CA-2024-000950 - [2025] EWCA Civ 1019

We were referred by both parties, without objection, to three categories of extraneous material, namely the Law Commission Report, the Explanatory Notes which accompanied the 2015 Act, and the Parliamentary debates on the Bill which became the Act. The parties relied on this material not only to explain such matters as the context for the Act and the mischief at which it was directed, but also in order to support their submissions as to what the provisions of the Act were intended to mean. We heard no submissions as to whether this was a legitimate approach, but it is unnecessary to pursue that matter further as, to my mind, the relevant provisions of the Act are clear and the extraneous material to which we were referred would do no more than confirm the conclusions as to the meaning of the relevant provisions which I would have reached in any event.