" to the same address. To make a posting to > all group members, send to . The list is > run by Lionel Smith of McGill University, . -- Jason Neyers January Term Director Associate Professor of Law Faculty of Law University of Western Ontario N6A 3K7 (519) 661-2111 x. 88435 ____________________________________________________________________ This message was delivered through the Restitution Discussion Group, an international internet LISTSERV devoted to all aspects of the law of unjust enrichment. To subscribe, send "subscribe enrichment" in the body of a message to . To unsubscribe, send "signoff enrichment" to the same address. To make a posting to all group members, send to . The list is run by Lionel Smith of McGill University, . ======================================================================= == Date: Mon, 30 Oct 2006 20:00:51 +0000 Reply-To: Robert Stevens Sender: Enrichment - Restitution & Unjust Enrichment Legal Issues From: Robert Stevens Subject: Re: DMG Comments: To: Charles Mitchell In-Reply-To: <5.1.0.14.2.20061030164318.01329850@pop.kcl.ac.uk> Content-Type: text/plain Content-Disposition: inline Content-Transfer-Encoding: 7bit MIME-Version: 1.0 Once we have accepted that the law can be changed with retrospective effect, I don't think it is important that as a matter of objective social fact the law was something different at the time of the facts as pleaded. This is nothing specifically to do with the law of unjustified enrichment but is a commonplace problem whenever the law is changed. If X does an action, which at the time of acting is not wrongful, but the law is changed with retrospective effect at some point in the future so that it becomes wrongful, X is a wrongdoer. It won't avail X to argue that "as a matter of social fact the law was different when I acted." So what? The problem is not that this is fictional: it isn't, although it would be fictional to say that X made a present mistake at the time of acting. The problem is that it appears to be contrary to the rule of law. If the law is changed with retrospective effect, X could not have ascertained at the time that he was committing a wrong. This problem is much more serious in the criminal law or the law of torts than it is in the law of unjustified enrichment where it is relatively tivial. This relates back to Peter Watts who wrote: "It amazes me how readily modern appellate judges think they change the law. Given that their primary function is to APPLY the law not change it, one would expect that they would hesitate long before exercising the constitutional power, if they have it all, to change the law." My view is that the truth is almost exactly the opposite of this. It is true that the sort of reasons that a court, including a Supreme Court, can bring to bear in reaching a decision are much more circumscribed than those of a legislature. But judges observably change the law. The common law is observably not the same as it was in 1700 and all of the changes cannot be ascribed to changes in society or the correction of mistakes. Someone changed it, and it wasn't elves. The role of the judge in interpreting the law is like that of a painter working on a vast canvas which has been, is being and will be worked on by others. The judge is trying to paint the best picture of the law that he can. The judge is not free, unlike a legislature, to whitewash over any area of the painting as he sees fit and start again. A judge is never painting on an entirely blank piece canvas. But, the best picture which can be painted changes. As the picture develops, as the strokes of judicial decisions are added over time, early work which once fitted may no longer do so and may need to be painted out. every judicial decision, however trivial, changes the law, even if only in an infinitesimal way. After DMG v IRC future judges are faced with a new picture that includes that decision. Even a banal decision which simply follows earlier authority adds strength to it which should influence future judges in deciding whether to continue to follow the standard set down. We must accept that the law changes as a result of judicial decisions. If such changes are given retrospective effect, which they are, so that they apply to events prior to the time of judgment, it must be accepted that our commitment to the rule of law is not absolute. Robert Stevens In message <5.1.0.14.2.20061030164318.01329850@pop.kcl.ac.uk> Charles Mitchell writes: > Re 2a: I'm afraid that I disagree with Jason and Robert that the only > source of difficulty here is the artificiality of saying that the payor was > mistaken. Problems also flow from the fact that the content of law is an > objective social fact that can be determined at any given moment. The > question whether the law requires X to pay Y in a given situation may > sometimes be difficult to answer because the law is uncertain, but suppose > that we know the answer because a judicial decision gives us a clear > 'yes'. If X pays Y pursuant to the rule and then seeks to recover his > payment, then Y can say that the rule established by the case constitutes a > legal ground for the transfer. If X pays Y, and then in a different case > the rule is overturned, it is fictional to say that X can now recover from > Y because there never was a legal ground for X's payment because there > never was a rule requiring the payment. To say that there is no fiction > 'because the law can be changed with retrospective effect' (Rob) is mere > assertion, and to say that 'the judges are for the most part stating what > they think the law always demanded' (Jason) does not really meet the > point. I don't deny that the courts (and Parliament) have the power to > deem there never to have been a legal ground for X's payment if they want > to - but I want them to tell me explicitly why they think this is a good > idea, and I don't think it's wise to let them off the hook by telling them > that repayment just follows 'automatically'. > > Best wishes > Charles > > > > At 16:36 30/10/2006 +0000, Robert Stevens wrote: > >Charles wrote > > > I'm not sure I think that absence of basis reasoning would allow us to > > > avoid either of the difficulties I describe under headings 2a and 2b. So > > > far as 2a is concerned, where C pays correctly believing that a rule of > > law > > > requires him to do so, and the rule is subsequently overturned by judicial > > > decision, would we not still be faced with the question whether the basis > > > for C's payment should be deemed by application of a legal fiction not to > > > have existed at the time when the payment was made? > > > >I don't think so. We don't need any fiction on the absence of basis model. > >There is no doubt that the law can be changed with retrospective effect, > >indeed this can be done by legislation. (A nice example is Commissioner of > >State Revenue v Royal Insurance (1994) 182 CLR 51.)If that change means > >that there is no legal ground, there is recovery. We don't have to worry > >about the fact that at the time of the payment there was a legal ground. > >We only need to worry about this if we feel compelled to squeeze the claim > >into a mistake analysis. > > > > And so far as 2b is > > > concerned, would we not still be faced with the problem that the payment > > > made by DMG was due under a valid statutory section? > > > >Absolutely, indeed the problem is even more obvious. > >Robert Stevens > > ____________________________________________________________________ > This message was delivered through the Restitution Discussion Group, > an international internet LISTSERV devoted to all aspects of the law > of unjust enrichment. To subscribe, send "subscribe enrichment" in > the body of a message to . To unsubscribe, > send "signoff enrichment" to the same address. To make a posting to > all group members, send to . The list is > run by Lionel Smith of McGill University, . > > ____________________________________________________________________ This message was delivered through the Restitution Discussion Group, an international internet LISTSERV devoted to all aspects of the law of unjust enrichment. To subscribe, send "subscribe enrichment" in the body of a message to . To unsubscribe, send "signoff enrichment" to the same address. To make a posting to all group members, send to . The list is run by Lionel Smith of McGill University, . ======================================================================= == Date: Tue, 31 Oct 2006 13:34:36 -0500 Reply-To: Neil Guthrie Sender: Enrichment - Restitution & Unjust Enrichment Legal Issues From: Neil Guthrie Subject: Serhan v. Johnson & Johnson MIME-Version: 1.0 Content-Type: multipart/alternative; boundary="----_=_NextPart_001_01C6FD1B.37C58C14" This is a multi-part message in MIME format. ------_=_NextPart_001_01C6FD1B.37C58C14 Content-Type: text/plain; charset="us-ascii" Content-Transfer-Encoding: quoted-printable The Ontario Court of Appeal has refused leave to appeal the decision of the Divisional Court (where the judges divided on the viability of a claim based on waiver of tort). See http://www.ontariocourts.on.ca/court_of_appeal/leave/2006index.htm (click on the 'refused' link). =20 Where this leaves us is not entirely clear: although the merits of such a claim might conceivably be determined in the Serhan class action, it is almost certain that the parties will settle before an actual trial of the issues. Other products liability claims have been drafted (or amended) to reflect Serhan, so perhaps the status in Ontario of waiver of tort will be decided in one of those. =20 Neil Guthrie =20 Stikeman Elliott LLP Toronto, Canada ____________________________________________________________________ This message was delivered through the Restitution Discussion Group, an international internet LISTSERV devoted to all aspects of the law of unjust enrichment. To subscribe, send "subscribe enrichment" in the body of a message to . To unsubscribe, send "signoff enrichment" to the same address. To make a posting to all group members, send to . The list is run by Lionel Smith of McGill University, . ------_=_NextPart_001_01C6FD1B.37C58C14 Content-Type: text/html; charset="us-ascii" Content-Transfer-Encoding: quoted-printable
The = Ontario Court=20 of Appeal has refused leave to appeal the decision of the Divisional = Court=20 (where the judges divided on the viability of a claim based on waiver of = tort).  See http://www.ontariocourts.on.ca/court_of_appeal/leave/2006index .h= tm (click on the 'refused' = link).
 
