Mitfam v Motley: Dispute over Cashew Nut Payments and Contract Breach

In a dispute before the High Court of Singapore on 16 December 2013, Mitfam International Ltd sued Motley Resources Pte Ltd for US$395,666 for raw cashew nuts sold. Motley admitted the debt but counterclaimed for US$486,553.33 in alleged overpayments and damages for breach of two cashew nut contracts. The court, Judith Prakash J, found that Motley failed to prove the overpayments but established a partial breach of contract. Judgment was entered for Mitfam for US$381,079.52, reflecting a deduction for Motley's damages on the counterclaim.

1. Case Overview

1.1 Court

High Court

1.2 Outcome

Judgment for Plaintiff in part; Counterclaim allowed in part.

1.3 Case Type

Civil

1.4 Judgment Type

Grounds of Decision

1.5 Jurisdiction

Singapore

1.6 Description

Mitfam sues Motley for unpaid cashew nuts. Motley counterclaims for breach of contract. Court finds for Mitfam, less damages for Motley's counterclaim.

1.7 Decision Date

2. Parties and Outcomes

Party NameRoleTypeOutcomeOutcome TypeCounsels
Mitfam International LtdPlaintiffCorporationJudgment for Plaintiff in partPartial
Motley Resources Pte LtdDefendantCorporationCounterclaim allowed in partPartial

3. Judges

Judge NameTitleDelivered Judgment
Judith PrakashJudgeYes

4. Counsels

4. Facts

  1. Mitfam sued Motley for US$395,666 for raw cashew nuts sold.
  2. Motley admitted purchasing the goods and owing the invoiced sum.
  3. Motley claimed the invoiced sum should be set off against US$486,553.33 in prior payments.
  4. Motley counterclaimed for breach of two contracts for the sale of raw cashew nuts.
  5. The first contract was for 1,500 MT of raw cashew nuts, which Mitfam allegedly did not perform.
  6. The second contract was for 1,000 MT of raw cashew nuts, of which Mitfam delivered only a portion.
  7. Motley claimed damages for both breaches of contract.

5. Formal Citations

  1. Mitfam International Ltd v Motley Resources Pte Ltd, Suit No 732 of 2010, [2013] SGHC 270

6. Timeline

DateEvent
Contract signed for sale of 1,500 MT of raw cashew nuts.
Contract signed for sale of 1,000 MT of raw cashew nuts.
Mitfam issues invoice for US$395,666 for raw cashew nuts.
Judgment issued.

7. Legal Issues

  1. Breach of Contract
    • Outcome: The court found that the plaintiff breached the contract by failing to deliver the full quantity of goods. The court also found that the defendant failed to establish a letter of credit.
    • Category: Substantive
    • Sub-Issues:
      • Short delivery of goods
      • Failure to establish letter of credit
  2. Set-off
    • Outcome: The court allowed the defendant to set off the damages awarded on the counterclaim against the amount owed to the plaintiff.
    • Category: Procedural

8. Remedies Sought

  1. Monetary Damages
  2. Set-off

9. Cause of Actions

  • Breach of Contract
  • Failure to deliver goods

10. Practice Areas

  • Commercial Litigation

11. Industries

  • Commodities
  • Trading

12. Cited Cases

Case NameCourtAffirmedCitationJurisdictionSignificance
No cited cases

13. Applicable Rules

Rule Name
No applicable rules

14. Applicable Statutes

Statute NameJurisdiction
Electronic Transactions Act (Cap 88, 2011 Rev Ed)Singapore
Evidence Act (Cap 97, 1997 Rev Ed)Singapore

15. Key Terms and Keywords

15.1 Key Terms

  • Raw cashew nuts
  • Running account
  • Advances
  • Reimbursements
  • Letter of credit
  • Short delivery

15.2 Keywords

  • Cashew nuts
  • Contract breach
  • Singapore
  • Commodities
  • Trading

17. Areas of Law

16. Subjects

  • Contract Dispute
  • Commodities Trading