David
Harris & Others v The Society of Lloyd's Heather
Mary Adams v The Society of Lloyd's Case No:
2007 FOLIO 1439; Case No: 2008 FOLIO 182 High
Court of Justice Queen's Bench Division Commercial Court 1 July
2008 [2008]
EWHC 1433 (Comm), 2008 WL 2465694 Before:
Mr Justice David Steel 01/07/2008 Representation * Paul Stafford (instructed
by Grower Freeman ) for the Claimants. * Richard Jacobs QC
(instructed by Freshfields ) for the Defendant. * The claimant in person
(assisted by her husband). * Richard Jacobs QC
(instructed by Freshfields ) for the Defendant. Judgment Mr.
Justice David Steel: Representation 1 It is
appropriate to start by introducing the parties and their representation. The
Claimants in 2007 Folio 1439 are 49 names at Lloyd's. They commenced
underwriting variously between 1973 and 1990. The Claimant in 2008 Folio 182 is
Mrs Adams, another Lloyd's name. She commenced underwriting in 1977. She has
instituted separate proceedings although it is accepted that they raise the
same issues of law and fact as in the other action and the strike out
application taken out in 2007 Folio 1439 is being treated by consent as
extending to her claim. 2 None of
the Claimants are strangers to the extensive litigation that has arisen out of
serious difficulties that faced Lloyd's in the 1980s and 1990s. The claimants
in Folio 1439 were represented by counsel. In the past, the court had allowed
Mrs. Adams to be represented by her husband. Such an arrangement was
accordingly permitted in the present action. However at the commencement of the
hearing, Mr. Adams in turn made an application that Mrs. Adams should be
represented by Mr. Stephen Merrett, the former underwriter and Deputy Chairman
of Lloyd's. I refused the application. My reasons for doing so were expressed
broadly at the time of my ruling but are now set out in greater detail. 3 Rights
of audience are governed by Section 27 of the Courts and Legal Services Act
1990 . Leaving aside the scope for representation by an appropriately qualified
advocate, a litigant in person (such as Mrs. Adams) is of course entitled to
appear on her own behalf ( subsection 2(d) ). There remains however a
discretion on the part of the court to accord anyone a right of audience in
relation to specific proceedings ( subsection 2(c) ). But it is well
established that the court will only accord that right (which would bypass the
stringent requirements of the legal professional bodies) in exceptional
circumstances: D. v S (Rights of Audience) [1997] 1 FLR 724 , Paragon Finance
Plc v Noueiri [2001] 1 W.L.R. 2357 . 4 As I
have already recorded, the court has already concluded that the circumstances
were sufficiently exceptional to allow Mrs. Adams' husband to make submissions
on her behalf. However, I had no hesitation in rejecting the application that
Mr. Merrett should replace Mr. Adams. My reasons were these: * i) The Claimants in 2007
Folio 1439 are represented by counsel, Mr. Stafford. As might be expected, he
has presented their case, in almost all respects in pari materia with Mrs.
Adams, with conspicuous thoroughness and clarity. * ii) Mr. Merrett is not
legally qualified. In the Commercial Court in particular lay representation is
seldom contemplated as permissible: see Section M of the Admiralty and
Commercial Court Guide . * iii) Furthermore he is a
witness in the case in the sense that extracts from two statements prepared by
him and deployed by the Claimants in an attempt to re-open earlier proceedings
in the Court of Appeal are relied upon by the Claimants (and in particular Mrs.
Adams) in the present hearing. * iv) This feature is of
particular significance for the following reason. Despite the acceptance by Mr.
Adams on his wife's behalf that her claim stands or falls with the other
Claimants, he had in fact sought to pursue a different argument to the effect
that RITC (reinsurance to close) as between Lloyd's syndicates constituted a
statutory novation by virtue of Section 85 of Insurance Companies Act 1982 . * v) This argument is not
open to Mrs. Adams. Indeed it is not pleaded. Although I will briefly touch on
it in due course, for present purposes the important factor is that it is clear
that the submission is a hobby horse of Mr. Merrett's. Indeed it was apparent
that Mr. Merrett was anxious to use the opportunity to appear for Mrs. Adams to
pursue this argument rather than make submissions in the general interest of
Mrs. Adams on the points properly open. * vi) This became all the
clearer when Mr. Adams came in due course to make his submissions. It became
obvious that he used as his text material prepared wholly or largely by Mr.
Merrett and which, in the main, focused on the discrete issue of statutory
novation. Disclosure 5 There
is one other threshold point which I must deal with. On the eve of the hearing,
the Claimants made an application for specific disclosure. I now set out my
reasons for rejecting that application. The three documents which were the
subject of the disclosure application were all associated with an opinion of
Mr. Stewart Boyd Q.C. dated 14 April 1993: * i) a note dated 4 October
1991 by Mr. Burling of the Defendant's legal department referred to in
paragraph 1 of the opinion; * ii) a note dated 5 April
1993 by Mr. Mallinson, at that time solicitor to the Corporation of Lloyd's,
referred to in paragraph 4 of the opinion; * iii) the instructions
provided to Mr. Boyd for the purpose of producing the opinion. 6 The
basis of the application was that the Defendant had deployed the opinion in the
proceedings thereby waiving privilege of the opinion and thereby effecting a
collateral waiver of the privilege in the documents sought: see Nea Karteria
Maritime Co. v Atlantic and Great Lakes Steamship Corp. [1981] Com LR 138 . 7 The
Defendant's position was as follows: * i) The documents were not
relevant and/or alternatively they were not necessary for the fair disposal of
the present application. * ii) The Defendant had not
deployed the opinion in the proceedings: it had been deployed by the Claimants
and it was thereby that its privilege had been lost. * iii) Thus the documents
sought remained privileged and that privilege had not been waived. 8 At the
end of the hearing late on Friday 11 April 2008, I refused the application and
indicated that I would give my reasons in due course. 9 Before
dealing with the substance of the matter I ought to record the remarkable delay
in presenting the application for disclosure which would, in any event, have
mitigated strongly against the exercise of any discretion to grant the relief
sought: * i) A CMC was fixed by
Tomlinson J in December 2007 to take place on 8 February 2008 at which, amongst
other matters, any application for disclosure was to be made; * ii) The documents presently
sought were requested in correspondence in January 2008; * iii) The CMC was moved to
22 February. The application notice for disclosure of the documents was duly
issued on 13 February, the notice itself identifying that the Claimant wished
that the issue be dealt with at the CMC; * iv) The Defendant's
evidence in response to the application was served on 19 February; * v) In the run up to the
CMC hearing there was some debate as to whether there was sufficient time to
deal with the application. Whilst the Defendant's position was that there would
be time, the Claimants ironically took the opposite view. * vi) The transcript of the
hearing before Andrew Smith J demonstrates clearly the willingness of the judge
to deal with the application which was opened at some length. In the event the
Claimants refused to pursue it and the judge struck the application out on
technical grounds but left it open to the Claimants to make a fresh
application. 10 It is
well established under the previous procedural rules that the power to order
disclosure for the purpose of interlocutory proceedings should be exercised
sparingly and then only for such documents as can be shown to be necessary for
the just disposal of the application: Rome v Punjab National Bank [1989] 2 All
E.R. 136 . There are good reasons for concluding that the same if not a
stricter approach is appropriate under the provisions of CPR : see Disclosure,
Matthews and Malek 3nd Ed. Para 2.68 . The delay described above undermines the
credibility of the Claimants' protestations that, leaving aside the issue of
privilege, the documents are necessary for (or even relevant to) the strike-out
application. Relevance 11 The
Claimants contended that the documents were relevant because: * i) It is said that Mr.
Burling's note would establish Lloyd's' view of the nature and effect of RITC
and this in turn would illustrate when Lloyd's became aware that the
representation they had made to prospective names was untrue. But there
appeared to be no issue about what Lloyd's' view of the nature and effect of
RITC was. It was regarded as a contract of reinsurance. Indeed it is the
Claimants' case that that was Lloyd's view because the complaint is that they
sought to deceive the Names by suggesting that it had some other nature and
effect. It is clear from the opinion that Mr Burling expressed the view in the
note that it was a form of reinsurance. Thus how it is relevant to any issue
remains at best wholly obscure. * ii) It is said that Mr.
Mallinson's note would indicate what information was provided to names at the
Rota Interviews. But Mr. Mallinson's note only purports to refer to the
relevant documents all of which are available. The note can add nothing to Mr.
Boyd's comment that some of the documents were "misleading". Accordingly the
note is not relevant let alone necessary. * iii) As regards the
instructions, it is said that they would in turn encompass the matters
identified in (a) and (b). It follows that they are equally irrelevant. Privilege 12 It is
common ground that the opinion of Mr Boyd QC (and the documents sought on this
application) was originally privileged. The opinion was indeed deployed by the
Claimants in October 2006 when it was appended as an exhibit to a statement of
Mr. Stephen Merrett and put before the Court of Appeal in the preparations for
the hearing of the appeal in Henderson . It was also deployed by the names in
the Taylor v Lawrence application in the Court of Appeal in June 2007. It would
appear that Mr Merrett had copies furnished to him in his earlier capacity as
deputy chairman of Lloyd's. In any event it was by this process that the
privilege in the opinion was lost. 13 The
suggestion made by the Claimants that, although the privilege had been lost, it
nonetheless remained a privileged document is rejected. Any subsequent
deployment of the opinion by the Defendant can be undertaken without any waiver
of privilege. It equally follows that, since the opinion was no longer
privileged, no question of any collateral waiver in respect of the documents
referred to in it could possibly arise: see Hollander: Documentary Evidence 9th
Ed. paras. 19.36 - 19.42 . 14
Leaving all this aside, the Defendant have not in fact deployed the opinion in
court. The only relevant hearing was in December 2007 before Tomlinson J. The
Defendant produced a detailed statement setting out their case. One of the
exhibits was the Boyd opinion but the judge was not shown it and he was not
invited to read that part of the statement which referred to the opinion. No
submission was made by either party as to the content of the opinion. In short
the statement was not deployed "in court" let alone in evidence. The
present application 15 This
is an application by Lloyd's to strike out or dismiss yet further claims
brought by the claimants. The application to strike out is made pursuant to CPR
3.4(2) and/or to dismiss the claims by way of summary judgment pursuant to CPR
24.2 . As regards the strike out application, it is contended that there are no
reasonable grounds for bringing the claims and/or that they constitute an abuse
of process. In regard to the application for summary judgment, it is submitted
that the claimants have no real prospect of succeeding on the claims and there
is no other compelling reason why the case should be disposed of at trial. This
is against the background of encouragement to exercise such powers in
appropriate cases contained the Report and Recommendations of the Commercial
Court Long Trials Working Party dated December 2007. The main
issues 16 As
already indicated, the claimants are no strangers to the "Lloyd's litigation".
