Wright, Johnston & Mackenzie Solicitors

Has Twitter Undermined Interdicts?

An interdict is an order of the court requiring the person or organisation to whom it is addressed to desist from a wrong he or she is committing or refrain from a wrong he or she is about to commit. The English equivalent of an interdict is an injunction. It works in the same way as an interdict albeit the scope of an injunction is broader than an interdict.

Last month an injunction by a firm of English Solicitors, Carter Ruck, on behalf of their clients was undermined by the micro-blogging website, Twitter. The English High Court had granted an injunction preventing the media from reporting on a particular question tabled by an MP in the House of Commons relating to alleged dumping of toxic waste by an oil company. There was widespread outrage in the media and civil liberties’ groups at what was viewed as a draconian “gagging order”.

However, the Guardian newspaper published an article vaguely telling readers that a “super-injunction” had been imposed restricting its right to publish details relating to the parliamentary question. Then the awesome power of social networking kicked in. Individuals began tweeting with each other to locate the parliamentary question and once that was found; they were again off searching for the parliamentary report mentioned in the question. Within a few hours, the name of the oil company, Trafigura, was the most tweeted word in the world! The injunction had been rendered useless and Trafigura’s solicitors, Carter Ruck, soon admitted defeat and dropped it.

The decision by Carter Ruck was greeted with whooping and cheering by thousands of Twitterers and the editor of the Guardian posted via his Twitter account: “Thanks to Twitter/all tweeters for fantastic support over past 16 hours! Great victory for free speech!”.

It certainly was a great victory for free speech. Could this be the canary down the mine for Scots law? If circumstances occurred in Scotland then solicitors would find themselves in a similar position to Carter Ruck, being powerless to stop the information spreading. While an injunction against a newspaper is pretty straightforward, it becomes a lot tougher dealing with thousands of Twitter users who cannot in a practical sense be sued for passing on information. Even if Twitter or Facebook were served with interdicts, there are an enormous number of similar websites or applications, which would allow the information to be shared.

However, it is even tougher in Scotland to obtain an interdict as Scottish media organisations unlike their English counterparts, have caveats lodged with the Scottish Courts. The caveats act as an early warning system, which enables the media organisation’s lawyers to be alerted to the action and argue the case at a hearing before a decision is taken. The hearing in an open Court of Law leaves the applicant vulnerable to publicity that would make life even easier for Twitter users to pass the information around until the intended purpose of the interdict is rendered futile. 

The majority of interdicts are not about parliamentary privilege and it is most likely that they will continue to serve a purpose in certain circumstances relating to so-called “gagging orders” but generally speaking will undoubtedly become less effective in this new social networking environment.

Perhaps one of the most famous Tweeters, Stephen Fry, highlights what the rich and powerful are up against now when dealing with savvy Twitter users in his tweet on the issue: “Carter-Ruck caves in! Hurrah! Trafigura will deny it had anything to do with Twitter, but we know don’t we?”. Don’t worry Stephen, we know.

More information from Neil Morrison: .(JavaScript must be enabled to view this email address)

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Directors' Duties & Conflict of Interest

The recent Court of Session hearing in the case of Commonwealth Oil & Gas Company (COG) v Nicholas W Baxter and Eurasia Energy Limited (EEL) concerned the duties of directors where a conflict of interest arises. The case concerned a geophysicist who was a director of the Pursuers and then became a director, the president and chief executive officer of the Second Defenders while retaining his other director position.

Mr Baxter entered into an exclusive one year agreement, on behalf of the Second Defenders, with the state oil company of the Azerbaijan Republic (SOCAR) for rights to negotiate an agreement to explore and develop large areas of the Caspian sea.

However, the Pursuers, COG, soon became aware that their director had entered into an agreement on behalf of a rival public company, EEL, and were unhappy at his involvement. They sought to negotiate an arrangement where both companies would have an interest in the Caspian Sea project. Mr Baxter proceeded to resign as director from COG. The President of the state oil company then informed Mr Baxter that the negotiating agreement had expired and that no further negotiations would take place.

The Pursuers raised an action against the First Defender on the basis that if he had brought the agreement with SOCAR to their attention, there is a high likelihood they would have successfully negotiated with SOCAR and developed the Caspian Sea oilfields. The Pursuers argued that both Defenders were liable in damages because of Mr Baxter’s breach of his fiduciary duty as a director and EEL’s knowing receipt of a commercial opportunity brought to it by Mr Baxter.

