Management time costs incurred by a plaintiff's existing employees in dealing with a defendant's breach of contract are not recoverable as damages unless the plaintiff proves additional expense was actually incurred (such as overtime, additional remuneration, or hiring additional staff) or that the diversion of management time caused the plaintiff to lose valuable business opportunities. The mere fact that employees spent time on the breach, even if quantified and uncontested, is insufficient without proof of additional cost or lost opportunity. The decision in Orlit Pty Ltd v JF&P Consulting Engineers Pty Ltd [1993] QCA 277 is distinguishable where the management costs were actually charged to the plaintiff by a related entity.
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