In particular they were all parties to Lloyd's v Jaffray [2002] EWCA Civ 1101
and to the subsequent Taylor v Lawrence application in the Jaffray case: see
[2007] EWCA Civ 586 . Since the present proceedings focus on alleged
misrepresentation by Lloyd's as to the nature of "reinsurance to close" or
"RITC" made at the time when the claimants became names, this previous
involvement is said by Lloyd's to be of particular significance. 17 This
was because one of the ancillary grounds on which the Taylor v Lawrence
application had been made was that the court had been misled about the nature
of RITC. The claimants had put the point in this way: * i) The names had always
assumed and the court had accepted that the impact of RITC was to extinguish
any further liability on the part of the members of the closing syndicate. * ii) Lloyd's were however
wrongly now asserting that RITC was simply a form of reinsurance and not a
complete discharge in the sense of a novation. * iii) This was not the
case. But if it was the case, then it followed that the Court had been misled
in its understanding that the effect of RITC was to bring about a legal
transfer of all outstanding liabilities. 18 The
argument failed to get off the ground because it was clear from the terms of
its own judgment that the court in Jaffray had not been under the impression
that RITC operated as a novation. It followed that the court was not influenced
by any shared misunderstanding with the names that RITC operated as a novation
when it had concluded, as regards the main issue in the case, that Lloyd's
legitimately thought its audit procedures were capable of producing reliable
information for the purposes of reserving and solvency. 19 By way
of summary the court said this in rejecting the Taylor v. Lawrence application: "62. The names are simply
seeking to re-open the appeal in order to put forward an argument that was
always available to them but which no one thought, or wished, to pursue. It
does not depend on new evidence. At best all that has happened is that Mr.
Merrett, and through him the names, has become alive to a view of RITC which
had not previously occurred to him. And it is very doubtful whether the view of
RITC which Mr. Merrett says is now being put forward for the first time is of
any significance in relation to Lloyd's understanding in the early 1980s of the
effectiveness of the audit procedures. If it were, we are confident that the
argument would have been pursued vigorously. These disputes and the way in
which they arise are miles away form the proper ambit of Taylor v Lawrence ." 20 I
shall need to revert to this passage in due course but I have set this out at
an early stage because in the present application it is Lloyd's submission that
the claimants are seeking to resurrect the very same point yet again, albeit in
a somewhat different form. The claim now advanced is in deceit and is based on
the proposition that, at the time the claimants joined, Lloyd's fraudulently
misrepresented to them that RITC constituted a novation. The motive for these
further proceedings, it was submitted by Lloyd's, was solely for the purpose of
further delaying enforcement in respect of Equitas premiums and other sums due
to Lloyd's from the claimants. 21 The
claim was accordingly, it was submitted, an abuse of process. In any event,
Lloyd's contend that the claim is bound to fail: * i) because as regards the
cause of action: o a) there
is no real prospect of establishing a clearly identified and false
representation of fact; o b) there
is no real prospect of establishing conscious knowledge of the falsity; and o c) there
is no real prospect of establishing reliance. * ii) because there is no
real prospect of overcoming the limitation defence. Statutory
novation 22 Before
turning to those issues I must deal with one discrete matter relating to the
nature of RITC. It was, or at least became, common ground (with one exception)
that RITC was indeed a form of reinsurance. It did not constitute a novation.
The exception was Mrs. Adams. As I have already mentioned, she sought to
contend, in reliance on advice from Mr. Stephen Merrett, that in truth RITC
created a statutory novation. 23 Given
the way in which these proceedings have been set up, the point is simply not
open to her. Her particulars of claim make no mention of the point. She
participates solely on the basis that the question whether her claim should be
struck out stands or falls with the others. However since the point has been
raised, I will deal with it briefly in the interests of completeness. 24
Sections 49 to 52 of the Insurance Companies Act 1982 make provision for the
transfer of insurance business subject as appropriate to the approval of the
court or the Secretary of State. Such approval is dependent, amongst other
things, on notice to all relevant policy holders. If approval is forthcoming,
the transfer is effected by way of a statutory novation. It is this machinery
which is relied upon by Mrs. Adams. 25 There
are however special provisions as regards the transfer of business by or to
Lloyd's underwriters. Section 85 provides that sections 49 to 52 only apply to
such transfers if the conditions in subsection (2) are satisfied. They are: * i) the transfer is not
one where both the transferor and the transferee are members of Lloyd's; * ii) the Committee of
Lloyd's have by resolution authorised a person to act in connection with the
transfer; * iii) a copy of the
resolution has been given to the Secretary of State. None of
these conditions are satisfied in the present case and, accordingly, any
suggestion of statutory novation is misconceived. 26 In any
event, since it is fundamental to the case pleaded by David Harris that RITC
does not constitute a novation (whilst he claims Lloyd's stated otherwise at
the time he renewed his membership), it follows that the line of argument which
Mrs. Adams was anxious to pursue would completely undermine that case. In short
on the claimant's case, it would establish the absence of any
misrepresentation. I say no more about it. Mr
Harris' claim 27
Accordingly, I turn to the claim as advanced by Mr. Harris. This can be very
broadly summarised as follows: * i) The brochure furnished
to him by Lloyd's in 1983 contained representations as regards the process of
RITC to the effect that all liabilities of a closed year of account passed to
the names of the succeeding open year. Such representations were repeated and
confirmed in the Verification form furnished to Mr. Harris in the run-up to his
interview by the Rota Committee. * ii) As intended, Mr.
Harris relied on the representation in pursuing his application for membership. * iii) Mr. Harris continued
to rely upon the representations for each year of his participation, his last
year being 1991, during which period he sustained substantial losses. * iv) The representations
in the brochure and the verification form were untrue. As confirmed by legal
advice to Lloyd's and explained in documentation distributed to the names, the
names into whose years the risks were originally written remained liable
despite RITC. v) Further the representations were made by Lloyd's fraudulently
either because Lloyd's had no honest belief in their truth or because Lloyd's
made them recklessly, careless whether they were true or false. * vi) The first time that
Mr. Harris knew or could with reasonable diligence have discovered that he had
any cause of action in this regard was August 2007 when the content of various
statements made by Mr Merrett together with various exhibits were closely
examined. Thus, by virtue of s.32 of the Limitation Act 1980 the claim is not
time barred. The brochure 28 This
was a document which was provided to all applicants for underwriting membership
of Lloyd's. Amendments were made year by year. The edition furnished to Mr.
