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11 August 2011
Issue: 7478 / Categories: Case law , Law digest , In Court
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Construction of deed

LB RE Financing No. 3 Ltd v Excalibur Funding No 1 plc and others [2011] EWHC 2111 (Ch), [2011] All ER (D) 22 (Aug)

The court’s task when addressing issues of construction was to ascertain the meaning which the instrument would convey to a reasonable person having all the background knowledge which would reasonably be available to the audience to whom the instrument was addressed. Identification of the relevant audience was important, because it served to identify the range of background facts relevant to interpretation. A distinction had to be made between commercial absurdity and irrationality and apparent unfairness or one-sidedness.

The former might compel the court to conclude that something had to have gone wrong with the language, but it was no part of the court’s task to mend businessmen’s bargains. Commercial absurdity might require the court to depart from the apparently unambiguous natural meaning of a provision in an instrument. Questions of commercial commonsense falling short of absurdity might, however, enable the court to choose between genuinely alternative meanings of an ambiguous provision. The greater the ambiguity, the more persuasive might be an argument

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MOVERS & SHAKERS

Jurit LLP—Caroline Williams

Jurit LLP—Caroline Williams

Private wealth and tax team welcomes cross-border specialist as consultant

Freeths—Michelle Kirkland Elias

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Flint Bishop—Deborah Niven

Flint Bishop—Deborah Niven

Firm appoints head of intellectual property to drive northern growth

NEWS
Talk of a reserved ‘Welsh seat’ on the Supreme Court is misplaced. In NLJ this week, Professor Graham Zellick KC explains that the Constitutional Reform Act treats ‘England and Wales’ as one jurisdiction, with no statutory Welsh slot
The government’s plan to curb jury trials has sparked ‘jury furore’. Writing in NLJ this week, David Locke, partner at Hill Dickinson, says the rationale is ‘grossly inadequate’
A year after the $1.5bn Bybit heist, crypto fraud is booming—but so is recovery. Writing in NLJ this week, Neil Holloway, founder and CEO of M2 Recovery, warns that scams hit at least $14bn in 2025, fuelled by ‘pig butchering’ cons and AI deepfakes
After Woodcock confirmed no general duty to warn, debate turns to the criminal law. Writing in NLJ this week, Charles Davey of The Barrister Group urges revival of misprision or a modern equivalent
Family courts are tightening control of expert evidence. Writing in NLJ this week, Dr Chris Pamplin says there is ‘no automatic right’ to call experts; attendance must be ‘necessary in the interests of justice’ under FPR Pt 25
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