The famous Scottish authority of Aberdeen Railway Co v Blaikie Bros from the mid-nineteenth century established that when a person is a director of a two companies with competing interests, any contract between the companies shall be invalid unless there has been complete disclosure of the director’s interests to the first company and the first company consents to its director pursuing his own interest in the second company. There have been more recent English cases where the case circumstances have been able to show that the director with a conflict of interests was excluded by the other directors of the first company and so it had impliedly released him from his fiduciary duty and consented to him pursuing his own interests in the second company.

Mr Baxter’s Counsel attempted to argue that because he was a non-executive director, he had no fiduciary duty to the Pursuers unless he was specifically asked by the Pursuers to do something. This argument did not hold any weight with the Inner House of the Court of Session who reiterated that a director’s fiduciary duty of loyalty is owed to the company as a whole and the duty extends to avoiding a conflict of interest. So even if Mr Baxter was not acting dishonestly by failing to tell the Pursuers about the agreement with SOCAR, he was under a duty to take appropriate steps to avoid a conflict of interest.

The Inner House did not go as far as to say there is a positive duty on a director to disclose the SOCAR agreement to the Pursuers but that there was certainly a duty on a director to seek consent to pursue their own interests in another company. Mr Baxter did not do this and accordingly was found to be in breach of his fiduciary duty.

The outcome of the hearing is a useful reminder that directors should always be aware that when they have competing interests in different companies, they are under a duty to request consent from one of the relevant companies to pursue interests although whether the director must disclose a commercial opportunity to the other company may depend on the circumstances of the case. 

More information from Andrew Wilson: .(JavaScript must be enabled to view this email address)

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Shaken, not shtirred: Unauthorised Agency

If your average person on the street was asked about agents or agency; he or she might think of James Bond and Martini cocktails, rather than a specific legal relationship between two parties where one acts on behalf of the other. Who could blame our man or woman on the street for not instinctively thinking of agents or agency in the legal context? It really is an area of the law that lurks in the shadows until certain circumstances suddenly present themselves. It is probably not very surprising to learn most of the Scottish cases relating to agency were back in the 18th or 19th century. However the law of agency is still a vital mechanism should the necessary circumstances arise.

During recessions, there are more rogues around who may fraudulently act as agents of businesses and then abscond with goods or money leaving the buyer of goods or third party with nothing. Also there are more companies looking to evade their legal obligations who may argue they are not liable for the contract as their agent exceeded their authority. What legal solution does the poor ripped off buyer or third party have when an agent disappears and the business (the principal) says their agent wasn’t authorised to contract with them? Well using the law of agency, in particular the legal action of “apparent or ostensible authority”, they can go after the deep pockets, the business, who the agent was apparently representing; even if the apparent middleman was not even authorised by the business to work for them.

What are the legal hurdles that need to be overcome to use “apparent or ostensible authority”? Firstly, the principal through representation or conduct has to have given the impression that the fraudulent agent is apparently authorised by them. The most common representation is allowing the fraudulent agent to act in the management or conduct of the principal’s business. Inaction on the part of the principal may amount to conduct. Controversially in the First Energy UK case, even an agent’s position as senior manager in a branch office within a company has been held as a representation.

Secondly, the principal’s representation or conduct must have induced the third party to believe that the agent was authorised. So if there were tell-tale signs from the nature of the transaction or the agent’s behaviour that there was something fishy going on and any reasonable person would have declined to contract unless certain safeguards were in place; then the third party’s action may likely fail.

Thirdly, the third party must have relied upon the representation. The third party’s belief must be reasonable; so if an agent gives you a suspiciously low price for goods which you do not question or requests you send him or her a blank cheque for payment of goods then the third party’s action may likely fail.

Finally, the third party must have suffered a loss through their reliance on the principal’s representation or conduct. Normally the third party will have lost money paid for goods not delivered or goods that are not fit for purpose.

If all four hurdles can be overcome then apparent or ostensible authority can be used to bar the principal from denying the existence of the agent’s authority and will bind them to the contract with the third party so the money can be recovered from the principal.

More information from Neil Morrison: .(JavaScript must be enabled to view this email address)

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Companies Act 2006– We read the 700 pages for you...

