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St Philips Commercial

On Wednesday 24th October 2018 we attended the Birmingham Business and Property Court Users Group Meeting, chaired by Mrs Justice Carr and Mr Justice Birss. The meeting also had the honour of being attended by Sir Terence Etherton, the Master of the Rolls, along with Lord Justice Flaux, and was well attended by local solicitors and members of the Bar.  

A number of current issues were discussed with some useful observations made which we thought may be of interest to our clients and so below is a summary of what was discussed. Many thanks to our new pupil, Natalie Kearney, for putting the minutes together. 


A member of staff from The Rolls Building attended and gave an update on the nationwide roll-out of the CE-Filing system. They confirmed that the roll-out is forecast to last a further 2 years, with QBD next in line as it has the oldest legacy systems. The regional Business and Property Courts (BPC) are to follow QBD. 

We were told that the technical build is scheduled to be complete by Christmas, with the internal release to staff and judges in January 2019. They are at this stage unable to provide a definite date for switching on the external element, however it was thought that the roll-out in QBD and the BPC should take around 2 months each and therefore it would probably be rolled out around March/April 2019. 

The Practice Directions for the Rolls Building and the QBD are done. It is expected that the PD for the BPC are to be substantially the same. 

CE-File will not be mandatory from its initial release; however, the aim is for it to be mandatory for professionals after a phasing-in period, but not for litigants in person. 

Updates on this will follow. 

Reform Programme 

Master of the Rolls, Sir Terence Etherton also confirmed that this is part of an ongoing reform programme, running until 2022. The aim is to improve the system beyond e-filing, hopefully with the aim of running paperless trials. This would not be possible on the CE-Filing system as designed so it will require the development of a new system. 

Specialist Lists – Intellectual Property 

Mr Justice Birss confirmed that early next year the aim is to introduce the IPEC list into regional BPC and there is a process underway currently to identify judges willing to have training. The first cases to be heard are likely to be small claims track trials. 2 DJs in Birmingham have already volunteered to undertake the necessary training. 

Specialist BPC DJs 

More DJs are to be added soon and recruitment is under way for DDJs. 

Birmingham has seen a significant increase in insolvency work, which may reflect the fact that the Insolvency PD changed in July 2018, with Birmingham a centre for specialised insolvency work. This means that there is a need for specialist DJs. 

Shorter and Flexible Trials Scheme 

This was piloted in the Rolls Building and is now permanent in all BPC. There appears to have been little uptake, although the shorter trials scheme has been more successful than the flexible trials scheme. The benefits are that a hearing date can be obtained more quickly, and appeals can also be expedited and Mrs Justice Carr was keen to see in increase in its uptake. 

Urgent Applications 

Concerns have been raised by Judges as to the limited information they receive when an urgent application is received at the counter. Quite often they simply have the signed application and that inappropriate applications are being made (e.g. applications without notice when notice should have been given). 

A new 2-page form is going to be introduced that will ask for additional information to be supplied about the urgent application, which will be handed to the Judge for them to decide if the application is urgent. This is intended to prevent inappropriate applications and was introduced successfully by HHJ McCahill QC in Bristol. 

Turnaround Times 

Issue is currently operating a 2-day turnaround. 

Correspondence and Orders are at 11 October 2018 at present. 

There have been some staffing changes which are impacting turnaround times, but new members of staff are joining the team and it is expected that the new CE-Filing system will reduce the turnaround time further. 

Disclosure Pilot 

James Morgan QC raised two concerns, both of which were discussed at the first or our Disclosure Breakfast Seminars that took place earlier that day :

1. The pilot is said to apply to new and existing claims from 1 January 2019, however what does this mean for CCMCs listed in the first weeks of January? The new rules require the completion of disclosure forms and there will not be time for these to be completed prior to the hearings from 1 January 2019.

a. Mrs Justice Carr and Mr Justice Birss confirmed that parties should begin completing the relevant disclosure review documents as soon as possible, ready to comply in January 2019, even though the pilot is not yet in force. There was some suggestion that words to that effect should be included on the notices being sent out by the courts, however the advice was to complete the forms regardless of whether any such wording was on the notices.

