Int. J. Private Law, Vol. 6, No. 3, 2013 303
The way forward to tort recovery of pure economic
loss for defective premises in the UK
Sandy Sabapathy
Faculty of Business,
School of Accounting and Finance,
The Hong Kong Polytechnic University,
Hung Hom, Kowloon, Hongkong SAR, China
E-mail: sandy.sabapathy@polyu.edu.hk
Abstract: The current tort law in the UK is averse to the recovery of pure
economic loss for defective dwellings for reasons which are unconvincing and
unsustainable, especially in relation to a subsequent purchaser of a house which
has dangerous structural defects. Thus, a legitimate claimant is deprived of a
remedy in tort without valid justifications. This paper aims to evaluate and
analyse the relevant legislation namely the Defective Premises Act 1972 (the
DPA) and the Latent Damage Act 1986 (the LDA) in the light of the decision
of the House of Lords in Murphy v Brentwood District Council [1999] 1 AC
398. As a solution, the paper will stress on the need to amend the DPA and the
LDA as a positive way forward to change this arena of tort law which is unduly
stringent and restrictive.
Keywords: tort law; economic loss; Defective Premises Act; Latent Damage
Act.
Reference to this paper should be made as follows: Sabapathy, S. (2013)
‘The way forward to tort recovery of pure economic loss for defective premises
in the UK’, Int. J. Private Law, Vol. 6, No. 3, pp.303–314.
Biographical notes: Sandy Sabapathy received her LLB at the University of
London, PG Diploma in Intellectual Property Law at Queen Mary College,
University of London, LLM at University of Strathclyde, Glasgow Scotland,
Certificate in Legal Practice at University of Malaya and Doctor of Juridical
Science at City University of Hong Kong. She is a Lecturer of Law at The
Hong Kong Polytechnic University. She was also a part-time Lecturer at the
Faculty of Law of University of Hong Kong. Prior to joining the academia, she
was practicing as an Advocate and Solicitor in Malaysia. Her research interest
is on the law of tort, company law and intellectual property law.
1 Introduction
In Dutton v Bognor Regis UDC (Dutton)
1
and in Anns v Merton London Borough Council
(Anns),
2
the courts in the UK allowed tort recovery of expenses incurred by a subsequent
purchaser of a defective dwelling house (the claimant) to rectify the dangerous structural
defects therein brought about by negligent design and/or construction of the property.
These expenses were referred to as ‘material physical damage’ or ‘preventive damage’.
3
Anns discerned a parliamentary policy and held that the recovery of ‘physical damage’ or
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