legal watch - property - issue 08
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Legal Watch - Property - Issue 08TRANSCRIPT
Legal Watch:Property Risks & CoverageSeptember 2015Issue 008
In this issue:
• Property Risks and Coverage seminar programme 2015/2016
• Future Litigation? “The Cheesegrater”
• Avoidance of public liability policy valid where insurer induced by the insured’s material non-disclosure and misrepresentation
• Intermediate supplier had no duty of care
• The Consumer Rights Act 2015
Contact usIf you would like any further information on the cases or articles featured in this issue, please contact:
Christopher MacQueen
T: 020 7469 6267E: [email protected]
Andrew Wallen
T: 020 7469 6286E: [email protected]
Marise GellertT: 020 7469 6249E: [email protected]
IntroductionAs we took a short break over the summer, this is a slightly larger than usual edition on which I have been assisted by my newly appointed sub-editor Andrew Wallen, to whom I am very grateful. Thanks also go to Andrew for his article on the Brit UW case below.
With the failure of bolts during the construction of the US Embassy building in Vauxhall recently hitting the press, Christopher MacQueen considers the possible consequences and implications of similar post-construction bolt failures at the Leadenhall Building.
We consider the case of Barking & Dagenham London Borough Council v GLS Electrical Supplies Ltd & Ors which looks at duties of care where there is a chain of intermediate suppliers.
We also look briefly at the Consumer Rights Act 2015, which is due to come into force on 1 October 2015. We will look at the Act in more detail next month.
Finally, we have included details of our 2015/2016 Seminar Programme, which we hope you will find interesting and useful.
The seminars are free to attend and will be followed by drinks. Confirmation of the dates and venue for the Leeds seminars will follow shortly.
In the meantime, please do circulate the programme to any of your colleagues who may be interested in attending.
Here are the links you can use to book your place:
• For Leeds seminars email [email protected]
• For London seminars email: [email protected]
• For Manchester seminars email: [email protected]
If there are any topics not currently covered which you would find useful please let me know so that we can add them to our next seminar programme.
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Property Risks and Coverage seminar programme 2015/2016
Date Location SeminarThursday
24 Sept 2015
5.30pm
Manchester
Parabis Law LLP
21st Floor City Tower
Piccadilly Plaza
Manchester M1 4BT
Claims handling:
Obtaining and preserving evidence
Followed by drinksTBC
Oct 2015
5.30pm
Leeds
TBC
Insurance Act 2015:
The practical effect on claims handling
Followed by drinksThursday
15 Oct 2015
5.30pm
London
Parabis Law LLP
Peninsular House
30-36 Monument Street
London EC3R 8NB
Insurance Act 2015:
The practical effect on claims handling
Followed by drinksThursday
12 Nov 2015
5.30pm
London
Parabis Law LLP
Peninsular House
30-36 Monument Street
London EC3R 8NB
Insurance contract terms and conditions:
How to identify different terms in insurance contracts, their legal effect, warranties – pre and post Insurance Act 2015
Followed by drinks
Thursday
19 Nov 2015
5.30pm
Manchester
Parabis Law LLP
21st Floor City Tower
Piccadilly Plaza
Manchester M1 4BT
Fire and flood claims:
Update
Followed by drinks
02
TBC
Jan 2016
5.30pm
Leeds
TBC
Claims handling:
Obtaining and preserving evidence
Followed by drinks
Thursday
4 Feb 2016
5.30pm
London
Parabis Law LLP
Peninsular House
30-36 Monument Street
London EC3R 8NB
Claims handling:
Obtaining and preserving evidence
Differences in property claims north and south of the border:
Key differences between Scottish and English property claims across the major perils of floods, fires and defective products; limitation and costs.
Followed by drinksWednesday
24 Feb 2016
5.30pm
Manchester
Parabis Law LLP
21st Floor City Tower
Piccadilly Plaza
Manchester M1 4BT
Insurance contract terms and conditions:
How to identify different terms in insurance contracts, their legal effect, warranties – pre and post Insurance Act 2015
Followed by drinks
TBC
March 2016
5.30pm
Leeds
TBC
Fire claims:
Ignis suus
S86 Fires Prevention Metropolis Act 1774 – accidental fires?
