This site uses cookies.

When is an Offer Not an Offer? - Sarah Prager, 1 Chancery Lane

23/05/12. The Court of Appeal has recently explored whether, and to what extent, offers must be made in accordance with the provisions of CPR Part 36 if they are to have the consequences set out in that Rule. Sarah Prager explores the ramifications of the decision in PHI Group Limited v Robert West Consulting Limited [2012] EWCA Civ 588.


The claim

The claim arose out of works undertaken by Carillion JM Ltd. It was the main contractor engaged to carry out the design and construction of a train servicing depot to the west of the Wembley Football Stadium between 2004 and 2006. The appellant, PHI, was the specialist design and build contractor for what was called...

Image ©iStockphoto.com/

Read more (PIBULJ subscribers only)...


All information on this site was believed to be correct by the relevant authors at the time of writing. All content is for information purposes only and is not intended as legal advice. No liability is accepted by either the publisher or the author(s) for any errors or omissions (whether negligent or not) that it may contain. 

The opinions expressed in the articles are the authors' own, not those of Law Brief Publishing Ltd, and are not necessarily commensurate with general legal or medico-legal expert consensus of opinion and/or literature. Any medical content is not exhaustive but at a level for the non-medical reader to understand. 

Professional advice should always be obtained before applying any information to particular circumstances.

Excerpts from judgments and statutes are Crown copyright. Any Crown Copyright material is reproduced with the permission of the Controller of OPSI and the Queen’s Printer for Scotland under the Open Government Licence.