At over 700 pages long and containing some 1300 sections, the Companies Act 2006 (the “Act”) is the single largest piece of legislation ever made in the UK. The Act has been implemented in stages over the last 3 years and the final sections of the Act came into force on 1st October 2009.

Some of the key changes introduced by the Act are as follows: -

Codification of directors’ duties, including a new duty to promote the success of the company;

Promoting shareholders’ engagement and a long-term investment culture through enhancing the power of proxies and enfranchising indirect investors;

Simplifying and de-regulating the legal requirements for running private companies through measures such as simplification of capital maintenance provisions, abolishing of the prohibition on financial assistance for private companies purchasing their own shares etc.;

Extending rights of shareholders to sue directors for negligence and other defaults and rights to bring derivative claims on behalf of the company in certain circumstances;

Introducing measures to allow companies to limit the liability of their auditors;

Simplifying the company formation process including abolishing the requirement for authorised share capital.

Below is an explanation of some of the most important changes:

The Act has for the first time codified directors’ fiduciary duties under s170 – s181. These are generally based on the pre-existing fiduciary duties that have always applied to directors, but in some cases go further.

Private companies will no longer need to hold an AGM, unless they are required to do so by their articles of association.

Shareholders can demand a shareholder meeting if at least 10% (5% where there has been no meeting in any 12 month period) of the shareholders wish to.

It is now usually necessary to give 14 (rather than 21) clear days notice of any meetings, unless articles of association state otherwise.

Written resolutions no longer need to be signed by all the shareholders. Instead, the required majority will be similar to that for the shareholders meetings – a simple majority of the eligible votes for ordinary resolutions, or 75% for special resolutions.

Written resolutions can also now be circulated by email or other electronic means such as websites, if the members of the company consent to this.

The previous statutory rule that companies cannot give financial assistance for the purchase of their own shares has been abolished for private companies.

Previously, private companies who wished to give such financial assistance had to comply with a “whitewash” procedure. The new arrangements should make transactions easier.

It will be possible for auditors to limit their liability by agreement with a company to cover liability for negligence, default, breach of duty and breach of trust. Members’ approval will be needed by resolution for such a liability limitation agreement to be effective. An agreement will not be effective to limit an auditor’s liability to less than an amount that is fair and reasonable.

From 1st October 2009, a new company will no longer need to have a maximum authorised share capital. Therefore, if the articles of association of the company permit, shares can be allotted freely without the need for a shareholders resolution amending the authorised share capital.

In order to reduce the time and expense involved in restoring the company, the Act introduces a new administrative procedure for the restoration of a company to the register by a director or shareholder after it has been struck off by the Registrar for failure to file returns and/or accounts. However, it does not apply where a company is struck off after voluntary application by the directors; in those cases it is still necessary to apply to the court for restoration.

They also change the period in which restoration must be applied for to 6 years except where the application is for the purpose of bringing proceedings against the company for damages for personal injury.

Phew! That’s enough information for now!

More information from Lyndsey Cavanagh: .(JavaScript must be enabled to view this email address)

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Swearing Spaniard Wins Unfair Dismissal Case!

Imagine after an argument with your boss you finish by calling him or her “a son of a bh”; you would expect to get fired, wouldn’t you? Recently in Spain, this very scenario happened; the employee and his manager had a discussion about pay which soon turned into a heated argument and the employee said to his manager’s face “you are a son of a bh” (the literal translation of “hijo de puta”is actually a lot stronger than that!) and told two other employees that the manager was mad.  Unsurprisingly, the employee was sacked on the spot by his manager for gross misconduct.

The employee took his employer to a Catalonian Employment Tribunal and lost. However he appealed to the Superior Court of Justice of Catalonia who decided that his dismissal had been unfair and awarded him reinstatement or damages of €6,500. The judges based their decision on the fact that although the employee had used insulting phrases, and should certainly have been disciplined; dismissal was clearly a disproportionate sanction.

Spanish law has recognised that in order for an employer to justify dismissing an employee for verbal abuse, it must be a serious offence, which must affect the person abused by the employee. The Catalonian Court also has to take into account the circumstances surrounding the dismissal such as when and where the incident occurred, the employee’s employment contract and the employee’s level of education. The Supreme Court weighed up all the factors and felt the balance was tipped in favour of the employee. One of the Supreme Court Judges observed that the decline in the social use of language had lowered the offensive nature of the insults used by the employee and that these words were now commonly used in arguments. 

