In two recent decisions, Consulting Concepts International Inc v Consumer Protection Association (Saudi Arabia) [2022] EWCA Civ 1699 (“CCI”) and Anron Bunkering DMCC v Glencore Energy UK Ltd [2023] EWHC 295 (Comm) (“Anron”), the English courts have dealt with issues of limitation in the context of claims founded on simple contract.

In CCI, the Court of Appeal confirmed that the cause of action in a claim for payment for work done and services rendered accrues when the work was completed unless there is some “special term” in the agreement to the contrary. In Anron, the Commercial Court confirmed that the cause of action in a claim in unjust enrichment arising for payments made pursuant to a contract where there has been a failure of basis for payment accrues when the failure occurs.