Legal Watch - Personal Injury - Issue 57

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Legal Watch: Personal Injury 27th March 2015 Issue: 057


Fraud/committal Royal & Sun Alliance Plc v Fahad [Lawtel 23/03/2015] is the latest example of a court punishing a claimant for bringing

In this issue:

of proof that an applicant must satisfy to succeed with an

• Fraud/committal

the value of Part 18 requests for further information.

• Watch this space

a fraudulent personal injury claim. It illustrates the burden

application under CPR 32.14 and CPR 81 and also highlights

• Jurisdiction/Rome II

The respondent/claimant had brought a claim in damages against the applicant arising out of an alleged road traffic

accident. The trial judge had found that the accident was

entirely contrived and that the respondent had known the

other driver who was involved, despite his assertions to the contrary. The applicant was the other driver’s insurer.

The trial judge found the respondent’s evidence inconsistent and untruthful, and the applicant was granted permission to bring committal proceedings on the basis that the respondent

had made false statements. The relevant statements were the allegation in the respondent’s particulars of claim that

Events

response to the applicant’s Part 18 request in which he stated

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the accident had been caused by the driver’s negligence; his

that he did not know the driver prior to the accident; and his

statement in his witness statement that he did not know the driver at the time of the accident and only became Facebook

friends with her after the event. The driver’s flatmate had given

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evidence during the trial that the respondent and the driver

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had been in a long-term relationship.

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The applicant submitted that the respondent (1) had made the

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false statements and verified (or caused them to be verified) with a statement of truth; (2) knew at the time that he made

the statements that they were false; (3) acted with the intention of interfering with the due administration of justice; and (4) if the false statement had been persisted in, it was likely that it

would have interfered with the course of justice. The applicant further submitted that, in relation to (3), if the court found

that the respondent knowingly made false and dishonest


statements of the kind alleged, there was an irresistible

and his argument that he had muddled his tenses in his

the due administration of justice. The respondent submitted

the respondent was well acquainted with the driver at the

inference that he acted with the intention of interfering with that he had communication difficulties due to English not

being his first language and that he had got confused with his tenses when he said that he had not known the driver at the time of the accident.

‘The central issue was the existence or absence of a relationship between the respondent and the driver.’ Allowing the application, the deputy High Court judge

held that the issues to be determined before the instant court were essentially the same as those before the trial judge. The central issue was the existence or absence of a

relationship between the respondent and the driver. It was

for the applicant to prove beyond reasonable doubt that the respondent had made the false statements knowing that they were false. The instant court had been impressed by

the flatmate’s evidence and there was no good reason to disbelieve it. The court accepted it in full.

The court could only deduce the respondent’s account of events from the papers before it, as he had not given

evidence and neither had any of the passengers involved in the alleged accident. His right to silence was not absolute

and could be taken into account. The court approached his

evidence with a great deal of caution. He had stated that he did not know the driver at the time of the accident. After the

applicant served a statement from its solicitors showing that the respondent and the driver were friends on Facebook, he

had made a statement claiming that they had only become friends on Facebook after the accident.

The respondent had been resident in the UK since 2011 and had attended an intensive English language course. His

difficulties with the English language had been overstated 02

statement was not accepted. The court was satisfied that time of the accident and accepted the flatmate’s evidence

that they had been in a long-term and serious romantic relationship for some time. The court also accepted the flatmate’s evidence that the driver had told her that she and

the respondent had nearly been caught out by an insurance company because they were friends on Facebook. There

was a good deal of evidence to show that the respondent had been dishonest. The only credible explanation for the

changes in his evidence was that he had been untruthful. The court accepted that the motivation for the respondent

to conceal his relationship with the driver was to deceive the applicant into believing that an accident had occurred which had not. The accident was not real and had been staged. It

could not reasonably be argued that the respondent had

an honest belief in his statements. He had knowingly and deliberately set out to defraud the applicant in a false claim

for damages. In doing that he had sought to interfere with the administration of justice and was in contempt of court,

Airbus considered. The respondent was sentenced to 12 months’ imprisonment.