The Judges added that for a verbal insult to justify dismissal, it had to be a head-on confrontation with the intention of seriously affecting the victim’s honour.  Dismissal for less serious insults such as “chorizo” or “coward” have been considered proportionate in previous cases before the Supreme Court. It really depends on the context in which the insults were made and the intention of the employee as to whether the dismissal can be deemed fair or not. The Catalonian Judges concluded that in the case before them, the insults did not amount to that and the dismissal was therefore disproportionate.

The ruling by the Catalonian Supreme Court will no doubt raise eyebrows in the United Kingdom. A Scottish Employment Tribunal would be unlikely to find a dismissal unfair in similar circumstances to the Spanish case, especially if the language was of a threatening nature. Although the Tribunal would likely find that the employer believed that the employee was guilty of misconduct due to the insults, it is unlikely that dismissal would fall outwith the range of reasonable responses available to a reasonable employer. It will be interesting to see whether the “decline in social use of language” argument is used by Scottish Employment Tribunals to justify unfair dismissals where the employee has been dismissed for verbal insults to his or her superior.

The safest approach to take should any incidents of verbal abuse occur between employee and employer is to delay dismissal and take time to assess whether dismissal would be the appropriate sanction for the level or type of insults used. Dismissing an employee in the heat of the moment for an insult could turn out to be a costly decision if it is later found to be unfair. It should also be remembered that each case will turn upon its own facts and a wise employer should seek legal advice at the earliest opportunity to ensure the matter is dealt with appropriately so that legal costs can be kept to a minimum.

More information on Spanish legal matters from Neil Morrison: .(JavaScript must be enabled to view this email address)

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Charity Loses Out on Significant Business Rates Discount!

A recent judicial review hearing in the Outer House of the Court of Session concerned whether a charity, the English Speaking Union Scottish Branches Educational Fund, who are tenants of an eight storey building but only use one floor of the building, could obtain 80% Business Rates discount in terms of local government legislation.

The charity relied on the local government legislation that provided for 80% Business Rates discount when: (1) a building was occupied by a charity; and (2) wholly or mainly used for charitable purposes. They argued that as they were a charity, occupied the building, and since the only use of the building, the building was wholly used for charitable purposes.

If the charity’s argument succeeded, there would be wide-ranging implications because then landlords with no occupants could rent out their building to a charity for a nominal rent and not pay Business Rates on an unoccupied building; perhaps coming to a mutually advantageous arrangement with the charity. 

The Respondents, City of Edinburgh Council, argued that the word “wholly used” was not synonymous with “solely used”. The Outer House was not persuaded that an office building which is unused for any purpose on seven of eight floors is “wholly used” for the purpose for which the one floor is actually in use does not accord with common sense and any other conclusion would have been unreasonable.

However the Court did not rule out that the discount would not apply if there were large areas of a building vacant for substantial periods of time if certain circumstances justified the discount. For example, if the charity in this case found demand for studying English changed dramatically from term to term and at certain times they needed more workspace than usually required then the only way to ensure they had the capacity would be to have parts of the building vacant for periods of time. Lord Bonomy contrasted the example with the present case and observed: “[to] put the majority of the building to no use at all, and effectively to mothball it, was something quite different”.

Lord Bonomy also gave examples of stadium stands and churches as other buildings, which may be largely unused for most of the time but could be considered as “wholly used” for a particular purpose such as sports events in the case of the stadium or specific days of worship in respect of the church. Taking into account the various reasons such as interpretation of the statutory words and common sense, the Court refused the charity’s petition.

It is clear from the Outer House’s decision that charities may be able to rely on the discount if they have vacant space within their building, which is used from time to time depending on demand for their services. However where there is no intention or evidence of the vacant parts of the building being used then it is unlikely that a Court would find the charity eligible for charitable Business Rates discount.

More information from Andrew Wilson: .(JavaScript must be enabled to view this email address)

 

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Can a Salesman's Sales Banter Amount to Negligent Misrepresentation?