Harris in 1983 provided as follows: "...This brochure is intended
to inform the recipient and his advisers of many general facts concerning the
organisation and operation of Lloyd's and is not intended to be an offer of
Membership of Lloyd's nor the solicitation of an application for Membership of
Lloyd's. This brochure should be read in conjunction with other materials
provided to the recipient in the process of his application for Membership of
Lloyd's. Unlimited liability A Member of Lloyd's is
severally liable for a specific share of risk on every policy underwritten by
him through the syndicate of which he is a member ....However in the event that
the chain of security described at 8.1 - 8.4 is insufficient to pay all the
claims made against the Member, he will be assessed to the entire amount of his
personal fortune to pay any valid claims against him. Non-transferability of
Membership ....The position with regard
to resignation from a syndicate will be as laid down in the agreement between
the Member and his Underwriting Agent. The Member may join one or more syndicates
at the beginning of any year. In the event of a Member's death or resignation
from Lloyd's he remains liable (or in the case of his death, his estate remains
liable) on all insurance policies underwritten by him, during the time of his
Membership, through syndicates in which he was a member. It may be that the
terms of his underwriting agreement provide for his participation in the
policies underwritten by his syndicates during the whole of the year in which
his resignation or death occurs. His deposit will be retained by the Committee
of Lloyd's in trust until such time as the Committee is satisfied that all
underwriting liabilities have been paid or provided for in a manner approved by
it. The deposit will be returned no sooner than the time the Member's last year
of account (for description of year of account see "Lloyd's System of
Accounting" at 10) is closed by reinsurance: this will normally be at least two
years after the effective date of his resignation or the end of the year of his
death, as the case may be." Description Of Security "... 8.5 Each member is obliged
each year to contribute by means of a levy on premium income to a Central fund
and contributions are collected from the syndicates concerned. This fund is
held and administered under a Trust Deed by the Corporation and the Committee
of Lloyd's and the purpose of the Fund is to meet underwriting liabilities of
any Member in the event that his security and personal assets are insufficient
to meet his underwriting commitments. The fund is for the protection of the
holders of Lloyd's policies, not the member, who is still responsible for his
liabilities to the full extent of his private wealth." 28 "Lloyd's System of
Accounting 10.4 ... Once this liability
has been estimated on the account at the end of its third calendar year, it
must be reinsured by a valid policy of reinsurance before the account can be
closed ..." 28 "Closing Reinsurance 11. When the estimated
outstanding liability on a year of account is determined at the end of the
third year pursuant to the provisions of the Lloyd's audit, a syndicate will
usually close the account by reinsuring such liability into a later year of the
syndicate. This is accomplished by the members of the old syndicate paying a reinsurance
premium to the new syndicate. The new syndicate then assumes any future
liability which may be incurred as a result of claims on the policies written
by the old syndicate. Being an estimate of future liability, the reinsurance
premium may or may not eventually be proven accurate. In certain cases it has
been inadequate and the new syndicate has suffered losses in excess of the
reinsurance premium received; in such cases Members in the new syndicate would
suffer a loss on the reinsurance to close. ... 28 "Glossary of Terms 28 "Closed years An underwriting account of
a syndicate which has been debited with a reinsurance premium to close the
account ... is known as a 'closed' account ... 28 "Reinsurance to Close The method by which the
outstanding liability on the Underwriting Account of a Lloyd's Syndicate for
any one year of Account is closed (usually, but not necessarily, at the end of
its third year) by reinsuring such liability into the Account of a later
Underwriting Year. A reinsurance premium is
charged to the Underwriting Account of the closing year and credited to that of
the reinsuring year, which then adds to its liabilities a sum equal to the
reinsurance premium so received and pays all claims which would otherwise be
the liability of the Underwriting Year reinsured." 29 As
already indicated, the claimants each received different editions of the
brochure. The description of RITC varied somewhat but not in my judgment in any
material respect. In this respect, it is instructive to have regard to the
terms of the earliest and latest relevant versions as regards RITC. In 1975,
the "Notes for Applicants" said this: 29 "Lloyd's Audit Under the Lloyd's system of
accounting the accounts for the business underwritten in each year are normally
kept open for three years. When the underwriting account is closed at the end
of the third year, a reserve is made in respect of outstanding liabilities and
this amount, designated a 'reinsurance' to close the account, is carried to the
credit of a later underwriting account." 30 In
very limited contrast, by 1987 it was defined as follows: "Reinsurance to close: the
method by which the outstanding liability of a year of account is closed by
reinsuring such liability to a later year of account in consideration of the
payment of a premium equal to the estimated value of known and unknown claims." Rota
Committee 31 Part
of the process of obtaining membership (and specifically referred to in the
brochure provided to Mr Harris) was an interview of the applicant by a Rota
Committee to ensure that the applicant was fully cognisant of the implications
of unlimited liability. The candidate was interviewed in a formal and
prescribed manner against an agenda or briefing note. The relevant version for
Mr Harris required the Committee to obtain confirmation from the candidate of
various matters as follows: "1. Confirm that the
candidate understands that - a) His liability is
unlimited and that everything he owns is at risk to support this liability also
that on his death this liability passes to his estate ... 3. Confirm - ... c) Candidate has seen at
least seven closed years figures in the form recommended by the committee for
the syndicates he proposes joining, together with an indication of the results
of the open years ..." Verification
form 32
Following the interview, a Verification Form had to be completed by the
applicant. Quite when this form was introduced remains unclear although it is
accepted that at least 15 of the claimants did not sign one. The verification
form which was duly signed by Mr. Harris stated: "(2) I understand the
following matters which have been explained to me by my underwriting agent: a) The underwriting of
insurance is a high risk business and profits are not guaranteed. b) As an underwriting
member of Lloyd's my liability is unlimited and in the event of my death my
estate will inherit my unlimited liability in respect of business underwritten
by me during my membership. c) I can only resign in
accordance with the rules explained to me by my underwriting agent and if I
resign I shall continue to remain liable until my last underwriting year has
been closed by reinsurance. d) Upon my resignation or
death my deposit ... will not be released until my last year of account has been
closed by reinsurance. This will be at least two years after my resignation or
death unless a suitable reinsurance policy exists. e) I will inherit liability
for claims arising out of losses which may have occurred prior to my becoming
an underwriting member of Lloyd's." The
alleged misrepresentation 33 The
claimants' case was that the brochure whether read in isolation or in
conjunction with the verification form was a clear statement to the effect
that, following RITC, no further liability to the names on the closed year
could arise and that nothing was said in the course of the Rota Interview to
contradict the position. In short the complaint was that the prospective names
were being told incorrectly that, as a matter of legal analysis, all the
contracts with the policyholders were novated by virtue of the RITC. On this
basis, names could accordingly thereafter resign and their estates could be
distributed all without any further residual exposure. 34 The
position of Lloyd's was that the contents of these documents were not intended
to, and did not, contain a legal analysis of the consequences of RITC. It did
not assert that there would be a novation: indeed it was clearly stated that it
was a form of reinsurance. The documents simply reflect the factual position
that, when a year was closed into a year in which a name was not a member, that
member had no further involvement despite the theoretical risk of residual
exposure. The elimination of that risk flowed from the security of the RITC
contract and, in the event any default on the part of the reinsuring syndicate,
the Central Fund. 35 It was
accepted by the claimants that the central fund underpinned the RITC mechanism
allowing for payment in the event of a default thereby avoiding recourse to the
names on the year of account in which the policy was written (although no such
recourse had in fact ever been necessary). Thus the fact that such was the
practical position was not controversial. Indeed such was confirmed in Lloyd's
v Clementson [1997] Lloyd's Reinsurance Rep. 175 at para 14.17: "A Name has been regarded
by the DTI as ceasing to conduct business when all his open years have been
closed by RITC. Because RITC is treated as ending a Name's involvement in a
syndicate for regulatory and tax purposes, it is effectively the mechanism
whereby a name is released from his membership of Lloyd's": per Cresswell J at
para 14.7. Origin of
allegation 36 The
complaint regarding the alleged misrepresentation did not see the light of day
until August 2007 with the claim form following shortly afterwards in October
2007. It arose from material annexed to a witness statement of Mr Stephen
Merrett dated October 2006 which was deployed by the claimant names in the
Court of Appeal in relation to the appeal in Henderson and the Taylor v.
Lawrence application in Jaffray : see further below. The exhibits included
documents provided to Mr Merrett by Lloyd's legal department in his capacity as
Deputy Chairman. The most significant material took the form of the advice from
counsel in respect of which Lloyd's could otherwise have claimed privilege. 37 The
first such advice emerged shortly after Mr. Harris was interviewed by the Rota
Committee. Lloyd's sought the opinion of Mr. Adrian Hamilton Q.C. as to the
nature of RITC. The instructions to Mr. Hamilton prepared by Lloyd's legal
department expressed the view that, notwithstanding expressions of opinion to
the contrary, "liability for risks underwritten at Lloyd's remain with the
syndicate of Names into whose years of account the risks were originally taken
down." It is also clear from the note of the subsequent conference with Mr.
Hamilton that he shared that view. RITC, he opined, was indeed a form of
reinsurance. The old names remained liable to the insured but were exonerated
by the indemnity given by the new names. 38 The
reason for focussing on the true nature of RITC in the mid-1980s was a dispute
that had arisen between Lloyd's and the Inland Revenue. The Revenue was taking
the line that the sums payable by way of RITC to the succeeding year's
syndicate was in fact a reserve. (Indeed, ironically in the light of subsequent
catastrophic events, the Revenue was alleging that syndicates were over
reserving for tax avoidance purposes.) In contrast, it was Lloyd's contention
that the sums represented a premium for reinsurance cover, a stance that in the
event was never formally challenged. 39
Consistent with this view of the nature of RITC, the Council of Lloyd's made a
byelaw in 1984. This is referred to in more detail below. Thereafter, in
September 1986, as the dispute with the Revenue rumbled on, the second item of
legal advice saw the light of day. Lloyd's sought advice from Mr. Nicholas Phillips
Q.C. A note of the ensuing consultation reveals that Mr. Phillips' opinion was
that the byelaw accurately defined the true position in that RITC was indeed
reinsurance and not a form of reserving. 40 The
note goes on: "Although technically an assured
could look to the members on old years that have since been reinsured in the
event that the reinsurers default in paying the assured, it would be,
presumably, a matter of policy for Lloyd's to state that the onus lies only on
the members of the latest reinsuring syndicate to pay the assured and, if they
do not, then Lloyd's itself (through its Central Fund or otherwise) would see
to it that the assured is paid. It would not be necessary to legislate for
this." Against
that background, Mr. Phillips is recorded as saying, in agreement with his
instructions from Lloyd's legal department, that, while "legally" the old names
remain on risk, "in practice there is a novation." 41
Thereafter, in October 1986, Mr. Phillips wrote a joint opinion with Mr. John
Gardiner Q.C. which confirmed the earlier advice. Paragraph 8 of the opinion is
of particular significance:- "8. In concluding the
multiplicity of contracts which make up a reinsurance to close, the Managing
Agent acts for all parties and owes duties to each. Contractually between the
Names the effect of the reinsurance to close is to pass, in consideration of a
premium, the risk of liabilities of the closed year. The Names of the
succeeding year undertake to pay all claims outstanding against the year that
is being closed and become entitled to receive all insurance recoveries etc.
that would otherwise be payable to the closing year. The Names of the
succeeding year are paid a premium for undertaking such risks. Strictly the old
Names probably remain liable to the assured under their original contracts of
insurance. In practice such liabilities are discharged directly by the new
Names. In practice a broker acting for the assured makes a claim against "the
Syndicate" without reference to the year of the Syndicate when the risk was
written or to the Names who were then on that Syndicate. It could be argued
that this practice is such an integral part of the way business is done at
Lloyd's that all who insure at Lloyd's accede to it, so that the reinsurance to
close is not merely a multiplicity of bilateral reinsurance contracts but a
multiplicity of novations. This sophistry in no way affects the principles of
taxation with which we are concerned ; [ emphasis added ]." 42 The
third element of the legal advice produced by Mr Merrett to the claimants dated
from 1993 when Mr. Stewart Boyd Q.C. was instructed to comment on the draft
Business Plan that in due course was to form the basis of the Reconstruction
and Renewal programme. He was asked the question whether Lloyd's were under any
duty to disclose to its membership the legal nature and effect of RITC. He
stated in terms that there was no duty of disclosure at any stage whether at
the Rota Committee at the earliest or the business plan at the latest. However
he confirmed that Lloyd's was under a duty to ensure that any representations
that were made to the membership were true. 43 In
this regard his attention was drawn to the Rota interview documentation
referred to above (and in particular the Verification Form) to the effect that
the proposed member would remain liable for his share of the business "until
the account is closed". He described this as "misleading". It is this
observation which caught the eye of the claimants when studying Mr Merrett's
witness statement with greater care after the Taylor v. Lawrence application. 44
However it is important even at this stage to note that Mr Boyd went on his
written opinion to say this: "The member remains legally
liable for his share of the business until the account is run off to
extinction. However, the difference has probably not been material until now.
