In a property development services agreement providing for a termination adjustment by reference to 'unrealised capital gains' and 'unrealised capital losses', those expressions encompass gains and losses on all properties irrespective of whether held on capital or revenue account, unless qualifying language expressly limits them. Multiple offers of compromise directed to different claims cannot be aggregated under r 26.08 of the Supreme Court (General Civil Procedure) Rules 2015, but a covering letter may operate as a Calderbank letter.
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