WR Berkley Insurance (Europe) Ltd & Ors

WR Berkley Insurance (Europe) Ltd & Ors

Payment into escrow did not constitute an ascertained loss or an immediately enforceable obligation to indemnify under the insurance policy; only payments out of escrow in accordance with the agreement would represent compensatory damages and insured loss.

Parties
Appellant/defendant: WR Berkley Insurance (Europe) Limited; Appellant/defendant: Aspen Insurance UK Limited; Respondent/claimant: Teal Assurance Company Limited
Jurisdiction
England and Wales
Judgment Date
25 January 2017
Procedural Posture
Civil Appeal / Judgment on Appeal
Outcome
appeal dismissed
Legal Topics
Professional Indemnity Insurance, Reinsurance, Escrow Agreements, Settlement Agreements, Ascertainment of Liability

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Parties

WR Berkley Insurance (Europe) Limited

Appellant/defendant

Aspen Insurance UK Limited

Appellant/defendant

Teal Assurance Company Limited

Respondent/claimant

Procedural Posture

Civil Appeal / Judgment on Appeal

  1. 1 Whether payment into escrow constitutes an ascertained loss for indemnity under professional indemnity insurance
  2. 2 Whether the insured's liability was established and quantified by entry into the Payment Deed and Escrow Agreement and/or payment of the Escrow Amount

Ratio Decidendi

Payment into escrow did not constitute an ascertained loss or an immediately enforceable obligation to indemnify under the insurance policy; only payments out of escrow in accordance with the agreement would represent compensatory damages and insured loss.

Court Disposition

appeal dismissed

Orders

  • Appeal dismissed; Eder J’s decision affirmed.