In the recent Sheriff Court case of McCalls Limited v Capture Imaging Limited, the Sheriff was asked to decide whether a salesman’s sales banter amounted to negligent misrepresentation. The case concerned the Pursuers, a highland dress outfitters based in Aberdeen, who were contacted by the director of the Defenders, who are a printing, copying and document management company. The Pursuers advised the Defenders’ director that their existing Canon printer was beginning to deteriorate.

The Pursuers used their printer to print promotional material demonstrating the tartans available for hire and sale. The colour accuracy of the printer was of great importance to the company as many customers used the brochure photos to decide upon dresses and tartans for weddings.

Representatives of the Pursuers met the Defenders at a meeting to discuss buying a new printer to replace the old printer. The Defenders’ director told the Pursuers that the Konica printers his company sold were “the best machines on the market” and that the Konica printer “would far exceed the quality of their current Canon”.

The Pursuers entered into a contract with the Defenders to lease the Konica printer from them relying on the statements made by the Defenders’ director. The new printer was delivered and immediately the Pursuers expressed their dissatisfaction with the quality of the colour prints. The Pursuers were unable to print any promotional material themselves for 6 months when an upgraded replacement was provided. However due to the commencement of legal proceedings, they were unable to use the replacement and so outsourced their printing for one year. The Pursuers raised an action of negligent misrepresentation under common law against the Defenders based on their director’s statements to the Pursuers at the sales meeting.

At the hearing, the Defenders’ director advised the Court that he acted honestly and that his comments were his own personal opinion based on information provided to him by the printer manufacturer, Konica Minolta.

In order to prove negligent misrepresentation, the Pursuers needed to overcome five hurdles: (1) that the statements made were representations; (2) that they were misrepresentations i.e they were false; (3) that the false representations were negligently made; (4) that the Pursuers relied upon the representations in entering the contract and; (5) prove that in the circumstances, the Defenders owed the Pursuers a duty of care. 

An action for negligent misrepresentation could have been raised under s.10 of the Law Reform (Misc Provisions) (Scotland) Act 1985. There is no need for any special relationship or special knowledge or skill on the party making the misrepresentation. However the Pursuers instead opted for the common law. The common law is founded on the famous case of Hedley Byrne & Co Ltd v Heller & Partners Ltd where the House of Lords held that a party will be liable for negligent misrepresentation where a duty of care arises from a special relationship. The Scottish common law position is that unless the representation is fraudulent, damages are not recoverable.

The Sheriff in the McCalls case found that the Defenders’ statements were representations but that the Defenders’ director was under no duty of care because he had not professed to have a special knowledge or skill on the issue in question, namely the quality of prints of tartans from the two machines. He also added that he did not think the Pursuers could be induced merely on the word of a salesman and should have made further inquiries themselves about the quality of the prints prior to entering into the contract. The Pursuers also failed to prove on the balance of probabilities that the Defenders statements were false as they did not provide sufficient evidence to prove the Konica printer would not exceed the quality of the Cannon printer which the Sheriff noted would require a significant amount of printer quality information.

For the various reasons set out above the Sheriff found that the Pursuers had failed to prove negligent misrepresentation. This case illustrates that unless a salesman professes to have special knowledge or skill relating to the issue in the statements then no duty of care arises under the common law. A salesman could however be found liable under a statutory action of negligent misrepresentation as there need be no special knowledge or skill professed. However a duty of care would still need to be proved which is more difficult when the Defender is not a professional and in addition, the other hurdles set out above will require to be overcome which may be hard to accomplish.

Before jumping the gun and raising an action for negligent misrepresentation, it is sensible to seek legal advice so the circumstances can be assessed to ensure that any action raised will overcome the all the legal hurdles.

More information from Fraser Gillies: .(JavaScript must be enabled to view this email address)

 

 

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Banks Win Overdraft Charges Test Case!

In recent years, thousands of bank consumers in the UK have been reclaiming their bank overdraft charges through the County and Sheriff Courts. However in order to resolve the issue, the Office of Fair Trading (OFT) and the UK’s eight main banks raised a test case in the English High Court in July 2007; to determine whether the OFT would be allowed to investigate the fairness of charges for unauthorised overdrafts. All the English court cases were frozen pending the decision. However in Scotland some cases were allowed to proceed as a few Sheriffs observed that the OFT decision would not necessarily address Scots common law. 

