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No more deemed fulfilment: The Supreme Court decision in King Crude Carriers SA v Ridgebury November LLC
Elliot Grosvenor-Taylor
9 December 2025
No more deemed fulfilment: The Supreme Court decision in King Crude Carriers SA v Ridgebury November LLC
The recent Supreme Court judgment in King Crude Carriers SA and others v Ridgebury November LLC marks a significant development in English contract law.
The decision arose from an appeal against an arbitration award and addresses the fundamental question of whether the so called “deemed fulfilment” principle established by the 1881 Scottish Appeal case of Mackay v Dick exists in English Law.
8 December 2025
2025 in Review: Civil Fraud
In 2025, two High Court rulings, Apollo XI Ltd v Nexedge Markets Ltd and J&J Snack Foods Corp & ICEE Corp v Ralph Peters & Sons Ltd highlighted the strict nature of the duty of full and frank disclosure in without notice applications.
In both cases, the court discharged freezing injunctions after finding that the applicants had failed to meet the requisite standard of candour and fair presentation. These decisions serve as a clear reminder that when seeking urgent relief without notifying the other party, applicants must present all material facts - including those that may undermine their case, and ensure the court receives a balanced and accurate account.
3 December 2025
Victims of Fraud Series Part 4: Tracing issues in crypto assets cases
Claims involving digital assets (including crypto assets) have become relatively common in the English Courts over the last five years and, as a result, the main areas of disagreement between the parties to those disputes are starting to emerge. A major theme is the methodology that should be applied to the tracing and following of digital assets.
1 December 2025
It was all a sham
Assets are typically placed in a trust for legitimate purposes, such as safeguarding wealth for future generations. However, arguments that a trust is in fact a “sham” created to hide the true ownership of assets often arise in the context of divorce litigation, bankruptcy/insolvency where a creditor seeks to argue that a trust is a pretence seeking to shield assets from creditors, or in estate disputes, where beneficiaries look to bring assets of the deceased back into an estate.
27 November 2025
Victims of Fraud Series Part 3: “What can I do if the fraudster has disappeared?” - Persons Unknown Injunctions
Where the identity of a person or group of people responsible for a fraud is not known, the courts have recognised that it may be appropriate in certain circumstances to allow a claimant to issue proceedings and obtain an injunction (both interim and final) against such individuals. These injunctions are referred to as “persons unknown injunctions” and they have become increasingly prominent in recent years.
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