Where this leaves=20 us is not entirely clear: although the merits of such a claim might = conceivably=20 be determined in the Serhan class action, it is almost certain that the = parties=20 will settle before an actual trial of the issues.  Other = products=20 liability claims have been drafted (or amended) to reflect Serhan, so = perhaps=20 the status in Ontario of waiver of tort will be decided in one of=20 those.
 
Neil = Guthrie
 
Stikeman Elliott=20 LLP
Toronto,=20 Canada
____________________________________________________________________ This message was delivered through the Restitution Discussion Group, an international internet LISTSERV devoted to all aspects of the law of unjust enrichment. To subscribe, send "subscribe enrichment" in the body of a message to <listserv@lists.mcgill.ca>. To unsubscribe, send "signoff enrichment" to the same address. To make a posting to all group members, send to <enrichment@lists.mcgill.ca>. The list is run by Lionel Smith of McGill University, <lionel.smith@mcgill.ca>. ------_=_NextPart_001_01C6FD1B.37C58C14-- ======================================================================= == Date: Tue, 31 Oct 2006 20:45:24 -0500 Reply-To: davidcheifetz@rogers.com Sender: Enrichment - Restitution & Unjust Enrichment Legal Issues From: David Cheifetz Subject: Re: Serhan v. Johnson & Johnson Comments: To: Neil Guthrie In-Reply-To: <55504D3AB84D364ABC1025E5AB7F30715589BC@TORMEX.int.stikeman.com> MIME-Version: 1.0 Content-Type: multipart/alternative; boundary="----=_NextPart_000_0010_01C6FD2D.7D5B9F30" This is a multi-part message in MIME format. ------=_NextPart_000_0010_01C6FD2D.7D5B9F30 Content-Type: text/plain; charset="us-ascii" Content-Transfer-Encoding: 7bit So the Ont. CA didn't want to touch the waiver of tort issue in Serhan? That might be becase the CA didn't want to have to explain what it meant by what it said in 3COM v Zorin, June 2/06, Ontario CA http://www.ontariocourts.on.ca/decisions/2006/june/C41878.pdf While 3COM was argued as if it was only tort (deceit) case and as if the award was damages, and waiver of tort wasn't mentioned, look at what actually went on. The tort was deceit.My understanding is that there wasn't, in fact, any evidence that the goods could have been sold at any higher price than what they were sold for, even to the bad guys. That means there wasn't an actual loss, here, despite what the CA said. While the award was called damages, the bad guys were effectively forced to disgorge the difference between the price at which they purchased and the price at which 3COM (supposedly) would have sold to them if the truth had been told to 3COM: see para 56-57, specifically, the last few sentences of para 57. "The fact that we are dealing here with a diminution in profit rather than an actual loss matters not. If the appellants had provided the respondents with the true customers and places of shipment, the respondents would have been entitled to a higher price for their goods or to refuse to sell their goods at the prices they did. The appellants deprived the respondents of this choice and made a greater profit because they did so. It was not necessary, in the circumstances of this case, to introduce evidence of a specific alternative third party buyer. In essence, the appellants' first and second arguments amount to a submission that the difference between the SPQ and what 3Com's pricing would have been should remain with the appellants. The appellants' submission ignores the conceptual basis of tort law, which is restitutionary. The difference between the contract price and the price at which the appellants would otherwise have had to purchase the goods is a cost properly borne by the appellants." Exactly what was it about the case that made it evidence that an alternative buyer existed at the higher price. That it was a deceit claim? David Cheifetz Bennett Best Burn LLP _____ From: Enrichment - Restitution & Unjust Enrichment Legal Issues [mailto:ENRICHMENT@LISTS.MCGILL.CA] On Behalf Of Neil Guthrie Sent: October 31, 2006 1:35 PM To: ENRICHMENT@LISTS.MCGILL.CA Subject: [RDG] Serhan v. Johnson & Johnson The Ontario Court of Appeal has refused leave to appeal the decision of the Divisional Court (where the judges divided on the viability of a claim based on waiver of tort). See http://www.ontariocourts.on.ca/court_of_appeal/leave/2006index.htm (click on the 'refused' link). Where this leaves us is not entirely clear: although the merits of such a claim might conceivably be determined in the Serhan class action, it is almost certain that the parties will settle before an actual trial of the issues. Other products liability claims have been drafted (or amended) to reflect Serhan, so perhaps the status in Ontario of waiver of tort will be decided in one of those. Neil Guthrie Stikeman Elliott LLP Toronto, Canada ____________________________________________________________________ This message was delivered through the Restitution Discussion Group, an international internet LISTSERV devoted to all aspects of the law of unjust enrichment. To subscribe, send "subscribe enrichment" in the body of a message to . To unsubscribe, send "signoff enrichment" to the same address. To make a posting to all group members, send to . The list is run by Lionel Smith of McGill University, . ____________________________________________________________________ This message was delivered through the Restitution Discussion Group, an international internet LISTSERV devoted to all aspects of the law of unjust enrichment. To subscribe, send "subscribe enrichment" in the body of a message to . To unsubscribe, send "signoff enrichment" to the same address. To make a posting to all group members, send to . The list is run by Lionel Smith of McGill University, . ------=_NextPart_000_0010_01C6FD2D.7D5B9F30 Content-Type: text/html; charset="us-ascii" Content-Transfer-Encoding: quoted-printable
So the Ont. CA didn't want to touch the = waiver of tort=20 issue in Serhan? That might be becase the CA didn't want to = have to=20 explain what it meant by what it said in 3COM v Zorin, June = 2/06,=20 Ontario CA
 
