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08 August 2014
Issue: 7618 / Categories: Case law , Law digest , In Court
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Contract

Lehman Brothers Finance S.A. (in Liquidation) v Sal Oppenhim jr. & cir. KGaA [2014] EWHC 2627 (Comm), [2014] All ER (D) 309 (Jul)

It was settled law that the identification of the non-defaulting party’s loss of bargain, arising from the termination of a derivative transaction, required a “clean” rather than a “dirty” market valuation of the lost transaction. That meant that the loss of bargain had to be valued on an assumption that, but for termination, the transaction would have proceeded to a conclusion, and that all conditions to its full performance by both sides would have been satisfied, however improbable that assumption might be in the real world. Thus, for the “value clean principle”, the conditions precedent as to payment, among other things, had to be deemed to have been satisfied. Otherwise no replacement transaction could be entered into, as there would be nothing to transfer to the new party, or only a transaction capable of being immediately terminated. The quotation was to be given for the replacement transaction on that basis. Quotations for replacement transactions were required to be obtained on or as soon as reasonably

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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

Freeths—Michelle Kirkland Elias

International hospitality and leisure specialist joins corporate team as partner

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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