2. The pilot will only work if DJs are given proper time to read the disclosure review documents prior to any CCMC, therefore were there provisions being made for the DJs to have extra reading time?

a. DJ Ingram raised concerns that increased reading time would impact the number of effective CCMCs it would be possible for the courts to hear. 

b. It was agreed that DJs would probably need more time to review the DRDs.

DJ Ingram asked that details of any seminars on the new disclosure pilot be provided to her to pass on to any other DJs as some judges had not been able to attend earlier training, She duly attended our seminar in chambers on the 1st November. 

Sir Terence Etherton confirmed that the aim for the pilot is that the disclosure scheme will eventually roll-out beyond the BPC to apply to all civil litigation. 

Appeals Query

Marc Brown had become aware that the current procedural rules mean that an appeal can only be heard by a full-time High Court Judge, not deputies or those sitting as s9 Judges. This presents a difficulty on circuit due to the number of available full-time High Court Judges. He questioned whether this was a matter to be referred to the Rules Committee. 

This is apparently an issue that has been considered in depth and is a question for the heads of the division. It is believed that the position is as Marc described and that there is to be a review to take place of the procedure in the next 4 months. 

We hope you find this of use. 

James Morgan QC and Justin Luckman

The Honourable Mr Justice Pepperall was officially sworn in by The Lord Chief Justice, The Right Honourable The Lord Burnett of Maldon, in a ceremony at the Royal Courts of Justice yesterday.

Ed, as he is known to most of you, took the Oath of Allegiance and the Judicial Oath before the Lord Chief who was joined on the bench by The President of the Queen’s Bench Division, Sir Brian Leveson and Ed’s former stablemate at No.2 Fountain Court (latterly St Philips Chambers) Sir Andrew McFarlane, The President of the Family Division. On what was a very proud day for Ed and for St Philips, Court 4 of the RCJ was full of Ed’s family, friends and colleagues to witness his appointment to the Queen’s Bench Division and to wish him well in his new role.

Tuesday, 09 October 2018 00:00

Kirsty White joins St Philips

St Philips is delighted to welcome Kirsty White as a new tenant in chambers.

Kirsty joins our Business & Property Group after 5 years working in-house in the litigation team of a national firm of solicitors. During this time a lot of her work has focused on contract and torts including claims of high value or with an international element.

I am incredibly excited to be joining St Philips and beginning the next stage of my career” said Kirsty. “Having instructed members of St Philips myself, I am only too aware of the first rate practitioners I will be working alongside and honoured to now be a member of their exceptional Business & Property Group.

Head of Group James Morgan QC said “I am delighted that Kirsty has accepted an invitation to join chambers. I know from our experience of working together that Kirsty is an exceptional barrister whose addition to our Business & Property Group enhances the strength and depth offered by our members across the full spectrum of commercial litigation.

St Philips Chambers is delighted to announce that Ed Pepperall QC has been appointed a High Court Judge, assigned to the Queen’s Bench Division.

Ed will take the customary Oath of Allegiance and the Judicial Oath at a swearing in ceremony before the Lord Chief Justice and will start sitting as The Honourable Mr Justice Pepperall on Monday 1st October 2018 at the Royal Courts of Justice.

Ed has enjoyed a distinguished career at the Birmingham Bar and was a founding member of St Philips Chambers.

The married father-of-three has strong connections with Birmingham in addition to his legal work. His grandfather, Sir Harold Gurden, was the Conservative MP for Selly Oak for 19 years (1955-1974). Ed studied law at the University of Birmingham – the first member of his family to attend university – and graduated in 1988.

Ed, who was called to the Bar in 1989, remained in the city for his pupillage and early career at Birmingham’s 2 Fountain Court. The set merged with 7 Fountain Court to become St Philips in 1998.

Ed took Silk in 2013, was appointed as a Recorder in 2009; and was made a Deputy High Court Judge in 2016, sitting in the Chancery and Queen’s Bench Divisions, including the Technology and Construction Court. He is a Justice of the Court of Appeal of the Falkland Islands, South Georgia and the South Sandwich Islands, and was a member of the Civil Procedure Rule Committee between 2010 and 2016. He is also a contributing editor of the White Book.

Ed said: “I am extremely honoured to be appointed a High Court judge following a rewarding career at the Bar. Although I have practised regularly in London, Birmingham has always been my legal home. The city is a centre of excellence and boasts many advocates of the very highest standard.

