Court of Appeal
Potter v Canada Square Operations Ltd
[2021] EWCA Civ 339
2021 Jan 19, 20, 21; March 11
Sir Julian Flaux C, Males, Rose LJJ
Limitation of actionBreach of dutyConcealment of factsCredit relationship between claimant and defendant unfair because of defendant’s failure to disclose fact and extent of commission paymentClaimant becoming aware of commission more than six years after end of credit relationshipWhether claimant’s claim for statutory remedy time-barredWhether commencement of limitation period postponed on basis facts “deliberately concealed” by defendantWhether non-disclosure of commission amounting to concealmentWhether defendant deliberately committing “breach of duty” so as to give rise to concealmentWhether recklessness sufficient to establish requisite mental element for deliberateness Consumer Credit Act 1974 (c 39), s 140A Limitation Act 1980 (c 58), s 32(1)(2)

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