Court of Appeal
Manchester Ship Canal Co Ltd v United Utilities Water Ltd
United Utilities Water Ltd v Manchester Ship Canal Co Ltd
[2022] EWCA Civ 852
2022 March 29, 30, 31; June 27
Asplin, Arnold, Nugee LJJ
WaterSewerageDischargeUntreated effluent discharged into canal from sewerage undertaker’s outfalls following heavy rainfallWhether canal owner having private right of action against sewerage undertakerWhether such action inconsistent with statutory scheme for enforcement of sewerage undertakers’ duties Water Industry Act 1991 (c 56), ss 117(5), 186(3)[1]
WaterSewerageDischargeAgreement between canal owner and sewerage undertaker giving sewerage undertaker right to discharge water from its outfalls into canalRight terminable on notice from canal ownerWhether agreement ultra vires and voidWhether sewerage undertaker having continuing statutory right to discharge following termination of agreement Public Health Act 1875 (38 & 39 Vict c 55), ss 16, 18[2] Public Health Act 1936 (26 Geo 5 & 1 Edw 8, c 49), ss 15, 22[3]

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