“I am delighted to have been a member of St Philips since its inception in 1998. St Philips’ obvious commercial strength helped me to achieve my ambitions and I wish the set the very best for the future.”

With a forensic eye for detail, Ed was regularly instructed in multi-million pound commercial and professional negligence litigation with particular expertise in business sale disputes, restraint of trade, confidentiality and commercial fraud work. Among other blue chip clients, he represented the royal household, the UK’s five largest brewers, a Formula 1 racing team and a sitting judge.

His final case as a QC was a five-week trial in London relating to a share warranty claim valued at $75 million.

Head of Chambers Andrew Smith QC said: “We are absolutely delighted for Ed and wish him every success as he embarks on his judicial career. His appointment is richly deserved and a great honour for both him and chambers.” Ed’s elevation to the High Court bench is the seventh judicial appointment from St Philips this year, following on the heels of three Circuit Judges, two District Judges and a First-tier Tribunal Judge. “Once again we have demonstrated that St Philips is the set to be in for barristers wishing to work in a collegiate atmosphere that encourages individuals’ ability to work, and reach, the highest possible level.” said Smith.

In addition to the usual Queen’s Bench diet of civil, appellate and serious criminal work, Ed is likely to sit in the Technology and Construction Court in London.

St Philips is extremely proud of his appointment and wishes Ed every success in his judicial career.

The official announcement can be viewed here.

Published by LexisNexis, Atkins Court Forms provides commentary and precedents in respect of civil proceedings before the courts and judicial tribunals of England and Wales.

Volumes 7(1) and 7(2) on bankruptcy and personal insolvency have recently been published in an updated form, stating the law as at 25 April 2018, having been updated to take into account recent developments and most notably the introduction of the Insolvency Rules 2016.

Marc Brown was one of the two contributors in respect of these newly published volumes.

If you require any further information about Marc’s practice or Chambers Business & Property Group, please do not hesitate to contact Justin Luckman or Arron Snipe.

John Randall QC and Marc Brown appeared in the Supreme Court over the last two days in the case of Regency Villas Title Ltd and others (Respondents/Cross-Appellants) v Diamond Resorts (Europe) Ltd and others (Appellants/Cross-Respondents).  The appeal was heard by The President of the Supreme Court Lady Hale and Supreme Court Justices Lord Kerr, Lord Sumption, Lord Carnwath and Lord Briggs, and has sought to clarify the appropriate test for easements, and specifically the extent to which easements can properly be granted in respect of recreational uses of land, such as to use a golf course or a swimming pool.

John and Marc appeared on behalf of Regency Villas Title Ltd and others, instructed by Shakespeare Martineau (as they did both at first instance and in the Court of Appeal).

The judgment is reserved.

The UK Supreme Court Case Summary


In the context of easements, what is the correct approach to the requirement that to qualify as an easement a right must accommodate the dominant tenement in the sense that it provides "utility and benefit" in the use of the dominant land? In particular, what is the correct approach when the right is a right to recreation which is enjoyed in a self-contained way on the servient land? The correctness of the decision in Re Ellenborough Park is also in issue.


The issue in the appeal is whether a transfer made in 1981 granted to the respondents easements (being property rights) to use the gardens, and sporting and recreational facilities on the appellants’ land, or whether the transfer simply granted personal rights incapable of being transferred to a third party. The judge found that the 1981 transfer did create easements to use (free of charge) the gardens and sporting and recreational facilities on the appellants’ land, even where these had not been built or contemplated at the time of the transfer in 1981. The Court of Appeal upheld the majority of the easements identified by the trial judge, but found that on the proper interpretation of the grant, facilities which were built after the time of the 1981 transfer were not included. The appellants now appeal that decision.

Judgment appealed

Tuesday, 03 July 2018 00:00

Marc Brown appointed as a Recorder

We are delighted to announce that Her Majesty the Queen has now appointed Marc Brown as a Recorder. Marc was officially sworn in by The Honourable Mr Justice Jeremy Baker at Nottingham Crown Court on 19th June and has been deployed to the Midlands Circuit.

Marc is a member of St Philips Business & Property Group and his profile can be viewed here.

Iqbal Mohammed has succeeded in obtaining an order for specific performance and judgement for damages in the High Court against a tenant who refused to abide by an expert determination in a lease dispute with the Council. The High Court ordered the Defendant to enter into a Deed of Variation, increasing the annual rent for a commercial property from £225 to £21,000, with 5-yearly upward rent reviews, for 48 years. The Court also gave judgement for damages, valuing the victory at over £1.1m for the Council. 


