The case is succintly described by creditlaw.co.uk experts on Consumer Credit Law, "This strange case was incompletely recorded and may well have been incorrectly decided" . There are many other commentators, but we are particularly indebted to Credit Law for their kindness and because the site has a full listing of the Court of Appeal Judgment, http://www.creditlaw.co.uk/Cases/Natwest.htm
Referring to the "significance" of the existing regulation here, the Act's Draftsman, Mr Francis Bennion, has bravely spoken out against the ruling, (follow the hyperlink below to his writings on the case) because Lord Justice Auld found that the contractual purpose of the new Multiple Agreement here was "partly to replace existing borrowings and partly to provide new monies". Who better therefore, than Mr Bennion to clarify the intended effect of Section 18 (Multiple Agreements) to the new package of facilities that the Court allowed to successfully defeat the anti-avoidance mechanisms within Section 18 ?
The 1974 Act (together with subsequent secondary legislation) was passed for the multitude of reasons advocated by Lord Crowther in his 1971 white paper "Consumer Credit - Report of the Committee [Command 4596]". Lord Crowther found that of all the contracts where consumer abuse occurred, by far the most cases occurred within moneylending. Banks had been exempted from the draconian documentational requirements of the old Moneylending Acts because of their status. Lord Crowther deemed this exemption as unsatisfactory, that a level lending field must be created and maintained. As he prophetically put it, discussing the exemption,
"........to the individual consumer faced with problems of the kind envisaged by protection legislation, it is little solace to know that the other party is a bank"
Lord Crowther's white paper was highly critical of the existing Common Law as it applied to moneylending; it had become vague and subjective - and the outcome to a particular commonplace dispute would be decided upon the preferred choice of precedents before the Court. Lord Crowther recommended "a sweeping review" of the law, to correct the mischief in the Common Law with a standardised approach to common problems experienced by both Consumers and Creditors - the Act is not one-sided, its whole aim being to create a level lending field where transparency ruled the day; that "truth in lending" would prevail.
The new legal framework was intended to make obsolete, to repeal, and did make obsolete, repealed, but for the decision here, the Common Law into Consumer Credit - where the new law is to apply - a point not lost on our Common Law Judges. The decision here effectively takes control for (consumer) moneylending cases away from Parliament. This is highly unsatisfactory, as Section 8 clearly demonstrates. Parliament decided that moneylending law was not an issue for the Common Law Courts - consequently, sole jurisdiction was granted to the County Court as a designated court of competence. Here, where the case was cleverly bundled up as a common law claim by the bank and placed before the High Court, Section 141(2) of the CCA deems the action as "improperly brought" where it was not transferred immediately to the County Court from the High Court, once it was clear to that Court that there was a CCA defence to the common law claim.
Lord Crowther's report is a very interesting read indeed. It is highly recommended for anyone who wishes to study this important area of social law.
Watch this space:-
Further applications to the Court(s) to reopen the case are in the pipeline.
Please register your support (or otherwise) ! (email address below). Responses may well be posted.