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Court of Appeal decision on reasonableness of requirement for guarantor

Court of Appeal decision on reasonableness of requirement for guarantor

The Court of Appeal has given judgment in Landlord Protect Ltd v St Anselm Development Co Ltd [2009] EWCA Civ 99 in which Martin Rodger QC represented the Respondent tenant. The Court held that a landlord could not reasonably require a guarantor of the liabilities of a proposed assignee to undertake a liability extending beyond the period during which the term would be vested in that assignee. The landlord had therefore acted unreasonably in requiring, as a condition of its consent to assignment of the lease, that a guarantor to be provided by the proposed assignee would only be released from his guarantee in the event of a subsequent assignment of the lease if "reasonable alternative security" was provided.