The Defendant acquired the lease at auction in early 2011. It subsequently altered the property, in breach of covenant, from a public house to convenience store, hot food take-away, ATM and two residential flats. The Council served a s. 146 notice, requiring the breaches to be remedied and damages to be paid. The Defendant disputed that it was in breach of lease and agreed to refer the dispute to a RICS-appointed expert for determination. The parties agreed the terms of reference and, if there was a breach of lease, agreed two proposed deeds of variation, for the expert to determine the appropriate one to compensate the Council. One required the payment of a premium, the other increased the rent to the prevailing market value for the property. 

The expert determined that there was a breach of lease and that the deed of variation increasing the rent, which he assessed at £21,000, was the appropriate deed to be executed. The Defendant refused to execute the Deed arguing that (1) the expert had no power to compel it to execute the deed; (2) by submitting to expert determination, it had not agreed to execute the Deed; and (3) it was entitled to simply reverse the alterations rather than abide by the expert determination; it being unjust to order specific performance. At trial, the Defendant also argued that if there was an agreement to execute the Deed, it was unenforceable as it failed to comply with section 2, Law of Property (Miscellaneous Provisions) Act 1989.

Litigation & trial

The Council instructed Iqbal at the pre-action stage to advise on strategy and tactics. Iqbal successfully argued that the case should be tried under Part 8, significantly reducing the cost of litigation and time to trial. The case was tried within 1 year and heard without oral evidence. The judge held that the Defendant (1) had accepted, in its email exchanges with the Council, the offer to resolve the dispute through expert determination and had agreed to execute the draft deed; (2) in any event, the agreement could be implied; (3) s. 2 did not apply as the deed did not dispose of, assure or create an estate in land; and (4) it was just to order specific performance. The court further gave judgement for the rent lost by the Defendant’s failure to execute the Deed.

Points of law

This is a rare decision on enforcing an expert determination. The judge applied Cott UK Limited v F E Barber [1997] 3 All ER 540, in which Hegarty J accepted that if “a dispute as to performance is referred to the expert, then he must by implication have the power to make a final and binding decision.”

Practical significance

This case demonstrates the need to carefully consider any decision to refer a matter to expert determination, specifically, the consequence of an expert determining the issue against the client. Further, where a party reneges on an expert determination, careful consideration should be given to obtaining relief through a claim for specific performance. 

Iqbal is a member of the Property Bar Association. Please click here to see his real estate experience.

Please contact chambers for a copy of the judgement.

Morris-Garner v One Step (Support) Limited [2018] UKSC 20

A couple of weeks ago (18 April 2018) the Supreme Court decided a landmark case on damages.  It was unusual in that it appears a unanimousdecision in the result, but Lord Sumption dissented from the majority in the reasoning.  Lord Reed gave the majority judgment with which Lord Carnworth agreed, but then he went in to explain the differences between the two judgments.

It concerns the recoverability of "negotiating damages", the expression settled upon by the Supreme Court, and therefore one which now seems to be established in our law. 

Legal Background to the Decision

Negotiating damages have been around quite some time, particularly given prominence after the judgment of Brightman J in Wrotham Park Estate v Parkside Homesin 1974[1].  The original evolution from Wrotham Parkconcentrated on damages in lieu of an injunction, sometimes referred to as damages under Lord Cairns' Act[2].  There then followed a line of cases where damages were given in place of an injunction, if it would otherwise have been appropriate to grant an injunction so long as one had been claimed or where otherwise the claimant had not debarred himself from obtaining it[3]. These tended to be property cases, predominately cases where there had been breach of a restrictive covenant and the court had refused to order the taking down of much-needed housing stock built in breach.  In these cases, the court would award a sum of money which it thought would represent the amount willing parties would have negotiated for the buying off, or release, of the right.  The classic subsequent example is Jaggard v Sawyer[4]and the much respected judgment of Millett LJ (as he then was). In Jaggard damages in lieu were calculated in the sum of £694 being one ninth share of £6250, the price the defendants might reasonably have had to pay to the nine inhabitants of the cul-de-sac having the benefit of the breached covenant. In Barnes v Severn Trent[5]the much larger damages awarded at first instance for trespass were reduced in the Court of Appeal to a sum (£110) based on that which the water company would have had to pay had it used the statutory machinery for laying new water mains (it did not know of the claimant’s interest in the land at the time it laid the main over his land).  The possibility of service of a notice, and ultimately the possibility of determining the sum under the relevant statute, would have featured in the theoretical negotiations between the landowner and the water company.  This would be the maximum the landowner could have achieved had things been done properly, although the court also allowed an additional sum of £500 to take account of the possibility negotiations would probably have produced more for the landowner than the statutory amount. 

