London International Exhibition Centre Plc v Allianz Insurance Plc & Ors

London International Exhibition Centre Plc v Allianz Insurance Plc & Ors

The causation requirement for 'at the premises' disease/hybrid clauses is satisfied if government action was taken in response to cases of COVID-19 which included at least one at the premises, regardless of whether the authority knew of the specific occurrence. The insured peril does not require knowledge or reporting of the occurrence at the premises. Cover does not extend to pre-notifiability occurrences. 'Medical Officer of Health' and 'Public Authority' are not limited to local authorities. In the Mayfair policy, 'suffered' means 'occurred or sustained', not 'manifested'.

Parties
Respondent/claimant: London International Exhibition Centre PLC; Appellant/defendant: Allianz Insurance PLC; Appellant/defendant: Aviva Insurance Limited; Appellant/defendant: Zurich Insurance Company Ltd; Appellant/defendant: Chubb European Group SE; Respondent/claimant: Hairlab Limited; Respondent/claimant: Muscleworks Limited; Respondent/claimant: Bodylines Fitness Limited; Appellant/defendant: Ageas Insurance Limited; Respondent/claimant: Mayfair Banqueting Limited; Appellant/defendant: AXA Insurance UK PLC; Respondent/claimant: Kaizen Cuisine Ltd (t/a Kaizen Cuisine); Respondent/claimant: My Time Fine Fair Ltd (t/a My Time); Respondent/claimant: Umberto’s Restaurant Ltd (t/a Umbertos); Appellant/defendant: HDI Global SE-UK Branch; Respondent/claimant: Why Not Bar and Lounge Limited; Appellant/defendant: West Bay Insurance PLC (formerly Zenith Insurance PLC); Appellant/defendant: QIC Europe Limited
Jurisdiction
England and Wales
Judgment Date
03 June 2025
Procedural Posture
Civil Appeal / Court of Appeal Judgment on Appeals From High Court Preliminary Issues
Outcome
All appeals and cross-appeals dismissed.
Legal Topics
Business Interruption Insurance, Causation, Policy Interpretation, COVID 19 Pandemic, Notifiable Diseases, Public Authority Powers
Insurance Law Contract Law Civil Procedure Business Interruption Insurance Causation Policy Interpretation COVID 19 Pandemic Notifiable Diseases +1 more

Case Brief

Summary, issues, holding and outcome

More case intelligence is available

Unlock the full research layer for this judgment.

Full judgment text Downloadable case file Legal principles 6 Authorities cited 13 Party arguments 2 Amounts and remedies 3
Sign in to unlock

Parties

London International Exhibition Centre PLC

Respondent/claimant

Allianz Insurance PLC

Appellant/defendant

Aviva Insurance Limited

Appellant/defendant

Zurich Insurance Company Ltd

Appellant/defendant

Chubb European Group SE

Appellant/defendant

Hairlab Limited

Respondent/claimant

Muscleworks Limited

Respondent/claimant

Bodylines Fitness Limited

Respondent/claimant

Ageas Insurance Limited

Appellant/defendant

Mayfair Banqueting Limited

Respondent/claimant

AXA Insurance UK PLC

Appellant/defendant

Kaizen Cuisine Ltd (t/a Kaizen Cuisine)

Respondent/claimant

My Time Fine Fair Ltd (t/a My Time)

Respondent/claimant

Umberto’s Restaurant Ltd (t/a Umbertos)

Respondent/claimant

HDI Global SE-UK Branch

Appellant/defendant

Why Not Bar and Lounge Limited

Respondent/claimant

West Bay Insurance PLC (formerly Zenith Insurance PLC)

Appellant/defendant

QIC Europe Limited

Appellant/defendant

Procedural Posture

Civil Appeal / Court of Appeal Judgment on Appeals From High Court Preliminary Issues

Legal Issues

  1. 1 What is the causation requirement for 'at the premises' disease/hybrid insurance clauses in business interruption policies?
  2. 2 Does the insured peril require knowledge or reporting of disease at the premises to the relevant authority?
  3. 3 Does cover extend to occurrences of disease before it became notifiable?

Ratio Decidendi

The causation requirement for 'at the premises' disease/hybrid clauses is satisfied if government action was taken in response to cases of COVID-19 which included at least one at the premises, regardless of whether the authority knew of the specific occurrence. The insured peril does not require knowledge or reporting of the occurrence at the premises. Cover does not extend to pre-notifiability occurrences. 'Medical Officer of Health' and 'Public Authority' are not limited to local authorities. In the Mayfair policy, 'suffered' means 'occurred or sustained', not 'manifested'.

Court Disposition

All appeals and cross-appeals dismissed.