1069 - 1746

...Smith v Hughes & Home Concerns (Scotland) Limited

Court of Session, Outer House 14 December 2007

In December 2007 Lord Brodie heard an opposed motion for a jury trial in the case of Smith v Hughes & Home Concerns (Scotland) Limited. The pursuer in that case was injured in a road accident. It seems to have been accepted that she was rendered permanently unfit to return to her previous employment as a carer or indeed any other employment. The fundamental uncertainties about future employment prospects which feature in Slessor and O'Neill were not present in the Smith case. The defenders opposition here was on narrower grounds focussing on the lack of detail in presentation of the claims for future promotion prospects and future services.

In relation to future promotion all that was said was at the time of the accident the pursuer had recently been promoted to supervisor and that but for it she had "prospects for further promotion".

In relation to services all that was said was the pursuer had and continued to receive services from her husband and daughter. A statement of valuation of claim had been lodged in which a figure of £94,000 was attributed to future services based upon a certain number of hours each day for life but no explanation was given of what the services would be or why they were necessary.

The pursuer's advisors argued that in terms of the Chapter 43 rules they were required in their pleadings to do little more than identify the heads of claim that she was putting forward. It was suggested that Lord Brodie could take account not only of what was said in the written case but also what was in the statement of valuation.

However Lord Brodie decided that notwithstanding the changes introduced by Chapter 43 the parties still required to give fair notice and that would normally require some detail in the pleadings both of what the head of claim was and how it was to be made up. As he put it "the pleadings should be in such a form as clearly to convey what the case is about to their two direct audiences, the other party and the judge:... when it comes to questions purely of quantification then the pleadings may be supplemented by what appears in the statement of valuation of claim but it would seem appropriate, and, in a jury trial, convenient to be able to ascertain from a party's pleadings what it is that a party seeks and the factual basis upon which he seeks it".

In relation to what was said about future promotion prospects on being told that nothing more could be added Lord Brodie had no hesitation in excluding this head of claim as irrelevant.

In relation to the future services the pursuer's advisors indicated that they could provide more detail to address the concerns raised and Lord Brodie therefore continued consideration of the motion for jury trial to allow this to be done.

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