Things started to go in a different direction consequent on the House of Lords opinions in the well-known case of Attorney General v Blake[6].  Blake was a former member of the British security services and a Soviet spy.  He wrote and published his autobiography.  The UK government sought damages from Blake for his breach of contract in disclosing official secrets.  The court held that in an exceptional case, and this was one, an order for an account of profits could be granted following the breach of contract.

Thus started, was a line of discussion in cases (as well as academic debate) concerning monetary awards for breach of contract which did not relate to the actual provable and proved losses incurred, but which sought to deprive the contract-breaker the fruits of his wrongdoing.  These included Vercoe v Rutland Fund Management[7]which involved the breach of a joint venture agreement.  It had been agreed that damages should be assessed on the basis of a hypothetical release fee.  The Supreme Court in Morris Garner reconciled the case as one where actual loss had been calculated for loss of the opportunity to control confidential information. Another case was Experience Hendrix LLC v PPX Enterprises[8] and its interpretation in World Wide Fund for Nature v WorldWrestling Federation[9].  These were cases where the Supreme Court had difficulty reconciling the reasoning (where in effect gains-based damages were awarded) but the result was again justified on conventional principles as damages for lossof a (property) right, which could be calculated on a release fee basis. 

What appeared to be forming was the more expansive view that, at least where proprietary rights are concerned, andwhere damages were difficult to prove, hypothetical release fee/ negotiating damages could be awarded.

It is now time to return to the instant case.  

The case before the Supreme Court


The claimant, One Step, had been owned and controlled by the Morris-Garners (civil partners) as to 50%; and a Mr and Mrs Costello as to the other 50%.   The working relationship broke down and the Morris-Garners left and sold their shares to the Costellos with non-compete and non-solicitation covenants.  They set up another company substantially trading in the same area.  The claimant company, One Step, sued the Morris-Garner's for breach of these covenants and a confidentiality covenant, and breach of equitable duties of confidence.  The High Court and then the Court of Appeal held that the company was entitled to Wrotham Parkdamages on the basis that the Morris Garner's had breached straightforward governance in circumstances where it would be difficult for the company to identify the financial loss it had suffered by reason of the wrongful competition (the indications were that these were greater than losses – which were still substantial – on a conventional, actual, loss basis[10]).  The Court of Appeal held that the test for awarding (as it described them) Wrotham Parkdamages was not whether the case was exceptional but what justice required.

Conventional principles return

The Supreme Court allowed the appeal and scotched any suggestion that, save in a truly exceptional case, damages for breach of contract or covenant could be based on the hypothetical sum which could be negotiated ("negotiating damages").

The majority reasoning reasserted conventional principles thus[11]:

