Bolton v Mahadeva [1972]

Bolton v Mahadeva [1972] 2 All ER 1322 is a significant English contract law case that revolves around the concept of substantial performance of contractual obligations.

Mr Walter Charles Bolton undertook the installation of central heating in Mr T Mahadeva's house for a contracted sum of £560. However, the installed heating system proved to be inadequate, with issues such as uneven heat distribution and the emission of fumes. Despite the deficiencies, Bolton refused to rectify the problems, estimating the cost of correction to be £174. In response, Mahadeva refused to make any payment. Subsequently, Bolton initiated legal proceedings against Mahadeva.

The Brentford Deputy County Court judge, Sir Graeme Finlay, determined that Mahadeva was required to pay the contract price but with a deduction for the cost of fixing the heating system, totalling £446, including labour.

However, in the Court of Appeal, Sachs LJ held that Bolton was not entitled to any payment because there had been no substantial performance of the contractual obligations. Sachs LJ emphasised the general ineffectiveness of the work for its primary purpose, stating, "It is not merely that so very much of the work was shoddy, but it is the general ineffectiveness of it for its primary purpose that leads me to that conclusion".

The judgment underscores the importance of substantial performance in contractual matters. Even though work may have been undertaken, if it falls significantly short of fulfilling the primary purpose of the contract, it may be deemed as not substantially performed, affecting the entitlement to payment. The case highlights the courts' scrutiny of the effectiveness and quality of the work in determining the rights and obligations of the parties involved.
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