Carl Harrison v Andrea Elaine Buchanan & Anor

Decision date: 17 December 2025

Neutral citation: [2025] EWHC 3283 (IPEC)

Overall AI summary confidence: high

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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: high

This case concerned whether Mr Carl Harrison had a binding agreement to create technical drawings for Andrea and Mr Buchanan and what sum was payable. The judge found an oral agreement made on or shortly after 22 May 2022 and awarded Mr Harrison €15,000 (converted with interest to £13,880) for breach of contract. The defendants' contention that the drawings were unfit for purpose was rejected for lack of evidential basis. No order as to costs.

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

An oral agreement to prepare and supply commissioned technical drawings can be established by contemporaneous and post-contractual correspondence and gives rise to a contractual obligation to pay; and a defendant seeking to rely on an implied term (such as fitness for purpose) must adduce sufficient evidence both of the criteria for implying the term and of non‑satisfaction—unsupported external assessments are insufficient.

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 judge expressed reluctance to allow concurrent recovery for payment for a licence under copyright and damages for lack of a licence (not finally determined). The judge also noted limited documentary comparisons made it more likely that CAD drawings supplied abroad were based on Mr Harrison’s drawings, though the copyright claim was not pursued to determination.