Spire Healthcare Ltd v Royal & Sun Alliance Insurance Ltd [2022] EWCA Civ 17 (11 January 2022)

Spire Healthcare Ltd v Royal & Sun Alliance Insurance Ltd [2022] EWCA Civ 17 (11 January 2022)

All claims against Spire arose from the same unifying factor—Mr Paterson's dishonest and negligent conduct in operating on patients without informed consent—so the aggregation clause applies and the £10 million policy limit is triggered for all claims collectively.

Citation
[2022] EWCA Civ 17
Parties
Claimant/respondent: Spire Healthcare Limited; Defendant/appellant: Royal & Sun Alliance Insurance Limited
Jurisdiction
England and Wales
Judgment Date
11 January 2022
Procedural Posture
Civil Appeal / Court of Appeal Judgment on Appeal From High Court
Outcome
Appeal allowed
Legal Topics
Aggregation Clauses, Policy Interpretation, Medical Negligence Liability, Indemnity Limits

Case Brief

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Parties

Spire Healthcare Limited

Claimant/respondent

Royal & Sun Alliance Insurance Limited

Defendant/appellant

Procedural Posture

Civil Appeal / Court of Appeal Judgment on Appeal From High Court

  1. 1 Whether all claims arising from Mr Paterson's conduct aggregate under the insurance policy's aggregation clause
  2. 2 Whether the policy limit is £10 million or £20 million for Spire's liability

Ratio Decidendi

All claims against Spire arose from the same unifying factor—Mr Paterson's dishonest and negligent conduct in operating on patients without informed consent—so the aggregation clause applies and the £10 million policy limit is triggered for all claims collectively.

Court Disposition

Appeal allowed

Orders

  • The £10 million policy limit applies to all claims arising from Mr Paterson's conduct under the aggregation clause.