Beacon Cymru Group Ltd (formerly Coastal Housing Group Ltd) v Mitchell

Subject Matter

LANDLORD AND TENANT — Occupation contract — Landlord’s obligations — Landlord failing to comply with statutory obligation to give contract-holder electric condition report within stipulated time — Whether contract-holder consequently entitled to withhold rent — Whether rent paid as result of mistake of law — Whether landlords unjustly enriched by retaining rent paid — Renting Homes (Fitness for Human Habitation) (Wales) Regulations 2022 (SI 2022/6), reg 6 — Renting Homes (Supplementary Provisions) (Wales) Regulations 2022 (SI 2022/23), reg 11

[2025] EWHC 2477 (Ch); [2025] WLR(D) 498, DC

AI Summary & Issues

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In Beacon Cymru Group Ltd and Others v. Mitchell and Others, the High Court dismissed the defendants' counterclaims for repayment of rent, ruling that the defendants continued to pay rent despite the landlords' failure to provide electrical condition reports (ECRs). The court determined that the defendants' payments were not made under a mistake of law, as they would have paid rent regardless of the ECR issue. Therefore, the claimants were not unjustly enriched, leading to the dismissal of the counterclaims.

Issues

• Did the defendants pay rent because of a mistake of law regarding the requirement for electrical condition reports, which affected their obligation to pay rent?
• Was the claimants' retention of the rent unjustly enriching them, given that the defendants received the benefits of their housing despite the late provision of the electrical condition reports?
• Is a claim for unjust enrichment unavailable to the defendants due to the existence of a subsisting contractual relationship with the claimants, which governs their obligations and rights?

Commentary

Nearly Legal
Actually, there needn’t (necessarily) be consequences Case comment