- In Manchester Building Society v Grant Thornton UK LLP [2021] UKSC 20 the Supreme Court abandoned the rigid SAAMCO ‘advice/information’ categories in favour of a purpose-based test
The Supreme Court’s judgment in Manchester Building Society v Grant Thornton UK LLP [2021] UKSC 20 was a watershed in negligence law. For over 20 years, practitioners had navigated professional liability using the binary framework of South Australia Asset Management Corp v York Montague Ltd [1997] AC 191 (SAAMCO), distinguishing between ‘advice’ cases, where the professional is responsible for all foreseeable consequences of a transaction, and ‘information’ cases, where recovery is limited to the consequences of the information being wrong. The decision in Manchester Building Society v Grant Thornton swept that distinction away.
The Supreme Court introduced a new principle: the scope of a professional’s duty is defined by the purpose of the advice or service provided, assessed objectively. This was more nuanced
