AIG Europe Limited v Woodman and others

AIG Europe Limited v Woodman and others

Claims by investors in each development arise from acts or omissions in a series of related transactions, permitting aggregation within each group, but claims from separate developments cannot be aggregated as they lack sufficient connection.

Parties
Appellant: AIG Europe Limited; Respondents: Woodman and others; Intervener: The Solicitors Regulation Authority
Jurisdiction
England and Wales
Judgment Date
22 March 2017
Procedural Posture
Appeal / Judgment on Appeal From Court of Appeal
Outcome
Appeal allowed
Legal Topics
Aggregation Clauses, Professional Indemnity Insurance, Solicitors' Liability, Interpretation of Insurance Contracts
Insurance Law Professional Negligence Aggregation Clauses Professional Indemnity Insurance Solicitors' Liability Interpretation of Insurance Contracts

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Parties

AIG Europe Limited

Appellant

Woodman and others

Respondents

The Solicitors Regulation Authority

Intervener

Procedural Posture

Appeal / Judgment on Appeal From Court of Appeal

Legal Issues

  1. 1 What is the correct interpretation of 'a series of related matters or transactions' in clause 2.5(a)(iv) of the Minimum Terms and Conditions for solicitors' professional indemnity insurance?
  2. 2 Can claims by investors in separate development projects be aggregated under the insurance policy?

Ratio Decidendi

Claims by investors in each development arise from acts or omissions in a series of related transactions, permitting aggregation within each group, but claims from separate developments cannot be aggregated as they lack sufficient connection.

Court Disposition

Appeal allowed

Orders

  • Case remitted to Commercial Court or transferred to Chancery Division for determination in accordance with Supreme Court judgment
  • Parties to submit written submissions on practical disposal and costs within 28 days