  1. the general principle is that damages are compensatory [25].  In tort damages are generally intended to place the claimant has nearly as possible in the same position he would have been in if the tort had not been committed [31].
  2. In contract, damages are intended, so far as money can do it, to place the claimant in the same situation as if the contract had been performed [32].
  3. However, in the case of tort "user damages" can be awarded.  For example, where real property has been taken, or damaged, by a trespasser.  In these cases, the courts had treated user damages as providing compensation for loss, albeit not loss of a conventional (actually occurring) kind [30].  It is no answer for the wrongdoer to show that the property owner would probably not have used the property himself had the wrongdoer not done so.
  4. User damages are also available for patent infringement and breaches of other intellectual property rights [26].
  5. In contract the obligation to pay damages is secondary (the primary obligation being to perform the contract) as a substitute for performance.  The court will notaward damages designed to deprive the contract breaker of any profit he may have made a consequence of his failure to perform [35] except, according to the decision in Attorney General v Blaketo the discretion to order an account of profits in exceptionalcircumstances [35].
  6. Separate to the concept of compensatory loss and or damages under the user principle are those which the Court of Chancery historically awarded under Lord Cairns Act. As Lord Reid explained, such damages are equitable in nature [46].  He rationalised that there were two phases in the development of these damages – the first phase, following from the Wrotham Park decision itself, where release fee damages had been awarded; and the second phase defined by the Attorney General v Blakedecision.
  7. The second phase was where matters started to go wrong; unless the hypothetical release fee resulted in an identifiable loss equivalent to the economic value of a proprietary right taken by the defendant.  Other than such cases, where the loss suffered is appropriately measured by reference to the economic value of the right which had been breached or infringed, there could be no damages for depriving the defendant of profits made as a result of the breach.
  8. In other words, the hypothetical release fee can be used as a tool for calculating the value of an asset lost, but it was notto be used as a matter of discretion to determine the measure or basis of damages.
  9. As Lord Reid concludes, common law damages for breach of contract are not a matter of discretion.  They are claimed as of right, and they are awarded or refused on the basis of legal principle.  [91] – [95]
Application to the facts of that case

Lord Reid held that the case before him was not one where the breach of contract had resulted in a loss of a valuable asset.  In reality, the claimant's losses were the cumulative result of breaches of a number of obligations, the most significance of which were the non-compete and non-solicitation covenants.  The decisions of the lower courts had to be overturned, and the case remitted for determination of what actual losses the claimant had suffered.

The reasoning of Lord Sumption

As stated earlier, Lord Sumption's reasons diverged from his brethren.  Lord Carnforth sought to explain the differences, describing Lord Reid's (and the majority's) analysis as entirely orthodox.  Lord Sumption's approach was, he said, more radical. Essentially, Lord Sumption was seeking to include cases where a notional release fee could be used as an evidential technique for estimating the claimant's loss [131] [124], and that this technique should be available to the judge.  Lord Carnforth disagreed with that approach, as it conflicted with the previous development of the law; it was not supported by the cases Lord Sumption used; and the approach gave no clear indication of the circumstances when such technique could be employed [136].


In conclusion, the conventional approach means losses must be proved.  There may be evidential difficulties in calculating such losses, but a way to so so has to be found.  The court should not shy away from making appropriate assessments and judgments even when the material before it only indirectly assists.  There is no place for an account of profit in the law of damages.  Damages in equity, under Lord Cairns Act of course survive but they are restricted to traditional categories where, principally, there is loss of a property right which is not remedied by specific equitable relief.  Attorney General v Blakemeans there is an exception to the prohibition on account of profits as a basis of damages, but this is confined to truly exceptional cases.  It is interesting to note that their Lordships did not identify any other single case where it was considered appropriate. Perhaps, Attorney General v Blakewill stand alone, for ever; or until the next spy tries to profit from his treason.

[1][1974] 1 WLR 798

[2]section 2 Chancery Amendment Act 1858

[3]Examples include Bracewell v Appleby [1975] Ch 408; Amec Developments v Jury’s Hotel (2001) 82 P&CR 22; Lunn Poly v Liverpool & Lancashire Properties [2006] EWCA Civ 430.  In some cases, no such damages were given; and actual loss was assessed as nominal (Stoke on Trent v Wass [1988] 1 WLR 1406, Surrey CC v Bredero Homes [1993] 1 WLR 1361).  The reasoning in these decisions is not easy to reconcile but it is to be noted in the first one an injunction was granted; in the second one no injunction was claimed (and in each compensatory damages, based on actual loss was nil or nominal). 

[4][1995] 1 WLR 267

[5][2004] EWCA Civ 570

[6][2001] 1 AC 268

[7][2010] EWHC 424 Ch

[8][2003] EWCA Civ 323

[9][2007] EWCA Civ 286

[10]The case had not been completed – liability had been determined but damages were still to be assessed. 

[11]Square brackets designate reference to paragraph numbers of the judgments

St Philips Business and Property are extremely proud to announce that Marc Brown and Mark Jones have been appointed to sit as Recorders across the country.

  • Marc Brown will be assigned to the Midland Circuit (Crime).
  • Mark Jones will be assigned to the Northern Circuit (Crime).

These appointments are a fantastic achievement and a resounding acknowledgment of the high level of expertise that St Philips offers.