The OFT was victorious in both the High Court and Court of Appeal but to the shock of many commentators, consumer action groups and general public; the banks won the test case in the UK Supreme Court. Many people will find the decision difficult to comprehend as surely charging customers £39 for exceeding their overdraft limit when it only costs the bank £2.50 is unfair?

Well unfortunately it’s not quite as simple as that. The banks argue that the charges amount to 30% of their revenue (some £2.6 billion) and the charges are an essential part of the bargain between a consumer and the bank when a contract is made. The banks further argue that the charges were the consumers’ side of the bargain, and in return, they were provided with a package of banking services. 

The UK Supreme Court was asked to decide whether overdraft charges were exempt from assessment of fairness by Regulation 6(2) of the Unfair Terms in Consumer Contracts Regulations 1999. The regulation says that the assessment of fairness shall not relate to whether the price is reasonable when compared to the services supplied in exchange.

The Supreme Court Judges found that the Court of Appeal had not interpreted the regulation correctly and that the charges were an essential part of the bargain, in effect, the price, for the banking services even though they are dependent on the consumer going overdrawn and the majority of consumers do not incur them. The Judges argued that as the charges amounted to 30% of the banks’ income then they clearly were an essential part of the contract between the banks and the consumers.

So that it’s over then? Not quite. Lord Phillips left consumers with some hope when he said that Regulation 5 could apply to a complaint that the banks’ charges overall were excessive in exchange for the package of services the consumer receives.

Consumers who have waited a number of years will be very disappointed by the Supreme Court’s decision but there may yet be more twists and turns in this saga should the OFT pursue the avenue highlighted by Lord Phillips. We shall wait and see.

More information from Neil Morrison: .(JavaScript must be enabled to view this email address)

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You Couldn’t Make It Up…

After the hard slog of reading our informative legal articles, time to sit back and let a wry smile spread across your face as you enjoy some funny news from the global legal community. As St Andrew’s Day is at the end of this month, the news comes from Scotland!

CLEANER ‘ASSAULTS HIMSELF’ TO AVOID WORK

A hotel cleaner has been fined £100 for wasting police time after attacking himself with a boulder and a razor in order to avoid going to work.

The cleaner told Grampian police that he had been assaulted, but later admitted that he had faked the attack because he wanted a day off. The cleaner who is now unemployed, later said that he should have asked his work for a day off instead.

Fiscal depute Jim Craigen said:

“He was making his way to work and didn’t really much fancy going.

“He therefore removed a razor from his pocket and repeatedly dragged it down his face. He also picked up a boulder and struck it off his head and repeatedly hit himself on the head and body.”

Mr Craigen added: “He went to the police station and said he had been assaulted by two male persons who repeatedly punched and kicked him.”

Defence solicitor Keidra Morrison said the first-time offender had been under stress.

Sheriff Graeme Buchanan said it was a “pretty bizarre act”.

Wright, Johnston & Mackenzie LLP would like to acknowledge the source of the news, which came from BBC Scotland.

 

 

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WJM’s Commercial Dispute Resolution Team

When you see a legal fight on the horizon, whether it involves you personally or your business, your best advice is to “lawyer up”. Many lawyers approach such problems by focusing on the court as the only way to end the argument if people cannot agree.

At WJM, we focus on solving arguments in the most appropriate way for our clients’ needs and the problem that they have. We will look at your problem and approach it in the best way for you, identifying a cost effective and sensible solution where your costs are not disproportionate to the value of the claim you are facing.  In many cases negotiation and mediation are often as effective as litigation and we will not jump straight to litigation if there is a better way of approaching the problem.

‘Commercial’ doesn’t mean we just act for businesses. It means that we focus on solutions which take into account the needs of your bottom line, whether in your own business or from your own pocket.

More information from Liam Entwistle: .(JavaScript must be enabled to view this email address) or Andrew Wilson: .(JavaScript must be enabled to view this email address)

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Employment Briefing

You may also be interested in WJM’s Employment Briefing which offers regular updates on employment news and views. If you’d like a copy delivered straight to your PC, please email .(JavaScript must be enabled to view this email address) with the title “Employment Briefing” in the subject line.

For further information on these or any other dispute related issues, please contact:

Liam Entwistle .(JavaScript must be enabled to view this email address) 0141 248 3434
Andrew Wilson .(JavaScript must be enabled to view this email address)  0131 221 5560

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