ht= tp://www.ontariocourts.on.ca/decisions/2006/june/C41878.pdf< /F= ONT>
 
While 3COM was argued as if it = was only tort=20 (deceit) case and as if the award was damages, and waiver of tort = wasn't=20 mentioned, look at what actually went on. The tort was deceit.My = understanding=20 is that there wasn't, in fact, any evidence that the goods could have = been sold=20 at any higher price than what they were sold for, even to the bad guys. = That=20 means there wasn't an actual loss, here, despite what the CA said.  = While=20 the award was called damages, the bad guys were effectively forced to = disgorge=20 the difference between the price at which they purchased and the price = at which=20 3COM (supposedly) would have sold to them if the truth had been told to = 3COM:=20 see para 56-57, specifically, the last few sentences of para 57.=20
 
"The fact that we are dealing here with a = diminution in=20 profit rather than an actual loss matters not. If the appellants had = provided=20 the respondents with the true customers and places of shipment, the = respondents=20 would have been entitled to a higher price for their goods or to refuse = to sell=20 their goods at the prices they did. The appellants deprived the = respondents of=20 this choice and made a greater profit because they did so. It was not = necessary,=20 in the circumstances of this case, to introduce evidence of a specific=20 alternative third party buyer. In essence, the appellants’ first = and second=20 arguments amount to a submission that the difference between the SPQ and = what=20 3Com’s pricing would have been should remain with the appellants. = The=20 appellants’ submission ignores the conceptual basis of tort law, = which is=20 restitutionary. The difference between the contract price and the price = at which=20 the appellants would otherwise have had to purchase the goods is a cost = properly=20 borne by the appellants."
 
Exactly what was it about the case that made = it=20 evidence that an alternative buyer existed at the higher price. That it = was a=20 deceit claim?
 
David Cheifetz
Bennett Best Burn=20 LLP
 

From: Enrichment - Restitution & = Unjust=20 Enrichment Legal Issues [mailto:ENRICHMENT@LISTS.MCGILL.CA] On Behalf = Of=20 Neil Guthrie
Sent: October 31, 2006 1:35 PM
To:=20 ENRICHMENT@LISTS.MCGILL.CA
Subject: [RDG] Serhan v. Johnson = &=20 Johnson

The = Ontario Court=20 of Appeal has refused leave to appeal the decision of the Divisional = Court=20 (where the judges divided on the viability of a claim based on waiver of = tort).  See http://www.ontariocourts.on.ca/court_of_appeal/leave/2006index .h= tm (click on the 'refused' = link).
 
Where this leaves=20 us is not entirely clear: although the merits of such a claim might = conceivably=20 be determined in the Serhan class action, it is almost certain that the = parties=20 will settle before an actual trial of the issues.  Other = products=20 liability claims have been drafted (or amended) to reflect Serhan, so = perhaps=20 the status in Ontario of waiver of tort will be decided in one of=20 those.
 
Neil = Guthrie
 
Stikeman Elliott=20 LLP
Toronto,=20 Canada
_____________________________________________ __= _____________________=20 This message was delivered through the Restitution Discussion Group, an=20 international internet LISTSERV devoted to all aspects of the law of = unjust=20 enrichment. To subscribe, send "subscribe enrichment" in the body of a = message=20 to <listserv@lists.mcgill.ca>. To unsubscribe, send "signoff = enrichment"=20 to the same address. To make a posting to all group members, send to=20 <enrichment@lists.mcgill.ca>. The list is run by Lionel Smith of = McGill=20 University, <lionel.smith@mcgill.ca>. ____________________________________________________________________ This message was delivered through the Restitution Discussion Group, an international internet LISTSERV devoted to all aspects of the law of unjust enrichment. To subscribe, send "subscribe enrichment" in the body of a message to <listserv@lists.mcgill.ca>. To unsubscribe, send "signoff enrichment" to the same address. To make a posting to all group members, send to <enrichment@lists.mcgill.ca>. The list is run by Lionel Smith of McGill University, <lionel.smith@mcgill.ca>. ------=_NextPart_000_0010_01C6FD2D.7D5B9F30--