SOCIETY OF LLOYD'S v (1) PETER EVERETT WHITE (2) STUART JEFFREY BEAL (3) ROBERT ALLEN BRADSHAW (4) LEWIS VARLEY LUXTON (5) ROBERT GEORGE MARICH (6) NEVIL BASIL PRATT (7) FRANCIS SUSAN PRATT (8) ROSS CLEMENT RADFORD (2000)
QBD Commercial Court
(Cresswell J) 3/3/2000
INSURANCE - CONTRACT -
INTERNATIONAL - CONFLICT OF LAWS - CIVIL PROCEDURE - ARBITRATION
LLOYD'S NAMES LITIGATION
: ANTI-SUIT INJUNCTION : EXCLUSIVE JURISDICTION CLAUSES : ARBITRATION
AGREEMENTS : BREACHES : ENGLISH COURTS : AUSTRALIAN COURTS : FOREIGN COURTS :
REFERRING DISPUTES : FOREIGN LEGISLATION : PERSONAL JURISDICTION : LLOYD'S
LITIGATION : CANADIAN SECURITIES LEGISLATION : PRIVATE INTERNATIONAL LAW
An English court
could restrain a party to a contract over whom it had personal jurisdiction
from the institution or continuance of proceedings in a foreign court in breach
of an exclusive jurisdiction clause, even though the foreign claim was based on
breaches of securities legislation which were only justiciable in the overseas
jurisdiction.
The claimant ('Lloyd's')
sought an interim anti-suit injunction against the defendants to prevent them
from pursuing claims against Lloyd's in foreign courts until judgment was given
in the continuing proceedings in Society of Lloyd's v Sir William Otho Jaffray
(1999) LTL 18/6/99, which was dealing with the allegations of fraud against
Lloyd's. The eight defendants were all counter claimants in the Jaffray
proceedings (supra) but had also started proceedings (or joined Lloyd's as
third party to existing proceedings) in Australia. Each of the defendants had
signed a General Undertaking in 1986 or 1987 containing an exclusive
jurisdiction clause in favour of the English courts. The Australian court had
dismissed Lloyd's applications that the third party proceedings be stayed or
dismissed. Amongst other arguments the defendants argued that issues relating
to the Australian securities legislation were only justiciable in Australia and
therefore this was a good reason not to grant the anti-suit injunction (British
Airways Board v Laker Airways Ltd & Ors(1985) 1 AC 58.)
HELD: (1) The following
potentially relevant decisions of the English courts were not drawn to the
attention of the Australian courts: Ashmore & Ors v Corporation of Lloyd's
(No.2) (1992) 2 Lloyd's Rep 620; Lloyd's v Canadian Imperial Bank of Commerce
& Ors (1993) 2 Lloyd's Rep 579; Henderson & Ors v Merrett Syndicates
Ltd & Ors (1994) 3 All ER 506; Society of Lloyd's v Clementson (1994) TLR
16/11/94; Society of Lloyd's v Leighs & Ors (1997) CLC 1398; Society of
Lloyd's v Daly (1998) LTL 1/9/98; Society of Lloyd's v Fraser & Ors (1998)
CLC 1630. (2) Further the defendants, in their lawyers' submissions to this
court, misstated the effect of the decisions in Daly and Fraser (supra). (3) In
Fraser, the CA held that following established principles of English private
international law, any invalidity or lack of enforceability of a contract under
a foreign law was irrelevant. Furthermore, no question of enforcing any act
which would involve infringement of the law of Ontario was involved.
Accordingly, the contracts had to be enforced in accordance with English law
and the arguments advanced on the Canadian securities legislation did not provide
any basis for giving leave to defend and did not provide any basis for giving
leave to appeal. This was followed in Daly (supra). (4) Various confidentiality
orders made by the court in concurrent proceedings, involving both parties,
before the English court should have been drawn to the attention of the judges
in Australia. (5) The defendants had not established a good reason for not
granting an injunction in the terms sought to restrain a breach of the
exclusive jurisdiction clause. It was vexatious and oppressive to pursue the
Australian proceedings whilst the Jaffray trial was proceeding, given the
nature, extent and complexities of that trial.
Injunction granted, with
liberty to apply to vary or set aside.
Michael Brindle QC and
Stephen Houseman instructed by Freshfields for Lloyd's. The defendants did not
appear and were not represented.
LTL 14/4/2000 : TLR
14/4/2000
Judgment Approved - 27
pages
Document No.
AC8001471