214 Bermondsey Street Limited v Crispin Corfe & Ors
Decision date: 2 March 2026
Neutral citation: [2026] UKUT 96 (LC)
Overall AI summary confidence: medium
Short overview
This short overview is intended to summarise the case, issues and outcome so far as they are supported by the judgment.
AI confidence in this short overview: medium
This appeal concerned whether four service-charge invoices for fire-safety work at 214 Bermondsey Street were recoverable. The First-tier Tribunal allowed one invoice, disallowed another (not appealed) and rejected two Assessed Risk invoices; the Upper Tribunal found the FTT had overlooked explanations in the appellant's pleadings and should have given the appellant an opportunity to address a new substantive point the FTT raised, set aside those conclusions, and remitted the question of what reduced sum (if any) is reasonably payable given the FTT's adverse finding about the poor quality of the Assessed Risk report.
Ratio decidendi
This summary is intended to identify the ratio decidendi, meaning the legal reasons for deciding and the binding part of the decision.
AI confidence in this ratio decidendi summary: medium
From the judgment as recorded in the notes: (1) a tribunal must take into account explanations contained in a party’s pleaded case in the case bundle and not disregard them as non-evidence without basis; and (2) a tribunal should not introduce a new substantive ground for disallowing costs (here, criticizing the choice of contractor) without giving the affected party an opportunity to respond. These principles led to setting aside the FTT conclusions about the Assessed Risk invoices.
Obiter dicta
This summary is intended to identify obiter dicta, meaning observations made by the way that were not necessary to deciding the case and are not binding.
AI confidence in this obiter dicta summary: medium
The notes record observations that pleaded explanations in a statement of case may suffice as material to be considered even if not separately served as evidence, and that contractor dissolution or invoicing/VAT anomalies do not, without more, preclude recovery where explanations are provided and work was performed. These comments appear as non-binding observations rather than central holdings.