The RITC has in practice proved effective from a practical point of view to
close the account so far as Lloyd's, the Inland Revenue and the DTI are concerned
because the RITC has had a Lloyd's syndicate and a Lloyd's Central Fund as
security, and the security has never failed." 45 The
reason why this distinction had become material was because the Business Plan
involved reinsurance of all open years into a corporate vehicle so that the old
liabilities were ring fenced. Thereby it was arranged that those continuing
their membership or joining thereafter would not be exposed to these
liabilities. Importantly therefore, any deficit would not be met from the
Central Fund, a matter which needed to be drawn to the attention of all names. 46 In any
event, prompted by this suggestion that the Verification Form was misleading in
stating that liability remained "until" the account was closed, taken with the
revelation that Lloyd's had been advised in terms that RITC was a form of
reinsurance and not a novation, the claimants issued these proceedings. Abuse of
process 47 It is
worth repeating the relevant statement of principle as contained in Johnson v
Gore-Wood [2002] 1 AC 1 , per Lord Bingham at 30 - 31:- "The underlying public
interest is ... that there should be finality in litigation and that a party
should not be twice vexed in the same matter. This public interest is
reinforced by the current emphasis on efficiency and economy in the conduct of
litigation, in the interests of the parties and the public as a whole. The
bringing of a claim or the raising of a defence in later proceedings may,
without more, amount to abuse if the court is satisfied (the onus being on the
party alleging abuse) that the claim or defence should have been raised in the
earlier proceedings if it was to be raised at all. I would not accept that it
is necessary, before abuse may be found, to identify any additional element
such as a collateral attack on a previous decision or some dishonesty, but
where those elements are present the later proceedings will be much more
obviously abusive, and there will rarely be a finding of abuse unless the later
proceeding involves what the court regards as unjust harassment of a party. It
is, however, wrong to hold that because a matter could have been raised in
earlier proceedings it should have been, so as to render the raising of it in
later proceedings necessarily abusive. That is to adopt too dogmatic an
approach to what should in my opinion be a broad, merits-based judgment which
takes account of the public and private interests involved and also takes
account of all the facts of the case, focusing attention on the crucial
question whether, in all the circumstances, a party is misusing or abusing the
process of the court by seeking to raise before it the issue which could have
been raised before. As one cannot comprehensively list all possible forms of
abuse, so one cannot formulate any hard and fast rule to determine whether, on
given facts, abuse is to be found or not ... Properly applied, and whatever the
legitimacy of its descent, the rule has in my view a valuable part to play in
protecting the interests of justice." 48 It was
Lloyd's submission that the present proceedings were a paradigm example of
abuse of process. The foundation to this submission was this. Given the long
history of the Lloyd's litigation and the desire of the Commercial Court to
conduct its business efficiently, it was the clearly expressed intention of the
court in Jaffray that it would constitute the one and only opportunity for
prosecuting a claim in fraud against Lloyd's. As Mr. Justice Cresswell stated
in a case management conference in June 1999: "This is the fraud case against
Lloyd's and there will not be further fraud cases against Lloyd's." 49 The
background in brief was as follows. The claim in Jaffray got underway in 1998.
In an order for directions made by Colman J on 4 June 1998 the solicitors
acting for the names were required to identify what categories of fraudulent
misrepresentation were to be relied upon. Category 1 was expressed as follows: "Damages for fraudulent
and/or negligent misstatement and/or misrepresentation arising out of or made
prior his or her admission as a name in particular statements made in the
Brochure for applicants for underwriting membership for the year of joining
between the years 1977 and 1995." Despite
the open ended nature of this category, the threshold fraud point was narrowed
down in the event by the names to an allegation of misrepresentation in the
brochures and other publications of Lloyd's with respect to asbestos claims.
Nonetheless the names had had every opportunity to put forward any different
formulation thought to be arguable. 50 At a
case management conference on 29 October 1999, Cresswell J (the judge in charge
of the Lloyd's litigation) ordered that any name who wished to pursue this
narrower allegation had to give notice or otherwise be shut out from advancing
it later. He made it clear that the Jaffray proceedings were to be regarded as
a test case which will dispose of all cases of the same "type" and that the
court would not countenance further allegations of fraud by reference to
misrepresentation being made in future proceedings - all the more so if the
issues could and should have been raised earlier on Henderson v Henderson
principles. 51 In the
absence of any broader complaint being advanced by any of the names then party
to the Jaffray proceedings (including the present claimants) the form of order
contained the following paragraph: "Any individuals being
present or former members of Lloyd's, who wish to reserve the right to advance
allegations that they were fraudulently induced to become or remain
underwriting members of the Lloyd's market by reason of Lloyd's failure to
disclose the nature and extent of the market's liability for asbestos-related
claims, must provide written notice to Lloyd's solicitors, Freshfields, at 65
Fleet Street, London EC4Y 1HS (ref RDP/GN, fax number 832 7001) by no later
than a.
3 December 1999, in the case of an individual ordinarily resident in the United
Kingdom and Europe, b.
10 December 1999, in the case of other individuals, confirming that they wish
to become parties to the litigation. Failing timely service of such a notice,
these individuals will thereafter be precluded from advancing such allegations
without leave of the Commercial Court. An individual who provides written
notice by the specified date will be deemed to have become a party to the
proceedings on date of receipt of such notice, and will be bound by the Court's
determination of the Threshold Fraud Issue ordered to be tried as a preliminary
issue herein." 52 It is
not necessary to cite from the judgment of Cresswell J. But it should be noted
that the RITC process is described throughout, consistently with the agreed
statement of facts (and the 1984 bye-law), as a reinsurance contract between
the members of the closed year and the members of a later year. Further, if and
to the extent it could be argued that the brochures or verification forms
suggested otherwise or were inconsistent with the bye-laws or the Business
Plan, the penny did not drop so far as the claimants were concerned. All this
despite all editions of these documents being thoroughly reviewed during the
course of a 64 day long trial. 53
Similar considerations arise with regard to the hearing in the Court of Appeal
over a further 14 days. Still no suggestion was made that the very same parts
of the brochure relied on as constituting a misrepresentation in regard to
auditing (in particular paragraph 10.4 of the brochure) also contained a
misrepresentation as to the nature of RITC. This was perhaps all the more remarkable
given the exchange between counsel for the names and Lord Justice Clarke, in
analysing the concept of RITC on day 2, to the effect that it was well
understood by the names that in regard to a policy taken out in, for instance,
1946 the insured would make a claim against the 1946 names who would in turn
claim under all the succeeding reinsurances. 54 In its
judgment in Jaffray [2002] EWCA Civ. 1107 at para 500, the Court rehearsed the
scope and purpose of the trial as outlined above: "500. At a case management
conference on 29 October 1999 Cresswell J, who was of course in charge of the
Lloyd's litigation, decided that any names who wished to reserve the right to
advance a case that they had been induced to become or remain members of
Lloyd's by reason of Lloyd's failure to disclose the nature and extent of the
market's liability for asbestos-related claims must give notice that they
intended to become parties to the litigation. He made an order to that effect.
Such an order was plainly appropriate since it would be unthinkable for either
names or indeed Lloyd's to be able to use valuable court resources twice (or
many times) in order to have the same issues determined (emphasis added) ." 55 The
Court of Appeal dismissed the appeal but in doing so held that the
representations relied upon by the names (as reformulated) were false but that
such was not known to be false by Lloyd's. Encouraged by this somewhat pyrrhic
victory, some of the names (including the claimants) sought to amend the claim
in Jaffray in various respects, including reliance on alleged fraudulent
misrepresentations other than those advanced and determined by Cresswell J and
the Court of Appeal. In particular, the names sought to contend that the
representation in the brochure about a rigorous audited assessment of
outstanding liability was false (or at least negligently made) in that not only
had the audit in fact led to large scale under reservation but it was also not
actually capable of producing a reasonable estimate. 56 The
application was in large part refused by Cooke J: [2003] EWHC 873 (COMM).
