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Watts v Morrow

[1991] 1 All ER 937

Case summary last updated at 04/01/2020 14:07 by the Oxbridge Notes in-house law team.

Judgement for the case Watts v Morrow

A surveyor, D, told P of the value of a house, but failed to report many defects, causing them to undertake costly repairs and suffer inconvenience when the repairs were occurring. CA said that the aim of compensation was to put the owners in as good a position as they would have been, had there been no breach of contract. Therefore D had to pay the difference between the actual value of the house and the value as D represented it to be. On the question of inconvenience-based damages, CA said that in the case of the ordinary surveyor's contract general damages were recoverable only for distress and inconvenience caused by physical consequences of the breach of contract and that the compensation for the physical inconvenience should be a modest sum. 

Bingham LJ: In general, for policy reasons, "A contract-breaker is not in general liable for any distress, frustration, anxiety, displeasure, vexation, tension or aggravation” that his breach causes, except where the contract’s purpose is to “provide pleasure, relaxation, peace of mind or freedom from molestation”. A surveyor’s contract does not fall within that category. However for cases not falling within that category, “physical inconvenience and discomfort caused by the breach and the mental suffering directly related to that inconvenience and discomfort” can be compensated, albeit with “modest” awards. 

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