廈門新景地集團有限公司 v Eton Properties Limited

Where a defendant has breached an implied promise to honour an arbitral award (here requiring continued performance of a 2003 agreement), damages are assessed on a realistic counterfactual of what would have happened had the award been performed at the breach date, allowing recovery of lost profits net of costs and excluding losses attributable to the defendant's own self-inflicted obstacles to performance.