Commercial Law - Implied Contractual Term - Letter of Engagement

The case of Weetwood Services Ltd v Ansvarcalculations for the two models had been provided,
Holdings Ltd [2007], concerned the implication of a termonly the results.
of a contract. The defendant occupied a site on whichThe claimant subsequently provided some further
it planned to develop a car showroom. It received aninformation, though not to the satisfaction of the
abatement notice from the local authority concerningdefendant, who refused to pay the fee of around
the unauthorised creation of a culvert for a stream on£5,000. The claimant then issued proceedings.
the site. The existence of the culvert affected theThe judge held that the limit of the claimant's obligation
planning permission for the proposed car showroom.under the letter of engagement was to provide the
It was the intention of the authority that the culvert beresults of the mathematical modelling, without more.
removed and replaced by an open channel stream.The defendant subsequently appealed.
The defendant engaged the services of the claimantThe issue was whether by the wording of the
engineering company to provide a report on theengagement letter, or by an implied term (the
culvert. The claimant was asked:defendant's alternative argument), the claimant had
- whether the culvert was capable of handling thebeen in breach of contract in failing to provide the
volume of water ever likely to pass through it (referredbasis of the results of the modelling which it had
to as the "1 in 100 year test"); andundertaken.
- whether the previous stream could be reinstatedThe appeal would be dismissed.
within a channel 10m wide along the north landing.It was held on appeal that on the true construction of
By the terms of the engagement letter, the claimantthe engagement letter, the claimant had not
undertook:undertaken to report the calculations involved in its
- To carry out a topographical survey;report, only the results. The suggested implied term
- To assess the catchment hydrology to give culvertwas therefore not necessary for business efficacy. It
inflow hydrographs for return periods of 5, 25, 50 andwas therefore decided that the purpose of the
100 years;engagement of the claimant was to determine the
- To build an HEC-RAS model of the watercoursepotential for flooding, which the information that the
with the culvert in place and with the replacementengineers had provided had done.
channel; and© RT COOPERS, 2007. This Briefing Note does
- To run the two models for the various return periodsnot provide a comprehensive or complete statement
and 'report on' the results.of the law relating to the issues discussed nor does it
In December 2001, the claimant provided a reportconstitute legal advice. It is intended only to highlight
which concluded that the culvert was inadequate. Thegeneral issues. Specialist legal advice should always be
defendant took the view that the report did not complysought in relation to particular circumstances.
with the letter of engagement, in that insufficient