Rylands v Fletcher
Causation
Tactical considerations
Followed by drinks
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Future Litigation? “The Cheesegrater”The Leadenhall Building, more affectionately known as the ‘Cheesegrater’, stands at 737 feet (48 stories) and is the tallest building in the City of London. Attracting companies from all over the world it is 90% pre-let and contains the most expensive office space in the City of London. However, its construction has not been incident free with two bolts, each around the size of a human arm, having broken in late 2014 and a third caught by protective tethering put in place earlier this year. With a precautionary programme well underway to replace 3,000 similar bolts and an estimated repair bill of £6m this is likely to be one of the legal stories of the 2015/16 calendar.
The circumstances which give rise to the remedial work provide a good demonstration of the difficulties which are inherent in proving causation in construction cases and of the potential financial risks which face manufacturers, product distributors and their insurers.
So what is the cause of the bolt failures? It has been publicised following tests by Laing O’Rourke (the main contractor) and Arup Structural Engineers (part of the design team) that the bolts appear to have failed due to hydrogen embrittlement. But what is hydrogen embrittlement? And is it really so straightforward to detect?
To understand hydrogen embrittlement requires a basic understanding of the microscopic structure of steel. Under a microscope, steel is made up of a latticework of overlapping sections with numerous microscopic cracks running through it. Hydrogen embrittlement occurs when hydrogen migrates into these cracks causing them to widen and eventually fracture the physical structure. Unchecked this process eventually leads to sudden catastrophic failures, which are precisely what makes hydrogen embrittlement so dangerous.
Ironically the danger which hydrogen embrittlement creates is that it makes steel act like any other metal (e.g. aluminium) and by so doing negates the property, its ability to bend before breaking, which has made it the mainstay of the
construction industry. From a safety point of view having a visible sign of deterioration before breakage occurs is a massive advantage as it gives you time to support, fix or, in a worst case scenario, evacuate a building before a catastrophic failure.
The post failure tests for detecting hydrogen embrittlement are not wholly reliable and require a certain amount of ‘interpretation’. Usually these tests involve reviewing the fractured edges under a microscope with the general wisdom being that if the edge is rough, then it is more likely to suggest hydrogen embrittlement and if it is smooth, a mechanical failure. However, the very process used to harden steel makes it more brittle, which means that as the tensile strength of the steel increases it becomes more likely that a mechanical failure will also lead to a rough edge. Therefore, with high tensile steel, which was used to make the supporting bolts, it is often difficult to differentiate between hydrogen embrittlement and a standard mechanical failure.
The interested parties in this case are likely to fall into three broad categories: (i) the design team (who will be responsible for any error in the calculation of weights, forces etc.); (ii) the build team (who will be responsible for installation defects); and (iii) the supply chain (who will be responsible for any latent defects in the materials).
This uncertainty in forensic ‘diagnosis’ will be an appealing argument for those companies in the supply chain and particularly steelwork firm Severfield, the current liability ‘front runner’, as if mechanical failure is the true cause then this opens up the possibility that the bolts failed due to poor installation, specification or design failure (rather than any inherent defect in the bolts) and so may leave the design and build team with questions to answer. Given the repair cost it would be surprising if Severfield did not challenge the suggestion of hydrogen embrittlement, especially when the report giving rise to that suggestion was prepared by two of the contractors from the design and build team.
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Even if the suggestion as to cause in the initial investigation is vindicated, identifying who is at fault is not straightforward. Further questions arise: when was the hydrogen introduced? Was this an impurity in the steel? Was it during the hardening process? Was acid used at any stage for cleaning? Was the steel baked long enough? Was it during the electrochemical binding of the coating? Was a scratch introduced in transit? Did a contractor damage the bolts during installation? Or is it simply that the coating was inappropriate for the ‘toxic smog laden air’ of central London? These questions and many more will no doubt be asked and sought to be answered as the legal and expert teams seek to expose the hidden depths of the figurative iceberg.
Whatever answers are found, it would be tempting to think that the final chapter would be straightforward with member(s) of the insurance industry agreeing to pick up the costs of the fallout in accordance with the insurance which each of the contractors likely have in place.
However, at least one outcome could have a final twist. Product liability insurance does not often cover contractual losses where the only damage is to the products themselves, as demonstrated in the claim of Pilkington v CGU Insurance PLC [2004] EWCA Civ 23. This means that with potential damages at £6m and legal and expert costs expected to be several million on top, there could be severe financial consequences for the loser(s?).
Therefore, in all the uncertainty, the only thing that seems for certain is that the legal repercussions of the broken bolts are going to reverberate around the City for the foreseeable future.