Having outlined the history of the Jaffray proceedings, Cooke J made the
following comment: "4. On 1st November 1999,
Cresswell J made a further order for directions. In this order, as in others,
additional Names were identified as counterclaiming Names and in each case,
where the Name had no existing proceedings, a date was specified as the deemed
date of commencement for Limitation Act 1980 purposes. He ordered that any Names
who wished to advance allegations of fraudulent inducement to become or remain
an Underwriting member of Lloyd's by reason of Lloyd's failure to disclose the
nature and extent of the market's liability for asbestos related claims had to
provide written notice by a specified date, failing which they would thereafter
be precluded from advancing such allegations without the permission of the
Court. As a result of this order (as appears from the statement sent on the
Court's instructions to Names who were in dispute with Lloyd's) the Court hoped
to ensure that all fraud arguments would be enshrined in the Threshold Fraud
Trial and would be determined once and for all, between Lloyd's and all
non-accepting Names, however such fraud claims were framed, whether by
reference to misrepresentation or non-disclosure of information ( emphasis
added )." The Court
of Appeal dismissed an appeal from Cooke J ([2003] EWCA Civ 1887 ) without
needing to touch on these issues. 57 Yet
another application to amend the Jaffray proceedings was made in Henderson .
This involved an unsuccessful attempt to introduce a claim for misfeasance in
public office: [2005] EWHC 850 (Comm). This failed both at first instance and
later on appeal. Andrew Smith J refused the application because amongst other
reasons given the court's strategy for the management of the Lloyd's litigation
and the long delay in pursuing the newly formulated case of fraudulent
misrepresentation the amendment should be refused as a matter of discretion,
even if it was unnecessary to go so far as to characterise it as an abuse of
process on Henderson v. Henderson principles. "83 ... the applicants have
had ample opportunity in the past to make the allegations that they now seek to
advance and have not previously done so. They seek permission to make them more
than eight years after R&R. No proper reason has been given for the delay
in pursuing these claims. If names thought that they would or might advance a
claim of misfeasance in public office involving allegations of this kind (or
indeed at all), it should have been mentioned at the case management conference
before the trial of the Threshold Fraud Point..." 58 The
decision of the Court of Appeal was to similar effect ( [2007] EWCA Civ 930 ).
Buxton LJ said as follows at para. 63: "63 ... I have no doubt that
... the attempt to introduce Misfeasance in Public Office into the case at this
stage is an abuse of process ... as early as 1997 leading counsel for the names ...
indicated that the pleading of misfeasance in Public Office was under
consideration. That step was not taken even when ... it was made clear that the
structure of the enormously expensive TFP proceedings had been set up in order
to deal at one time with all of the allegations of fraud sought to be brought against
Lloyd's. It is plain abuse to come back to court now, after having gone
unsuccessfully through the whole of the TFP trial and appeal, with a new claim
that it was decided ten years ago not to plead." 59 But in
the meantime a Taylor v Lawrence application had been made in Jaffray: [2002]
EWCA Civ. 1101 . The point arising here was the desire to argue that the
falsity of the representations made as regards the soundness of Lloyd's
accounting system was demonstrated by the fact that RITC was only reinsurance.
This was premised on evidence from Mr. Stephen Merrett that Lloyds had
portrayed RITC as a contract to transfer liability and thereby achieve
"closure". Mr. Merrett put the matter this way: "1.5 Lloyd's suggestion
that Names on historic years of account retain a residual liability to
policyholders, and that it is those names in that role who face policyholders
claims and who are legally dependent on a successful claim against each name
participating in the RITC of that underwriting year, is a change in position
which has never been notified by Lloyd's to the Names whom Lloyd's now says
have this ongoing liability." 60 It was
thus said that the fact that RITC was not by way of "closure" but a form of
reinsurance falsified any representation relating to the rigour of the audit
procedure. (Notably the present proceedings bring matters full circle since the
names now seek to establish that the representation was to different effect -
namely that RITC constituted a novation - which in turn was false because it
was in fact reinsurance.) 61 The
application failed for the following reasons: "60. This part of the
names' case depends on the following propositions: (a) that when hearing the
appeal the court understood that the effect of RITC was to bring about a legal
transfer of outstanding liabilities from the Names on the closing year to the
Names on the next open year; (b) that that was an important factor in its
finding that Lloyd's thought that the audit system was capable of producing
reliable information about outstanding liabilities and solvency; (c) that if
Lloyd's is right in saying that RITC operates merely as a reinsurance, the
court was misled; (d) if the court had realised that RITC operates merely as
reinsurance, its finding about Lloyd's perception of its audit system would
have been different and fraud would have been established. 61. This argument fails at
the first stage. In ¤ 373 of its judgment the court adopted the description
given by Mr. Outhwaite in his statement in Stockwell v RHM Outhwaite
(Underwriting Agencies) Ltd of the way in which reserves were set. In the light
of that evidence there is no basis for saying that the court was under the
impression that RITC operated as a novation of names' liabilities to the
original policyholders. If that is right, it follows that when reaching the
conclusion that Lloyd's thought that its audit procedures were capable of
producing reliable information for the purposes of reserving and solvency the
court was not influenced by an understanding that RITC involved a transfer of
legal liabilities, whether that be the correct view or not": per Buxton LJ. As
already noted the court was of the view that the names were simply seeking to
put forward an argument that was always available to them but which "no one
thought, or wished, to pursue". 62 The
present proceedings are, in my judgment, unquestionably an abuse of process: * i) The court has been at
pains to structure the Lloyd's litigation in an efficient way. * ii) The claimants were
all parties to the Jaffray action. * iii) This was decided at
first instance by the judge then nominated by the Commercial Court to be in
charge of the Lloyd's litigation. * iv) The action was
designed to deal with the fraud defence raised by the names in Lloyd's v Leighs
. * v) The action was
constructed so as to furnish an opportunity for any name to pursue a claim
based on some form of fraudulent representation by Lloyd's which had allegedly
induced him or her to become a name. * vi) The documents
primarily relied upon in the present proceedings as containing the fraudulent
misrepresentation were at the forefront of the Jaffray litigation. * vii) It is an abuse of
process to allow the marshalled proceedings in respect of fraud to be
undermined by a later action, based on the same cause of action and indeed the
same documents. 63 It
follows that in my judgment the action should be struck out. Deceit 64 If I
am wrong in reaching this conclusion I must turn to the next consideration as
to whether there is an arguable case on the merits. It was common ground that
the claimants' claim was in deceit. The elements of the tort were fully
discussed in The Kriti Palm [2007] 1 All ER (Comm) 667 : "252. At the basis of any
claim in deceit is the representation in question. Its falsity, and the honesty
of the representor, cannot begin to be considered until the representation in
question has been identified. In the case of a written document, the
representation can usually be pinpointed (unless questions of implication
arise), but of course context remains everything. In the case of an oral
representation, the identification may be a more difficult process, involving
disputed testimony, but again context remains everything... 253. It is sometimes said
that the necessary representation must be unequivocal. That is too broad a
statement to be accurate. Because dishonesty is the essence of deceit it is
possible to be fraudulent even by means of an ambiguous statement, but in such
a case it is essential that the representor should have intended the statement
to be understood in the sense in which it is understood by the claimant (and of
course a sense in which it is untrue) or should have deliberately used the
ambiguity for the purpose of deceiving him and succeeded in doing so... 254. It remains true,
however, that in any case of fraud the dishonest representation must be clearly
identified. 255. It is also standard
law that to found an action in deceit the representation relied on must be one
of fact. A statement of opinion will not suffice unless the deceit is in the
fact that the opinion was not, or not honestly, held or in some further
implicit dishonest misrepresentation of fact to be derived from the statement
of opinion; and neither will a misstatement of law suffice save on the same
ground that it involves implicitly a misstatement of fact, viz that the
representor did not in fact entertain the opinion of law which he expressed... 256. As for the element of
dishonesty, the leading cases are replete with statements of its vital
importance and of warnings against watering down this ingredient into something
akin to negligence, however gross. The standard direction is still that of Lord
Herschell in Derry v. Peek (1889) 14 App Cas 337 at 374:
"First, in order to sustain an action in deceit, there must be proof of
fraud and nothing short of that will suffice. Secondly, fraud is proved when it
is shown that a false representation has been made (1) knowingly, (2) without
belief in its truth, or (3) recklessly, careless whether it be true or false." 257. In effect,
recklessness is a species of dishonest knowledge, for in both cases there is an
absence of belief in truth. It is for that reason that there is "proof of
fraud" in the cases of both knowledge and recklessness ... 258. And in Armstong v.
Strain [1951] 1 TLR 856 at 871 Devlin J, after a full citation of passages in
earlier authorities which stress the need for dishonesty (also called actual
fraud, mens rea, or moral delinquency), said this about the necessary
knowledge: "A
man may be said to know a fact when once he has been told it and pigeon-holed
it somewhere in his brain where it is more or less accessible in case of need.
In another sense of the word a man knows a fact only when he is fully conscious
of it. For an action of deceit there must be knowledge in the narrower sense;
and conscious knowledge of falsity must always amount to wickedness and
dishonesty. When Judges say, therefore, that wickedness and dishonesty must be
present, they are not requiring a new ingredient for the tort of deceit so much
as describing the sort of knowledge which is necessary."" 65 Thus
in summary the position is as follows: * a. The Defendant must
have made a representation which can be clearly identified. * b. It must be a
representation of fact. * c. The representation
must be false. * d. The representor must
have intended the statement to be understood in the sense that it was so
understood. * e. It must have been made
dishonestly in the sense that the representor had no real belief in the truth
of what he stated: this involves conscious knowledge of the falsity of the
statement. * f. The statement must
have been intended to be relied upon. * g. It must have in fact been relied upon. 66 The
question therefore arises whether there is any realistic prospect of the
claimants making good all these ingredients remembering in addition that they
must be established by reference to the heightened burden of proof as discussed
in Hornal v Newberger Products Ltd [1954] 1 Q.B. 247 , Re H (minor) [1996] A.C.
