Supreme Court
Devani v Wells
[2019] UKSC 4
2018 Oct 11; 2019 Feb 13
Lord Wilson, Lord Carnwath, Lord Briggs, Lord Kitchin JJSC, Lord Sumption
ContractFormationImplied termParties agreeing orally that estate agent introduce buyer for vendor’s propertiesNo express agreement as to event triggering agent’s entitlement to commissionWhether parties’ bargain completeWhether agreement containing term providing for payment of commission on completionWhether legitimate to imply such term so as to convert incomplete bargain into legally binding contract
AgencyEstate agentContractEstate agent breaching statutory obligation to inform client of prospective liabilitiesAgent applying for enforcement of contract notwithstanding breachWhether just to dismiss agent’s applicationWhether commission to be reduced to compensate client for prejudiceProper approach to agent’s “culpability” and “prejudice” to client Estate Agents Act 1979 (c 38), s 18(6)

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