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Avoidance of public liability policy valid where insurer induced by the insured’s material non-disclosure and misrepresentationIn the matter of Brit UW Ltd v F & B Trenchless Solutions Ltd [2015] EWHC 2237 (Comm) the court considered the claimant insurer’s (C) application for a declaration that it had validly avoided a contractor’s combined liability policy into which it had entered with its insured, the defendant (D).
BackgroundC was engaged as a subcontractor to construct a concrete micro-tunnel beneath a railway line and level crossing in Nottinghamshire. Network Rail required, as per guidelines that it had issued, that all estimates for under-track crossings showed no more than 5mm of track settlement (i.e. deformation of the railway). D’s tender proposal estimated there would be no more than 2-4mm of track settlement. This estimation was included in the subcontract along with a requirement to carry out the work with due diligence and in a workmanlike manner.
D’s subcontract also required it to indemnify the contractor for any liability or loss sustained by the main contractor as a result of any breach of the main contract as a result of any act, neglect or default on the part of D. The subcontract works were carried out between 11 June and 9 July 2013.
At a site meeting on 17 July 2013 it was established the settlement of the tracks had increased to 15-18mm. A void also then appeared in the adjacent road. Both the rail and road settlement varied day by day but became worse after this point. On 13 August 2015 a representative of D visited the site and concluded the settlement was not as a result of D’s works but rather as a result of earlier exploratory works carried out by a third party.
At approximately 4.27am on 27 August 2013 a freight train derailed when passing over the level crossing. Whilst all of
the carriages remained upright they were damaged along with the track.
The insurance positionUpon notification of the derailment D sought to notify its insurers, Novae (N). However, N responded by indicating its policy had expired on 14 August 2013, prior to the derailment, such that it was not on cover. It was then established that C were on cover at the time, although they had not come on cover until 19 August 2013 meaning that there was no insurance cover for five days rendering D in breach of its subcontract. More pertinently, however, it was clear that D knew of the existence of both the settlement of the track and void in the road at the time it entered into a contract of insurance with C and that it did not disclose this information.
C’s initial response was that since the derailment occurred within its period of insurance it would likely fall under cover, but that it was to carry out the necessary investigations first to establish whether or not D in fact knew of the void and risk of collapse prior to the policy inception. A meeting between C’s solicitors and D also gave rise to a conflict of evidence as to what was said during that meeting and, specifically, whether a reservation of rights was made on behalf of C.
Following the initial reservation of rights, C wrote to D’s broker on 21 January 2014 purporting to avoid the policy for material non-disclosure. In addition, D had indicated in its proposal to C that it did not carry out work on active lines, which C relied upon as a misrepresentation by D such that it was also entitled to avoid cover.
Accordingly, C sought a declaration from the court that it was entitled to avoid the policy for material non-disclosure
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and/or misrepresentation. D denied C was entitled to do so and counterclaimed for both damages and various declarations that C should indemnify it for numerous claims arising out of the derailment.
Specifically, D sought to rely on the guidance issued by Network Rail that an intervention was only required once the settlement was 25mm or greater, such that it was reasonable not to disclose this fact to C at the time the policy was incepted since the settlement was below this level. Further, D’s case was that it had not seen the proposal sent to C as this had been prepared by its broker.
The issues before the courtThe court summarised the issues to be considered as follows:
1. would the disclosure of the earth settlement and/or road void and/or the fact the railway was active have influenced the prudent underwriter in deciding to offer cover to D and, if so, have influenced the terms of cover?
2. on an objective reading of the risk details provided prior to inception of the policy, did D tell C it did not work under railway lines whilst they were active?
3. did D’s failure to disclose those facts, or the misrepresentation allegedly made by D, induce C’s underwriter to offer cover to D on the terms of the policy?
4. did C affirm the policy with the result that it lost its right to avoid?
The court then set out the law relevant to considering those issues, which it is useful to summarise briefly below:
The law i) Non-disclosure
The Marine Insurance Act 1906 (the Act) (specifically section 18(1)) sets out the principles governing non-disclosure and duties of utmost good faith in insurance contract. The authority of Pan Atlantic Insurance Co Ltd & Anr v Pine Top
Insurance Co Ltd [1995] 1 AC 501 (Pan Atlantic) confirmed that the same principles apply at common law for non-marine insurance cases, that an insurer may avoid the policy for a material non-disclosure.
