Caselaw Digest
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Management Information Centre Limited v Royal Berkshire NHS Foundation Trust

[2023] EWHC 3497 (Ch)
A company sued an NHS trust for ending their IT contract early. The NHS trust said it was a short-term deal; the company said it was a long-term deal with more notice needed. The judge said there's enough doubt to let the case go to trial to see who is right.

Key Facts

  • Management Information Centre Limited (MICL) provided IT services to Royal Berkshire NHS Foundation Trust (RBFT) from 2015 to 2022.
  • RBFT terminated the services in June 2022, engaging Techfull Limited (a company formed by MICL's former directors).
  • MICL claims unlawful termination, alleging a contract with a nine-month notice period or breach of good faith.
  • RBFT argues that MICL worked on project-by-project contracts with no notice requirement.
  • MICL's claim is hampered by deleted emails and missing documentation due to the actions of its former directors.
  • The case involves disputes over the existence and nature of the contract (oral, written, implied, relational), notice periods, and standard terms and conditions.
  • A draft Call-Off contract was negotiated but never executed, and this played a role in the arguments.

Legal Principles

Summary Judgment - CPR 24.2

Civil Procedure Rules

Striking out a statement of case - CPR 3.4

Civil Procedure Rules

Practice Direction 16 - Particulars of Claim based on written or oral agreements

Civil Procedure Rules Practice Direction 16

Implied duty of good faith in relational contracts

Bates v Post Office Ltd (No.3: Common Issues) [2019] EWHC 606 (QB)

Summary judgment should not be granted unless the court is certain the claim is bound to fail; consideration of evidence reasonably expected at trial.

Easyair Limited v Opal Telecom Limited [2009] EWHC 339 (Ch); A C Ward & Son Ltd v Catlin (Five) Ltd [2009] EWCA Civ 1098; Swain v Hillman [2001] 1 All E.R. 91; ED & F Man Liquid Products Ltd v Patel [2003] EWCA Civ 472; Royal Brompton Hospital NHS Trust v Hammond [2001] EWCA Civ 550; Doncaster Pharmaceuticals Group Limited v Bolton Pharmaceutical Company [2007] FSR 3; ICI Chemicals & Polymers Ltd v TTE Training Limited [2007] EWCA Civ 725

Outcomes

Application for summary judgment and/or strike out refused.

The court found that while the claimant's case is weak, it has a real prospect of success, particularly given the missing documentation and potential for further disclosure. Amendments to the Particulars of Claim were ordered to clarify certain aspects.

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