UCL Faculty of Laws


Two Steps Forward, One Step Back

Two Steps Forward, One Step Back: One Step (Support) LTD v Morris‐Garner and Another

Holywell Bay beach. Tire tracks in the sand.

7 March 2019

Publication details

Bartscherer, Caspar (2019) 'Two Steps Forward, One Step Back: One Step (Support) LTD v Morris‐Garner and Another', Modern Law Review, 82(2), 367-376.


One Step is an important decision that deals with the circumstances in which a claimant may recover damages in contract on the so‐called Wrotham Park basis, valued as the amount that would hypothetically have been negotiated between willing parties to release the defendant from his obligation. This note argues that, although the Supreme Court was right not to award damages on this basis in this case, the test laid down by their Lordships for when such damages are available is unclear and will be difficult to apply.

Read the case note 

Image credit: © UCL Digital Media