563 . In my judgment it is plain that there is no such prospect. Claimants'
case 67 The
claimants' case was gravely undermined by the moving target that they put up in
alleging deceit. In this regard the following propositions relating to the
description of RITC in the brochure were advanced from time to time: * i) RITC was a form of
reinsurance and understood as such throughout * ii) RITC was a form of
novation and understood as such throughout * iii) RITC was formerly
understood as a novation and later thought to constitute reinsurance. 68 The
claimants then went on to argue variously the following somewhat inconsistent
positions: * i) The names "take no
formal position" on the effect of RITC: it is uncertain in its nature and
effect and Lloyd's dishonestly failed to correct any potential for
misunderstanding that arose from the brochure. * ii) It is a form of
novation: Lloyd's dishonestly failed to disclose that there was an alternative
view. * iii) Lloyd's had
originally thought it to be a form of novation but fraudulently failed to tell
the names that they had changed their view. * iv) Lloyd's had
originally thought it was a form of novation but dishonestly failed to tell the
names that it had received advice from counsel that it was a form of
reinsurance. * v) Lloyd's correctly
appreciated that it was a form of reinsurance but dishonestly described it as a
form of novation. * vi) Lloyd's fraudulently
failed to amend the verification form in the light of Mr Boyd's advice but
fraudulently produced a Bye-Law to different effect to that advice. Clearly
identified representation of fact 69
Reverting to the pleaded case, this is set out in paragraph 10 of the
particulars of claim: 69 "The representations by
Lloyd's 10. In the circumstances of
his membership application as described above, the statements made by Lloyd's
to Mr. Harris in the brochure and the Verification Form, and the lack of any
qualification to those statements by the members of the Rota Committee,
constituted representations to him by Lloyd's (1) that if he became a
Name he would continue to have liabilities to policyholders until the last
underwriting year of account for all syndicates of which he had been a member
had been closed by RITC; and (2) that the effect of RITC
was to close the outstanding liability for a year of account on a particular
syndicate; and (3) that the syndicate of
the reinsuring year which had accepted the RITC would assume all future
liabilities of the reinsured account; and (4) that a Name's liability
to policyholders ceased on payment of RITC because the liability had been
transferred to the syndicate accepting the RITC. The first three
representations were express (from the Verification Form (1) and from the
brochure (2) and (3)). The fourth was implied from the first three. Mr Harris
understood these representations as statements of fact as to the effect of the
law or alternatively, if he understood them only as statements of fact he also
understood that they implied that they were correct in law." 70 In my
judgment it is obviously arguable that the first three representations were made.
Whether the fourth is implicit is far less clear. In effect it is being
contended that Lloyd's were setting out by implication not just the practical
effect of RITC but also its legal effect as being in the form of a novation,
statutory or otherwise. Further, if and insofar as it was being understood to
be going any further than the three express representations, it was not a
representation of fact but of law. Given the context of the express
representations, I have the gravest doubts whether any objective reader would
regard the documents as containing an implied analysis of the law on the topic. False 71 The
first three representations were not false. They reflected an entirely accurate
picture of the impact of RITC. The practical effect was to release the name in
the closed year from any liability. This would be absorbed in the form of
reinsurance by the next year's syndicate, failing which the central fund would
meet any default. It follows that these representations were not even
misleading save in a sense wholly without significance. 72 As
regards the implicit representation, that is to say to the extent that the
representations are said to constitute a statement that the impact of RITC was
to create a novation of the business written in the earlier year, there is no
material whatsoever to support the case that Lloyd's held that opinion or
indeed intended that it should be understood in that sense. Knowledge
of falsity 73 The
first difficulty here is that the names somewhat fought shy of alleging dishonesty.
The proposition was advanced that Lloyd's had simply been reckless. But this
flies in the face of the decision in the Kriti Palm warning against any
watering down of this ingredient. In any event, there is no material on which
it could be concluded that Lloyd's were acting dishonestly in making the
representations. They genuinely reflected the practical position. RITC was
indeed a form of reinsurance with the added obligation on the part of the open
year to manage and pay claims arising from the closed year. Such had been
Lloyd's understanding throughout. In the run up to the dispute with the
revenue, the legal advice afforded to Lloyd's shared this understanding -
namely a practical form of novation. Leaving aside the absence of any
conceivable motive on the part of Lloyd's to wish to mislead its members
deliberately in this respect, in the light of the contents of the joint opinion
of Mr Nicholas Phillips QC and Mr John Gardiner QC, it is not arguable that
Lloyd's could be shown to have had conscious knowledge of the falsity of the
statements. Reliance 74 It is
almost impossible to discern how the claimant will be able to make good any
form of reliance. It is common ground that he was accepting total and unlimited
exposure on any open year. It is inconceivable that, in contrast, the
"sophistry" of the distinction between the legal and practical effect of RITC
would have been viewed by him as of any significance. This is confirmed by the
failure to raise the issue until 2007 and only then in the wake of Mr.
Merrett's suggestion that RITC created a statutory novation. Limitation 75 Again,
if I am wrong about this, there remains the issue of limitation. In fact many
of the points made under this heading also reinforce the conclusion that there
was no false representation that was relied upon in the first place. 76 Mr.
Harris stopped underwriting in December 1991. It follows that his cause of
action based on his alleged reliance on a fraudulent misrepresentation in the
brochure and/or verification form arose in late December 1990 when he joined
the 1991 syndicates. It further follows that, by virtue of section 2 of the
Limitation Act 1980 , the time limit for bringing any action expired in
December 1996. 77 This
of course is subject to section 32 of the Act which so far as material reads as
follows: Postponement of limitation
period in case of fraud, concealment or mistake (1) Subject to [subsections
(3) and (4A)] below, where in the case of any action for which a period of
limitation is prescribed by this Act, either- (a) the action is based
upon the fraud of the defendant; or (b) any fact relevant to
the plaintiff's right of action has been deliberately concealed from him by the
defendant; or (c) the action is for
relief from the consequences of a mistake; the period of limitation
shall not begin to run until the plaintiff has discovered the fraud,
concealment or mistake (as the case may be) or could with reasonable diligence
have discovered it. References in this subsection
to the defendant include references to the defendant's agent and to any person
through whom the defendant claims and his agent. (2) For the purposes of
subsection (1) above, deliberate commission of a breach of duty in
circumstances in which it is unlikely to be discovered for some time amounts to
deliberate concealment of the facts involved in that breach of duty." 78 The
exercise of reasonable diligence was considered by the Court of Appeal in
Paragon Finance v Thakarar [1999] 1 All ER. 400 :- "In my judgment this
reasoning is misconceived. The question is not whether the plaintiffs should
have discovered the fraud sooner; but whether they could with reasonable
diligence have done so. The burden of proof is on them. They must establish that
they could not have discovered the fraud without exceptional measures which
they could not reasonably have been expected to take. In this context the
length of the applicable period of limitation is irrelevant. In the course of
argument May LJ observed that reasonable diligence must be measured against
some standard, but that the six-year limitation period did not provide the
relevant standard. He suggested that the test was how a person carrying on a
business of the relevant kind would act if he had adequate but not unlimited
staff and resources and were motivated by a reasonable but not excessive sense
of urgency. I respectfully agree": per Millett LJ at p.418. 79
Further, in considering the application of Section 32 , it must be borne in
mind that the inquiry is directed at establishing when the relevant facts
needed to establish a prima facie case were gleaned. That is to say that the
focus is on the existence of the cause of action not the evidence which will
prove the case: see C v Mirror Group Newspapers [1996] 4 All ER. 511 . 80 There
is of course no difficulty in terms of the claimants discovering the nature of
the representation. This is said to be clear from the terms of the documents
shown to the names in preparation for their joining. When then could it
reasonably have been discovered to be false? The claimants say that despite
reasonable endeavours the falsity was not apparent until the statement of Mr
Stephen Merrett (together with its exhibits) was examined in 2007. 81
Leaving aside the contention on the part of Lloyd's that it was self-evident
that the representation as allegedly understood was bad in law, Lloyd's
submitted that there was a whole range of documentation furnished to names from
1984 onwards from which it was apparent that Lloyd's understanding of RITC was
not as, on this basis, had been understood. Indeed, Lloyd's goes further and
says that it is quite apparent from material emanating from names in the period
from 1984 onwards that the position as to the true effect of RITC was not only
fully explained but fully understood. 82 The
starting point is bye-law no.7 of 1984 made shortly after the consultation with
Mr Adrian Hamilton QC. This reads as follows:- "reinsurance to close"
means an agreement under which underwriting members ('the reinsured members')
who are members of the syndicate for a year of account ('the closed year')
agree with underwriting members who comprise that or another syndicate for a
later year of account ('the reinsuring members') that the reinsuring members
will indemnify the reinsured members against all known and unknown liabilities
of the reinsured members arising out of insurance business underwritten through
that syndicate and allocated to the closed year, in consideration of:- (i) a premium; and (ii) the assignment of the
reinsuring members of all the rights of the reinsured member arising out of or
in connection with that insurance business (including without limitation the
right to receive all future premiums, recoveries and other monies receivable in
connection with that insurance business). 83 This
bye-law is not materially different from the description of RITC contained in
the brochures, a point which further supports the proposition that the
brochures did not contain any false statement save in the most pedantic sense.
