Indirect and electronic service: serving the interests of justice?

ABSTRACT In UKI (Kingsway) Limited v Westminster City Council, the Supreme Court of the United Kingdom considered the fundamental question of what constitutes effective service in the context of service of notice under a statutory regime. Two questions of general importance arose. First, is a notice validly served where it reaches the intended recipient indirectly through the actions of a third party not authorised for that purpose? Second, is a notice validly served where it is received in electronic form? On each question, the Court held that service was valid, expounding an approach that significantly expands the valid means and modes of service. This case note considers the difficulties in principle and practice of this decision, as well as its future implications.