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Thomas Aubrey James Needham v The Master and Fellows of the College of the Great Hall of the University of Oxford

28 June 2023
[2023] EWHC 1591 (KB)
High Court
A student had mental health problems that stopped him from finishing his degree at Oxford. The college tried to help him, but he still couldn't finish. The court said the college did nothing wrong, so the student lost the case.

Key Facts

  • Claimant (Needham) sued Oxford University College for breach of contract regarding his MChem degree.
  • Needham experienced significant mental health issues (depression, anorexia) throughout his studies, leading to multiple deferrals.
  • The College provided various support measures, including mentors and flexible exam arrangements.
  • Needham ultimately failed to complete his degree due to ongoing mental health challenges and missed crucial examinations (Collections).
  • The claim focused on alleged breaches of contract after August 2011 (due to statute of limitations).
  • The College's actions were judged based on whether they acted reasonably in providing educational services.

Legal Principles

Implied terms in contracts for services require reasonable care and skill (Supply of Goods and Services Act 1982, s13).

Supply of Goods and Services Act 1982

Courts generally do not interfere with academic judgments regarding student performance or course viability.

Clark v University of Lincolnshire and Humberside [2000] 1 WLR 1988, Abramova v Oxford Institute of Legal Practice [2011] EWHC 613 (QB)

Contractual terms, including college regulations, are legally binding.

College Handbook of Information and Regulations 2010-2011

Limitation periods apply to contract claims.

Outcomes

Claim dismissed.

The College acted reasonably in providing support and adhering to contractual procedures. The claimant's failure to complete his degree stemmed from his own mental health challenges and inability to meet exam requirements, not the College's actions. The relevant contractual provisions were not breached, and any academic judgments made were not subject to judicial review.

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