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Vick v Vogle-Gapes [2006]


  • Vogle-Gapes (principal) reduced the territorial scope of Vick’s (agent) activities
  • Vick sued for Vogle-Gape’s breach of his duty of good faith


  • What is the extent of the duties of good faith imposed by regulation 3 and 4 on agents and principals under the Commercial Agents (Council Directive) Regulations 1993? Was this duty breached?


  • To not act in a way calculated or likely to damage or destroy the agency relationship; no


  • Damages not payable
  • The reduction of territorial scope was reasonable in the circumstances
  • For the purposes of regulation 8, an agency agreement may specify the length of the reasonable time period
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