The claimant must establish a causal link between the defendant's breach of contract and his loss in order to recover damages. The courts have treated the determination of whether a breach was a cause of the loss in a broad way, advocating a 'common sense approach' (Galoo Ltd v Bright Grahame Murray [1994] 1 WLR 1360). The court in Galoo suggested that the defendant's breach should be a 'dominant' or 'effective' cause of the loss.