It certainly undermines any suggestion that Lloyd's intended the brochures to
be understood in the sense pleaded when the very same description is proffered
in the wake of the consultation with Mr Hamilton QC. 84 Even
at this stage the nature of RITC and the position of names in the syndicate
writing the business was well established in the authorities. For example in
Daly v. Lime Street Underwiting QB (Comm Ct) 4 June 1987 Staughton J explained
that although the claimant "formally remains a party to contracts made on his
behalf in that year he no longer has any financial interest in them since his
liability is covered by the reinsurance to close". It followed as the judge
pointed out that whilst in point of form he himself might be a party to the
action he had no financial interest in it as he had resigned his membership in
1980. 85 The
next stage was the distribution of the Business Plan. This was in due course to
form the basis of the Reconstruction and Renewal proposal. It was distributed
to all names in April 1993 (including of course all the claimants who were by
then stuck on open years albeit some, like Mr. Harris, had ceased
underwriting). 86 The
Business Plan spells out in para 3.8 the positions as regards the liability of
those in closed years with stark clarity: "The creation of the 'ring
fence' is intended to shield the providers of capital from the impact of old
year liabilities. At the same time Names who underwrote the old years must be
given the greatest possible security against their outstanding liabilities. In
the past the reinsurance to close had proved effective to bring an end to the
involvement of Names on closed years. Legally the Names on closed years
remained in theory liable for the liabilities attaching to those years: in
practice the fact that reinsurance to close was effected with the security of
the same or another Lloyd's syndicate as reinsurer meant that closure was for
all practical purposes final. An essential feature of the 'ring fence' is that
the reinsurance in years 1985 and prior by NewCo will be liabilities of NewCo
alone and cannot be allowed to engage the liability of syndicates in future
years. Proper capitalisation of NewCo on the basis of appropriate and equitable
reserving standards for all the accounts to be reinsured is therefore an
indispensable part of the two-phase restructuring approach in order to achieve
the same practical finality for the 1985 and prior years of account as was
previously achieved by reinsurances to close into Lloyd's syndicates." 87 There
was a tentative suggestion made on behalf of the claimants that the plan was so
detailed and elaborate that they could not be expected to have read it let
alone hoisted in its implications. Against the gloomy prognosis for Lloyd's and
its names which was being expressed at the time, this strikes me as so
improbable as to be safely discounted. It has to be remembered that the
document was sent out to thousands of names together with all managing and
members agents accompanied by the suggestion that recipients should seek
professional advice. 88 By
this stage, various names had formed an "Open Year Panel" to assist Lloyd's.
This was chaired by a Mr. Stockwell whose wife is one of the claimants. The
understanding of Mr. Stockwell and his colleagues about the nature of RITC is
well documented. In the Final Report of the Panel on Open Years published in
March 1993 there is the following passage:- "One major caveat is
necessary in respect of all the options outlined in the later paragraphs of
this section. It is important to recognise that it is not legally possible to
transfer liability under an insurance policy from the original underwriter (in
this case, individual Names) without the consent of the policy's beneficiary.
Hence, when this report describes means to close years or release Names, these
options are, in fact or in practice, the reinsurance of liability, not its
permanent and irrevocable transfer. Should the reinsurer fail, for any reason,
to meet its obligations under a policy, liability legally reverts to the Name." 89
Against this background, the concept of his wife who is one of the claimants
not appreciating some fifteen years ago both the true nature of RITC and
Lloyd's understanding of it, in alleged contrast with the brochure which
induced her to join and remain with Lloyd's, is truly startling. 90 Again
the description of RITC in the brochure (and both in the bye-law and in the
joint opinion signed by Mr Phillips) was entirely consistent with the analysis
in Toomey v. Eagle Star [1994] 1 Lloyd's Rep 516 : "Therefore when the
accounts for a given year are closed it is necessary to make provision for the
outstanding liabilities and credits. This is done by assessing a fair figure to
represent the assessed outstanding net liability. The mechanism by which these
liabilities are transferred is called a "reinsurance to close" and the sum
being paid as a consideration for such transfer is called the "premium to
close". The transfer that takes place covers the whole of the underwriting
account including the benefit of the reinsurances and reinsurance treaties held
by the year to be closed. It is a requirement of Lloyd's that the reinsurance
to close should be into another Lloyd's syndicate and that the management of
the account should remain with a member of Lloyd's. The purpose is to retain
both the solvency requirements and the discipline of the Lloyd's market": per
Hobhouse LJ. 91 In May
1994, Lloyd's distributed to members an explanatory pamphlet entitled "Value at
Lloyd's". It explained the process in which an individual member could transfer
his past (and future) underwriting business (including open years) to a
corporate member. The pamphlet expressly identified some of the concerns that
had been identified in regard to these transitional arrangements. In
particular, the primary concern was expressed in this way: " reinsurance not novation
: the scheme involves the new vehicle reinsuring liabilities under the policies
written by the individual. The liabilities under these policies remain those of
the individual and if the new vehicle is unable to honour the reinsurance the
liability will revert to the individual member." 92 Again
if all or some of the names had truly been misled by the brochure in renewing
their membership the penny would have dropped with someone. That of itself
militates against any finding of causative misrepresentation but, more
importantly for present purposes, is wholly inconsistent with any suggestion
that the true nature of RITC as understood by Lloyd's was not apparent for
another decade. 93
Another group (the Lloyd's Names Association Working Party - LNAWP) of which
Mr. Stockwell was also chairman published a paper on a proposed alternative to
Reconstruction and Renewal in December 1995. It was a necessary precondition to
the workability of the alternative proposal that the subscribers to a syndicate
remained liable to policy holders even after a year was closed. 94 Indeed
the whole concept was based on the perceived difficulty and cost of pursuing
the original names (or their estates):- "It is considered that in
the event of a default by a name that cannot pay, a policyholder is likely to
experience significant difficulties in taking direct action. (This is also true
in the event of the failure of Equitas.) Before the policyholder can initiate
action against a Name, he would have to establish that the claim had not
already been resolved by the run-off agent and that the Name had defaulted.
This should not occur for many years. In the event of seeking to take action
against the Names, policyholders first have to locate the Names. The Names in
question are those on the original policies, the whereabouts of around a third
of whom are unknown to Lloyd's. Of the remainder the majority on old policies
are deceased and their estates are wound up. Policyholders seeking to take
action will have to locate the original Names or the Executors of original
estates and persuade them to make a claim on reinsurance -to-close policies.
Even very substantial claims in fact represent very small sums per Name. By the
time these sums have been reinsured by 500 people or more, generally speaking
the sum is only a couple of dollars per person. By the third year the sum is
pence per person. The costs for pursuing these claims are hundreds of pounds
per person per year; costs of collection are likely to outweigh potential
returns." 95 Thus
it was Lloyd's submission that any name who was under any misapprehension as to
the nature of RITC could not continue to fail to appreciate the potential
on-going exposure. This commentary from LNAWP (which held itself out as the
"lobby and mouthpiece" for the Lloyd's Action Groups with a newsletter
circulated to 23,000 names) made it clear that there was no such
misunderstanding. 96
Lloyd's responded to this idea in its "Papers on Alternatives" sent to names in
January 1996. Although it rejected the LNAWP proposal (now christened "Dead
Man's Shoes"), it made it clear that the underlying premise was indeed correct
namely that the policyholders claims lay against the original syndicate
members: it was simply that they (or their estates) were entitled to the
benefit of the indemnity under the RITC. "The obligations under the RITC
contracts ... are not dependent on the original insurers' ability to pay." 97 The
absence of any misunderstanding was confirmed, it was submitted by Lloyd's,
from the stance taken by legal advisers to the names when acting on their
behalf. In October 1996 the claim in Lloyd's v Leighs [1997] CLC 761 got
underway in which Lloyd's sought and obtained summary judgment in respect of
the claims for Equitas premiums. This litigation was conducted by the United
Names Organisation of which the claimant, Mr. David Harris, was chairman. During
the course of the litigation, Colman J asked for counsel's help in considering
the position of members of Lloyd's who were in run off but did not accept
Reconstruction and Renewal ("R & R"). 98 In his
response, Mr. Romie Tager Q.C. counsel for the Defendant stated that members of
syndicates which had been closed through RITC or through Equitas "will be in
run off as long as there are prospective liabilities to policy holders." 99 When
the claim reached the Court of Appeal ( [1997] CLC 1398 ), the court duly
confirmed that the Equitas scheme did not derogate from the principle that
"each name remains directly liable to policy holders in respect of the business
written by that name and in respect of that business alone." 100 This
recognition of the continuing liability was recognised yet again, so Lloyd's
submit, in the course of the Jaffray litigation when, as already noted, Mr.
Simon Goldblatt Q.C. acting for the names (including all the claimants)
accepted that in the event of a claim on an old policy the claim would in a
formal sense be made against the original names. 101 The
position was yet again confirmed in an important report prepared by Messrs.