Information that is material must be disclosed to an insurer prior to the conclusion of a policy, where materiality is determined by whether it ‘would influence the judgement of a prudent insurer in fixing the premium, or determining whether he will take the risk’. It is worth remembering that this does not mean that a fact needs to be determinative in whether the underwriter would write the risk or alter the premium, but merely that it would have had ‘an effect on the mind of the insurer when weighing up the risk’. The reasons for failing to disclose the risk are irrelevant and materiality is judged objectively from the perspective of a prudent insurer.
ii) Misrepresentation
Section 20(1) of the Act sets out the general common law rule that the parties to an insurance contract must avoid making material misrepresentations and that an insurer may avoid as a consequence. Materiality has the same meaning as for non-disclosure. Again, a representation is judged objectively and is true ‘if substantially correct’. Where a representation is ambiguous, it is for the person relying on that representation to establish how he understood it.
iii) Inducement
However, where a material non-disclosure and/or misrepresentation has been made it was held in Pan Atlantic that an insurer is only entitled to avoid where either of those was a substantial cause in the underwriter’s decision to write the policy or on the terms agreed.
iv) Affirmation
It is a well established principle that an insurer may lose its right to avoid as a result of an affirmation or waiver by election. It is for the insured to prove that at the time of affirmation the insurer knew of its entitlement to avoid but that its words or actions amounted to an unequivocal election to keep the policy in force.
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FindingsThe court heard evidence from various witnesses including C’s underwriter and solicitors, as well as from the relevant persons at D. There was also expert underwriting evidence before the court, although the court indicated it was able to make findings without reference to that evidence.
i) Expectations of settlement levels
The court found that there was no justification to D’s initial estimate that there would only be 2-4mm settlement as a result of the tunnelling works. Had that been the case then when D was advised of the ever increasing settlement during July and August 2013, its actions would have been different. The court did not accept D’s position that it was unconcerned by the deviation from the settlement levels because of the Network Rail’s intervention levels.
ii) Material non-disclosure (on settlement and the void)
The court found that if it was truly D’s expectation that settlement levels were between 2-4mm and that by the time the policy was concluded the settlement was well beyond this, then that was something of which a prudent underwriter would want to be aware. A claim for liability and future remedial costs was plain as soon as the expected settlement levels were exceeded. Further, as soon as the void appeared in the road there was a clear claim for liability as a result. Looking objectively, it is not for the insured to determine what is material, otherwise it becomes ‘judge and jury on the risk that the underwriter is contemplating’. Accordingly, there was material non-disclosure on the part of D.
iii) Material misrepresentation and non-disclosure (work on active railway lines)
There is no doubt that the proposal misrepresented the fact that D undertook work on active railway lines. It did not matter that the proposal was completed by the broker, since the broker was clearly acting as D’s agent. Both the lay and expert evidence was that had it been disclosed a prudent underwriter would likely have considered that such works would attract a higher excess or premium. Accordingly this was also a material fact that should have been notified to C.
iv) Inducement
Even though the non-disclosure was found to be material, as noted above the insurer must show it would not have written the risk on the same terms or at all in order to be entitled to avoid cover. The evidence before the court was that had the settlement and/or void been notified to C then its underwriter would have excluded the site from the policy. The non-disclosure did therefore induce C into writing the policy on the terms it did.
Likewise, in respect of the work on active railway lines, the consistent evidence before the court was that had C been notified of the fact there was work being undertaken on active railway lines then there would have likely been a higher premium due to the increased risk. Whether by reference to misrepresentation or non-disclosure, this was again a material fact.
The non-disclosure did therefore induce C into writing the policy on the terms it did. v) Affirmation of the policy
D relied on the sequence of events from the meeting with C’s nominated solicitors on 3 October 2013. The court held it was unlikely that the phrase ‘reservation of rights’ was expressly used in that meeting, since it did not appear in the solicitors’ manuscript or typed notes of the meeting. However, the notes did indicate that D had been told that C might not provide cover. Against this backdrop and other evidence before the court, it was satisfied that C had not affirmed the policy at any stage prior to formally reserving rights, by letter, on 3 December 2013.
CommentThis is likely to be one of the last cases to be governed by the Marine Insurance Act 1906, since contracts of insurance entered into after 16 August 2016 will be subject to the less stringent provisions of the Insurance Act 2015.
