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What must a statement of agreed facts contain?

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Published by a LexisNexis Dispute Resolution expert
Published on: 24 February 2016
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The TCC decision in the case of Amey Birmingham Highways Ltd v Birmingham City Council provides clear guidance to parties on drafting statements of agreed facts, which should:

  1. •

    rarely involve reference to the source documents behind the agreed facts

  2. •

    be limited to the material facts as alleged in the pleadings, and

  3. •

    not deal in detail with issues of admissibility or relevance

Amey—the facts

In a claim concerning the construction of a contract, the parties were unable to agree the terms of one paragraph of a case management order made by the court following a hearing. The parties therefore sought further directions from the

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