Deleted words can come back to bite

Narandas-Girdhar v Bradstock [2016] EWCA Civ 88, 16 February 2016

A debtor attempted to challenge a modified proposal in his individual voluntary arrangement (IVA), and one of the arguments was that his proposal had been conditional and dependent on the simultaneous proposal for an IVA from his wife, which had been rejected. In the Court of Appeal, an interesting legal point arose as to whether a deleted paragraph was relevant to the interpretation of the proposal as a whole, since the paragraph deleted referred to his wife’s IVA.