Doctrine of merger does not apply to declaratory judgments

Nasir v Zavarco plc [2025] UKSC 5

Raj Arumugam

Any lawyer who has issued proceedings which include a claim for declaratory relief will breathe a small sigh of relief following the Supreme Court's decision in Nasir v Zavarco plc [2025] UKSC 5. In that judgment, the Supreme Court confirmed that the doctrine of merger does not apply to declaratory judgments. Surprisingly, there is no prior reported authority in English law on this point. The decision provides welcome clarification of the law.