Slaughter & May in April 1996 as legal advisors to the Validation Steering
Group. The group was chaired by Sir David Berriman representing the Association
of Lloyd's Members. The other members were Damon de Laszlo representing the
Litigation Names Committee and Alan Porter representing LNAWP. 102 In
the covering letter sent to members and signed by Sir David Berriman and Mr. de
Laszlo, the authors confirmed their agreement with the conclusion that the
names would not be better off if the whole of Lloyd's went into the run-off as
suggested by the Dead Man's Shoes argument. The letter went on to summarise the
main conclusion of the report including this reference to 'finality':- ""True finality" in the
sense of limiting or "capping" liabilities to policyholders cannot be achieved
for Names. The "finality" offered by R & R is not "true" or "absolute" finality,
but is similar to that offered by the traditional RITC in that it depends on
the continuing ability of the reinsurer (in this case, Equitas) to meet its
obligations under the reinsurance contract. R & R will, however, enable
Names to leave Lloyd's. Lloyd's are trying to make the price of that "finality"
more affordable by redistributing to some extent the impact of losses across
the society as a whole and assembling a substantial fund from various sources
to reduce the overall cost to Names." 103 The
report itself reinforced the point that it is not possible to "novate" a
contract without the consent of both parties. "In other words, names cannot be
released from their obligations to policy holders' except with the policy
holders consent." 104 So
far as reinsurance into Equitas was concerned the report stated: "41. In legal terms the
essence of what is proposed is the same as the traditional RITC contract which
for many years has been the mechanism through which Names have been able to
leave Lloyd's when they wish. The traditional RITC contract has been treated by
all concerned, Names, Lloyd's and the DTI, as providing finality even though,
in reality, that depends upon the reinsuring syndicate continuing to comply
with its obligations under the RITC contract, in particular to pay claims: the
Name is allowed to resign from Lloyd's, is no longer required to maintain
reserves to back his underwriting liabilities (even though, in law, he still
has them) and conducts his affairs on the basis that he is not only solvent but
no longer has any of the contingent liabilities incurred while carrying on
insurance business. He may, for example, be able to give his assets away and,
if he dies, his executors may be able to wind up his estate without those liabilities
being taken into account. The same result is intended to be achieved by the
proposed reinsurance into Equitas." 105 In
terms of Dead Man's Shoes, Slaughter & May commented that such a policy
would not only damage the credibility of all policies written at Lloyd's but
failed to allow for the fact that RITC is not simply a reinsurance contract but
also contained an undertaking on the part of the successor syndicate to manage
the business of the closing year. Thus the difficulties of identifying and finding
the original names was not significant. In the light of this report written 12
years ago it is impossible to accept the proposition that the names had not
discovered (or could not by reasonable endeavours discover) that any
understanding as to novation derived from the brochures was a misconception. 106 In
due course, Lloyd's sent two further documents to names - Settlement
Information and Settlement Offer dated June and July 1996 respectively. The
Settlement Information, in referring to the prospect of affordable 'finality'
said this: "The combination of the
settlement offer and the reinsurance into Equitas is designed to provide Names
with affordable 'finality': that is, a final reckoning in respect of 1992 and
prior business. Although it is not within the power of Lloyd's to grant Names
an absolute release from their liabilities to policyholders, Names who wish to
resign from the Society will be able to do so (provided they do not have
outstanding Lloyd's liabilities). Full acceptance of the settlement offer would
also end widespread litigation brought by the Names and allow the Lloyd's
market trade forward with increased confidence." 107 In
the result arrangements were duly made for all names whether in closed or open
years to become parties to the run-off contract with Equitas. As explained in
the Settlement Offer, this in turn allowed a member to cease being a member by
virtue of the reinsurance into Equitas:- "A member may resign from
the Society at any time by giving written notice of resignation. Under
paragraph 40 of the Membership Byelaw (No. 17 of 1993), notice of resignation
ordinarily takes effect (that is, the member ceases to be a member) at the end
of the year following the year in which the member's remaining open years of
account have been closed by reinsurance to close with another Lloyd's syndicate
or Equitas. The DTI has accepted that the reinsurance into Equitas can be
treated as a reinsurance to close and that, having paid their finality bills,
Names with no other outstanding Lloyd's liabilities may resign." 108 In
his judgment in Lloyd's v Leighs - Part 1 - [1997] CLC 759 which was concerned
with the issue of authority to enter into the settlement, Colman J set out the
position with characteristic clarity at p781: "It cannot even be said
that the names have by means of the scheme somehow ceased to be severally
liable to their assureds. On the contrary, they remain severally liable on
every risk written on their behalf, a liability which could theoretically be
enforced if Equitas were ever to go into liquidation before concluding the
run-off.... The reinsurance of the run-off by Equitas has simply been on
market-wide, uniform terms which have involved the names transferring their
assets and paying premium to a reinsurance company in exchange for (i) cover
and (ii) claims handling." 109 Much
was sought to be made by the names as to the implications of the decision in Re
Yorke (decd) [1997] 4 All ER 907 . The application was a test case as to
whether personal representatives needed to obtain the consent of the court
before distributing the estate of names on open years the liabilities of which
had been reinsured into Equitas. It was submitted that the decision drew a
distinction between such cases and the position where the liabilities had been
transferred by way of RITC. It was suggested that in the latter case no such
consent was required as the court recognised that no residual liability could
remain. 110 I
detect no such distinction. It was certainly not a proposition that was argued.
The comparison potentially arises from the fact that unlike earlier years
policyholders would be unable to look to the Central Fund at Lloyd's in the
event of failure of the reinsurance. The decision remains entirely consistent
with the proposition that names on a closed year with RITC protection
nonetheless remain theoretically liable to policyholders. Indeed the Practice
Direction made in the wake of Re Yorke is directed equally to reinsurance into
Equitas and RITC with a Lloyd's syndicate. 111 Was
it apparent throughout that Lloyd's were aware of the falsity (if any) of the
representation in the brochure? The short answer must be yes. They were the
authors of many of the documents cited above. The suggested reluctance to plead
fraud on this basis sits uneasily with the readiness in which it was alleged in
Jaffray . But if there was any doubt, the names only had to ask. Indeed on 15
January 2007, Mr Stockwell wrote to Lord Levene, the then Chairman of Lloyd's,
asking various questions including the following: "1. On what basis does
Lloyd's believe that any liability is vested in the original names on policies
written before 1992 and now reinsured by Equitas? Does it accept that all
liability to original policyholders has been transferred by the RITC chain to
the names on the open years that were eventually closed into Equitas? If not,
in what circumstances could the original subscribing names have a continuing
liability with and without the NIC deal?" 112 Mr
Julian Burling, Counsel to Lloyd's responded to this letter and said as
follows: "1. as you are aware the
names (or the former Names) originally subscribing policies subsequently
reinsured by Equitas Reinsurance Limited remain liable on those policies ... but
are reinsured in respect of those liabilities by their reinsurers to close.
This was made clear in the Settlement Offer Document and other materials
published to names in 1996 ..." 113 Mr.
Stockwell wrote again in July 2007 raising the further question as to when
Lloyd's had concluded that RITC was only reinsurance. Mr. Burling replied on 27
July to the effect that the view had antedated his employment in September 1985
as "reflected in the Lloyd's Syndicate accounting rules made before that date".
I reject the suggestion made by the names that Mr Burling would have given a
different answer if he had been asked the question earlier. This seemed to be
premised on the proposition that he was only prepared to be honest about it
because he was aware that the names now had copies of Mr Merrett's statement
and exhibits. Given the content of the bye-law let alone the later documents
this submission is unarguable. 114 In
short all that the names now rely on was reasonably discoverable more than 6
years before the issue of the proceedings. The claims are thus barred. Breach of
fiduciary duty 115 In
addition to the claim advanced in deceit, the claimant pleaded a case of breach
of fiduciary duty:- "Further, in the context of
its relationship with Mr. Harris as a prospective Name and subsequently as an
existing Name, Lloyd's owed to Mr. Harris a fiduciary duty in circumstances
where it undertook to explain to him during the membership application process
and at the Rota Committee interview the nature and implications of the
unlimited liability that he would have as an underwriting Name. The duty was to
disclose the principal features of unlimited liability, and one of those
features was that unlimited liability was of unlimited duration. If Lloyd's was
aware or became aware from professional advice, whether from its Legal
Department if from Leading Counsel, that Names remained liable or might remain
liable to a policyholder indefinitely, then Lloyd's had a duty to inform Mr
Harris of that advice. It failed to do so at any time and accordingly was in
breach of that duty. For the avoidance of doubt, Mr Harris will contend that
the exclusion from immunity conferred on Lloyd's under the Lloyd's Act 1982
does not extend to breach of fiduciary duty." 116 In
the skeleton argument served on the claimants' behalf the issue of time-bar was
covered in paragraph 51: "Mr. Harris's claim is for
dishonest breach of fiduciary duty and, because fraud is involved, is covered
by s.32(1)(a) of the Limitation Act 1980 and the construction of that subsection
in Barnstaple Boat Co v Jones. Alternatively, if fraud is not made out, the
claim is for breach of fiduciary duty in circumstances where Lloyd's
deliberately concealed from Mr Harris and the Claimants facts relevant to their
right of action. If so, then s. 32(1)(b) applies, and in that event too, the
claim is not time-barred." 117 In
the course of the hearing, it was accepted by the claimants that the
alternative claim was one of "dishonest breach of fiduciary duty". Since it was
accepted that the only relevant distinction from deceit was in respect of the
appropriate remedy (particularly in terms of compound interest), it was agreed
that no further argument on the issue was required. But in post hearing
correspondence, the Claimants invited the court to allow further written
submissions on the issue. In particular, the claimants argued that Lloyd's were
in breach of fiduciary duty (such breach not being dishonest). 118 I
leave aside the question whether a fiduciary duty arose (which I strongly doubt
is even arguable). The immediate difficulty with any such alternative case is
that the Lloyd's Act 1982 section 14 provides that, in the absence of bad
faith,: "14 ...the Society shall not
be liable for damages whether for negligence or other tort, breach of duty or
otherwise ..." In my
judgment, giving this section its natural meaning, the more so having regard to
the "sweeping-up" provision, a claim for breach of fiduciary duty comes within
the words "breach of duty or otherwise": see Ashmore v Lloyd's [1992] 2 Lloyd's
Rep. 622 at p.634. 119
Furthermore, there is still no answer to the limitation plea. The alternative
argument now advanced is an allegation of deliberate concealment within the
scope of section 32 of the Limitation Act 1980 . However no deliberate
concealment of Lloyd's different view of the legal effect of RITC can possibly
be made out in the light of the 1990's documentation. Conclusion 120 For
all these reasons the entire claim must in my judgment be struck out |