Complex Contract Termination in Motorboat Purchase – Reasoning of the Lübeck Regional Court
In connection with the contract termination of a purchase agreement for a motorboat, the Lübeck Regional Court, in its judgment dated June 11, 2024 (Case No. 15 O 37/23), addressed numerous practice-relevant issues significant both for businesses and wealthy private individuals when entering into and terminating purchase contracts—especially in the high-value segment of yachts and boats. The court’s decision provides a detailed insight into challenges arising from material defects, issues with expert reports, and specific characteristics of consumer goods purchases.
Initial Situation and Core Dispute
The buyer of a motorboat sought contract termination citing material defects which, from his perspective, rendered the boat unusable. The core issue was whether the identified technical deficiencies justified a significant depreciation—and thus a right of withdrawal under §§ 437 No. 2, 323 of the German Civil Code (BGB)—or whether only a price reduction was appropriate.
Material Defect and Usability
The Regional Court had to examine whether the disputed motorboat was a defective purchase item. Crucial was the extent of the technical issues and their impact on road safety and usability. Key points of contention included:
Technical Defects
Among others, errors in the shift mechanism and a defect in the cable guidance were identified. After evaluating several expert reports, it was confirmed that these defects existed at the time of delivery. The defective components impaired the steering system and thus the safe use of the boat, objectively constituting a material defect within the meaning of § 434 BGB.
Significance of Usability
The central legal evaluation was to determine whether the usability was so substantially limited that a withdrawal was justified. According to the court, the boat could not be used as intended during certain time periods due to the defects. However, the court did not consider the impairments so severe as to completely negate the buyer’s contractual interest—therefore the conditions for a withdrawal were not met.
Contractual Defect Rights and Their Limits
The ruling emphasizes that the right to withdraw in consumer goods purchases is linked to a substantial limitation of the contract’s purpose. Withdrawal is excluded under § 323 (5) sentence 2 BGB if the defect is insignificant; only a price reduction remains as a legal consequence.
Insignificance of the Defect
The court precisely distinguished between price reduction and full withdrawal. Weighing the existing defect against the overall value and usage of the motorboat, it affirmed that the identified defects caused depreciation but did not lead to total loss of value of the purchased item. The depreciation determined by the expert confirmed this assessment.
Expert Proceedings and Burden of Proof
The procedural situation was further complicated by repeated expert examinations of technical disputes. The court reviewed the evidence and its reliability regarding the time of origin and remediability of the defects. It concluded that the defects were already present at delivery, but the buyer was entitled only to a price reduction, not further rights.
Relevance for Contracting Parties in Commercial Transactions
The decision underscores that especially in high-value purchases of specialized goods such as motorboats, clear contract design and precise documentation of agreed quality characteristics are of significant importance. Considering the typically complex technical features of such goods, later disputes over the existence or relevance of defects can only be minimized through detailed provisions.
Specifics in Consumer Goods Purchases
The Regional Court highlighted that when selling new or used motorboats to consumers, the tenancy and purchase law protection mechanisms of the BGB must be supported by appropriate contract execution to ensure legally secure outcomes in case of disputes.
Contract Termination as a Last Resort
The right of withdrawal remains an exceptional remedy, applicable only where defects severely impair the agreed contractual benefit and no alternatives exist. Mere usage restrictions, even if significant over a certain period, do not automatically lead to contract termination, as long as the overall benefit of the purchase can be maintained or restored.
Conclusion and Outlook
The decision of the Regional Court of Lübeck illustrates the strict requirements for the reversal of sales contracts, especially when it concerns technically sophisticated and high-value goods such as motorboats. It provides guidance for contracting parties on both the seller’s and buyer’s side, highlighting what must be particularly observed in the drafting and execution of contracts.
If you require advice beyond this individual case, for example on transactions, defect management, or the legally compliant drafting of complex sales contracts, tailored legal support may be advisable. Further information and individual contact are made possible, for example, by our legal advice in contract law offered by MTR Legal Rechtsanwälte.
