There is a “a dearth of case law” on s1(1) of the Contracts (Rights of Third Parties) Act 1999 (Act), as observed by Lenon KC, the judge in the case of HNW Lending Ltd v Lawrence [2025] EWHC 908 (Ch). Whilst an accurate assessment, the judge would have been well within his rights to add (but didn’t) that the dearth of caselaw extends to the entire Act, not just s1(1). This is surprising given the rising prevalence of reliance on the Act in commercial contracts (and perhaps most frequently, construction contracts) since its introduction in 1999. Therefore this case is particularly welcome and in this Insight, Kevin Henderson takes a look at what we can learn from it.