Wickham Holdings Ltd v Brooke House Motors [1967] 1 WLR 295

Facts

  • The case involved a dispute over the assessment of damages following conversion, where the defendant wrongfully sold vehicles owned by the claimant.
  • The main issue was the proper date for valuing damages in a claim involving conversion of goods.
  • The Court of Appeal was called upon to clarify the appropriate measure of damages for the tort of conversion, particularly regarding the assessment date.
  • The defendant’s actions constituted conversion, involving intentional interference inconsistent with the claimant’s possessory rights.

Issues

  1. Whether damages for conversion should be assessed at the date of the conversion or at a later date, such as the date of judgment.
  2. Whether exceptions to the general rule on the assessment date could apply when special circumstances are demonstrated.
  3. What valuation methods are appropriate for determining the market value of the converted goods.

Decision

  • The Court of Appeal held that damages for conversion are generally assessed at the date of conversion.
  • It was affirmed that, unless exceptional circumstances exist, the value of the goods as of the conversion date serves as the primary reference point.
  • The court recognized that exceptions to the general rule may be permitted, such as when the claimant can show a higher value would have been realized at a later date or where additional losses were caused by the defendant’s conduct.
  • The judgment provided clarification on the principles governing the valuation of goods in conversion claims, emphasizing predictability and consistency in awarding damages.

Legal Principles

  • Conversion is a strict liability tort consisting of intentional interference with another's possessory rights to goods.
  • The assessment of damages in conversion aims to restore the claimant to the position they would have been in but for the wrongful interference.
  • The market value of the goods at the date of conversion is typically the benchmark for damages.
  • Exceptions to the date rule may apply where it is just to depart from the conversion-date valuation, subject to judicial discretion.
  • Valuation methods may involve market evidence, expert valuations, or alternative calculations like replacement cost where relevant.

Conclusion

Wickham Holdings Ltd v Brooke House Motors established that damages in conversion cases are typically assessed at the date of conversion unless clear evidence demonstrates the need for an alternative approach, thereby providing consistency in tort law while maintaining flexibility to achieve fairness in unique cases.

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