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Would the result have been any different here? That question would fill an article all of its own and we shall no doubt see similar cases in the next few years. Yet in summary, it is unlikely that the result would have been any different. C’s evidence was unequivocally that it would have excluded the site from the policy had it been made aware of the settlement and/or void. There would be no other appropriate remedy as set out in the 2015 Act other than allowing the insurer to avoid cover.
For solicitors, this case demonstrates the importance of taking good notes during a meeting, retaining these afterwards as well as typing them up. In such matters where solicitors are called to give evidence, contemporaneous documents are likely to be the most persuasive evidence that can be put before a court.
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Intermediate supplier had no duty of careThe recent TCC case of Barking & Dagenham London Borough Council v (1) GLS Educational Supplies Ltd (2) Stearn Electrical Co Ltd (3) RKW Ltd [2015] EWHC 2050 (TCC) demonstrates how important it is to ensure that contribution claims are properly and fully pleaded. This was not a consumer case and so the provisions of the Consumer Protection Act 1987 did not apply.
BackgroundThis was a contribution claim arising out of a fire in a defective Micromark oil-filled radiator, ordered by the claimant local authority (B) to be used in a school. The radiator was ordered from GLS Educational Supplies Ltd (G) who was told that it was to be used in a school. G had, in turn, ordered the radiator from Stearn Electrical Co Ltd (S), who purchased it from RKW Ltd (R).
R did not manufacture or import the radiator and purchased it from others, merely being one link in a chain of contractual transactions starting with the foreign manufacturer and ending with B. There was no evidence or reason to believe that R, S or G would or should have carried out an intermediate inspection of the radiator.
The radiator caught fire within 10 minutes of first being used. It appeared from the information before the court that the nature of the defect that was being alleged in the radiator was identified at an early stage and was known to all.
B commenced proceedings against G in contract, alleging that the radiator was defective, also relying on a contractual indemnity. G admitted the contract with B but denied the radiator caused the fire. G, in turn, brought an Additional Claim (as Part 20 claims are now known) against S, on a contingent basis, in contract and under the Civil Liability (Contribution) Act 1978 (the Act) – in other words, if B succeeded in its claim against G, then G sought damages from S for breach of contract amounting to an indemnity and/or an indemnity/contribution under section 1 of the Act.
S, in turn, defended the claim and brought a claim against R. S accepted the existence of a contract between it and G but denied that the terms were congruent with those in the contract between G and B and denied liability both in contract and under the Act. G responded to S’s defence by averring that S, as a provider of goods and having knowledge of the use of those goods, owed a duty of care to B, as the end user of those goods.
There were procedural issues with the Additional Claim against R. R was actually called RK Wholesale Ltd and it appears that from an early stage S and its solicitors knew this but R was sued as RKW Ltd in the claim form and in the statement of case. The address for service was stated to be RKW Ltd care of R’s solicitors but they had agreed to accept service of proceedings for ‘RK Wholesale Limited’ and had not waived the requirement in the CPR that the defendant’s last known address should be included in the claim form.
The application(s)R applied to strike out S’s claim against it in contract on the basis that it was statute- barred and on the basis that it disclosed no reasonable cause of action under the Act. R also sought summary judgment against S.
S responded by applying to substitute RK Wholesale for RKW Limited and to amend the claim form to include R’s place of business.
S also applied to strike out G’s claim against it on the basis that it disclosed no reasonable cause of action.
S’s witness evidence acknowledged that the claim in contract against R was statute-barred. It also acknowledged the defects in failing to correctly name R and failing to supply its address.
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JudgmentS’s claim against R
The judge took the view that S’s pleading was fundamentally defective. To succeed in its contribution claim against R, S had to prove that R was or would at some stage be liable to G for the same damage. It was common ground that R did not enter into a contract with G, so S had to prove the existence of a duty of care owed by R to G, breach of which could entitle G to recover the same damage from R as it may recover from S. However, G’s damage was the purely financial loss that it may incur to B (the claimant) and S realistically conceded at the hearing that it could not pursue a claim against R on the basis of such a duty. There was no special relationship or relationship akin to contract in existence between R and G. R was merely one intermediate supplier in a chain of contracts relating to a product in respect of which R assumed no responsibility other than any responsibilities arising out of its contract with S. That claim in contract was statute-barred.
