C&P Haulage Co Ltd v Middleton [1983]

Court: Court of Appeal

Facts: Middleton held a license to occupy a property for his car repair business. He was ejected by C&P Haulage for breaching the contract, and he sought damages for improvements made to the property. Middleton argued that he was entitled to recover the cost of these improvements as wasted expenditure.

Issue: Whether damages for wasted expenditure can exceed the financial position the claimant would have been in had the contract been performed.

Held: The court awarded Middleton nominal damages, ruling that compensating him for wasted expenditure would place him in a better financial position than if the contract had been performed. The court reiterated that damages should not overcompensate the claimant.

Key Judicial Statement: Ackner LJ emphasized that reliance loss (wasted expenditure) cannot exceed expectation loss, and the courts should not grant damages that put the claimant in a better position than if the contract had been performed.

💡Leveluplaw: Reliance damages are limited by expectation loss. Claimants cannot recover more in damages than they would have gained from the proper performance of the contract.