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FHR European Ventures LLP v Cedar Capital Partners LLC
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1 User Commentary

Melanie Davidson (In-house lawyer) 28 September 2015

Case Digest: FHR European Ventures LLP and others (Respondents) v Cedar Capital Partners LLC (Appellant) [2014] UKSC 45

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Whether equitable remedy available to principal where bribe paid to agent

The Supreme Court handed down judgment in the matter of FHR European Ventures LLP and others (Respondents) v Cedar Capital Partners LLC (Appellant) [2014] UKSC 45 on 16th April 2014.

The appellants had acted as agents for the respondents in the purchase of sale capital from a third-party seller. The third party was alleged to have paid the appellants a bribe or commission in respect of the transaction. 

At first instance, the respondents' claim for recovery of the bribe was successful, but the Court had refused to grant the respondents a proprietary remedy in respect of the sum. The matter was appealed, and the Court of Appeal had found that the sum claimed was held on trust for the respondents and could be traced in equity. The appellants now sought to appeal to the Supreme Court.

Lord Neuberger, giving the only judgment in the matter, stated the principles applicable to a claim for proprietary remedies. While the principles were not in doubt, the extent to which they applied to a bribe was disputed by the parties.

An examination of the case law in the matter provided support for the respondents' submissions. While the cases of Metropolitan Bank v Heiron, 5 Ex D 319 and Lister & Co v Stubbs, 45 Ch D 1 did not follow this trend, the Supreme Court was satisfied these two cases should be regarded as overruled.

The appeal was therefore dismissed.


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