The claim against R under the Act therefore disclosed no reasonable cause of action and no reasonable grounds for bringing the claim and had no prospect of success. On that basis, it was to be struck out and judgment entered summarily for R. The defects in this claim were not simply defects that could be remedied by changing the name on the pleading against R or inserting their address and S’s application to do so was also dismissed.
S’s application to strike out the claim against it by G
The court levelled the same criticisms against G’s pleading of its claim under the Act against S. There was no sound basis for the existence of a duty of care owed by S to B (the claimant). Again, there was no relationship in contract between S and B and the amended Additional Claim did not assert the existence of a duty of care in tort or that such a duty was breached and did no more than refer to breaches of the contract between G and S. Those breaches did not, of themselves, either demonstrate or evidence negligence on the part of S.
The court held that an intermediate supplier did not owe a duty in respect of internal defects unless it could be shown that he should have inspected and detected them. Likewise,
the mere fact that an intermediate supplier of radiators knew they were going to be used for heating did not of itself give rise to a duty to inspect and that was not affected by the type of use of the building to which the radiator was ultimately delivered, in other words, the fact that they knew it was going to be used in a school made no difference.
Once again, S was no more than an intermediate link in the chain of suppliers. There was no allegation anywhere that it was negligent to supply that type of radiator and the only complaint related to that particular radiator being defective, which carried no implication of fault on the part of an intermediate supplier.
On that basis, G’s claim against S was also struck out.
“an intermediate supplier did not owe a duty in respect of internal defects unless it could be shown that he should have inspected and detected them.” Comment As can be seen from this case, care must be taken when considering a contribution claim to ensure that the target defendant would be liable for the same damage as the party seeking the contribution under the Act. Here, it was pure financial loss and that was not recoverable in the absence of a contractual or special relationship.
The judge commented on the need for competence and care in determining the names of potential corporate parties and the inadequacy of relying on current websites. There is clearly no substitute for full enquiries being made to ensure that the proceedings are issued against the correctly named parties.
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The Consumer Rights Act 2015The Act is a major part of the government’s reform of UK consumer law, streamlining and consolidating complicated law from numerous pieces of national and EU legislation, which has developed over many years. The Act even goes so far as to contain amendments to the weights and measures legislation in relation to unwrapped bread!
There are numerous innovations and the Act includes measures to specifically reduce the burden of understanding and applying consumer law.
When it comes into force on 1 October 2015 the Act will introduce a range of new rights for consumers, including a 30-day time period to return faulty goods and, for the first time, replacement rights for faulty digital content. Currently the law in that regard is unclear and has failed to keep up with the huge demand for digital products.
The definition of ‘consumer’ has been widened by the Act (section 2) so that it now means ‘an individual acting for purposes that are wholly or mainly outside that individual’s trade, business, craft or profession’. A trader who claims that someone is not a consumer (in other words, was not so acting) has the burden of proof.
Under the Act, consumers and businesses will have clearer rights and responsibilities. These include:
1. new rights for consumers to get a repair or a replacement of faulty digital content such as online film, games, music downloads and e-books
2. consumers having a clear right to demand that substandard services are redone or failing that receive a price reduction
3. a 30-day time period to return faulty goods and get a full refund. The law is currently unclear on how long this period should last and the Act therefore provides certainty
4. consumers being entitled to some money back after one failed repair of faulty goods (or one faulty replacement) even if more than 30 days have passed, rather than
having to put up with repeated attempts to get a repair done
5. consumers being able to challenge terms and conditions which are not fair or are hidden in the small print
The Act also provides guidance in relation to unfair contract terms. An indicative and non-exhaustive list of terms in consumer contracts that may be regarded as unfair is provided in Part 1 of Schedule 2.
The Act and its practical implications will be considered in more detail next month.
www.plexuslaw.co.ukwww.greenwoods-solicitors.com
The information and opinions contained in this document are not intended to be a comprehensive study, nor to provide legal advice, and should not be relied on or treated as a substitute for specific advice concerning individual situations. This document speaks as of its date and does not reflect any changes in law or practice after that date. Plexus Law and Greenwoods Solicitors are trading names of Parabis Law LLP, a Limited Liability Partnership incorporated in England & Wales. Reg No: OC315763. Registered office: 12 Dingwall Road, Croydon, Surrey CR0 2NA. Parabis Law LLP is authorised and regulated by the SRA.
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Contact usFor information on articles and cases featured in other editions of Property Risks and Coverage Newsletters, please contact:
Marise GellertPartnerT: 020 7469 6249E: [email protected]