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The Court of Appeal held that for a specific type of claim to be covered by a compromise agreement, it must be particularly specified - a general ‘catch-all’ provision is not enough. Clause 9 of H’s compromise agreement stipulated that all outstanding claims arising out of the employment and/or its termination were intended to be settled and went on to list 11 particular kinds of claim, but expressly exempted certain other kinds of claim such as pensions and personal injury.
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