Jurisdiction/Rome II The application of the Rome II regulations to a fatal accident

Rejecting the claim, the High Court judge held that under

EWHC 626 (QB).

fact, and if foreign law was to be relied on it had to be

claim was considered in Bianco (deceased) v Bennett (2015) The claimant (the deceased’s widow) and her family were

Italian and lived in Italy. The deceased had been hit by a car driven by the defendant in the UK. He died from his

injuries. The defendant had admitted that he was two-thirds to blame.

The claimant claimed damages under the Fatal Accidents Act 1976 and pursuant to the Law Reform (Miscellaneous Provisions) Act 1934. In her schedule of loss, she made

“subrogated claims” under the 1976 Act relating to sums paid and to be paid to the family by the Italian Workers

Compensation Authority (UNAIL) and by her husband’s

employer. It stated that, under the terms of an insurance policy with UNAIL, the claimant was contractually obliged

to seek a subrogated claim where a third party was at fault. The preliminary issue was whether such claims were recoverable.

English law, the content of foreign law was a question of

pleaded and proved as a fact by expert evidence. In the

absence of satisfactory evidence of foreign law, the court

would apply English law. The schedule of loss made no reference to Article 85. However, the 2004 Regulation, as

a directly enforceable instrument of EU law, was part of

English law and a party did not have to plead matters of domestic law. The position was different in relation to the provisions of Italian law, which was the foundation of the subrogated claims. The defendant was entitled to object to

the claimant’s reliance on the Italian law which had since been identified as founding her case under Article 85. The Italian law case had not been pleaded and there was no

admissible evidence to support it. The subrogated claims as pleaded could not succeed. Regulation 864/2007 (Rome II) applied to claims in respect of accidents and the applicable

law was that of the country in which the damage occurred. The claim was governed by English law and the only

The defendant submitted that there was no head of loss

available basis for a claim in respect of her husband’s death

include the subrogated claims and that payments from

claims were not causes of action possessed by the husband

the assessment of her claim as irrelevant. He argued that

they could not be brought within the terms of the 1976 Act.

and proved by expert evidence. The claimant argued that

provided that all benefits coming to a dependant as a result

Regulation 883/2004.

Article 85(1)(a) was a choice of law provision by which the

under the 1976 Act which was permitted the claimant to

was under the 1976 Act and the 1934 Act. The subrogated

the husband’s insurer and employer were disregarded in

before his death so the 1934 Act was not applicable and

any claim based on Italian law would have to be pleaded

The claimant had the benefit of S4 of the 1976 Act which

the sums claimed were recoverable pursuant to Article 85

of death were to be left out of account.

‘…the applicable law was that of the country in which the damage occurred.’

home law of the institution providing benefits in respect

of an injury would govern whether the institution was subrogated to rights enjoyed by the beneficiary against the

wrongdoer and, if so, the extent of the subrogation. That provision did not require the court of the foreign member

state to apply the law of the institution’s home jurisdiction to the claim against the defendant. There was no authority for

the proposition that the law of the institution’s home country

applied to determine the existence and extent of the rights to which the institution was subrogated.

03


Watch this space The Social Action, Responsibility and Heroism Act 2015 will

come into force on 13 April and will apply to claims that a person was negligent or in breach of statutory duty where the act or omission giving rise to the claim occurs on or after

that date. The Act has been heavily criticised for seemingly adding nothing to the existing law but merely reemphasises that in considering a claim in negligence, the court must

take account of the context in which the alleged negligence occurred.

On the same date S57 Criminal Justice and Courts Act 2015 comes into force. It states that if in a personal injury claim

‘the court finds that the claimant is entitled to damages

in respect of the claim, but….on an application by the defendant for the dismissal of the claim under this section, the court is satisfied on the balance of probabilities that the

claimant has been fundamentally dishonest in relation to the

primary claim or a related claim...the court must dismiss the primary claim, unless it is satisfied that the claimant would suffer substantial injustice if the claim were dismissed.

The duty…. includes the dismissal of any element of the primary claim in respect of which the claimant has not been dishonest.

The court’s order dismissing the claim must record the amount of damages that the court would have awarded

to the claimant in respect of the primary claim but for the dismissal of the claim.’

The effect of this is that if part of a claim is tainted by fraud the court is required to dismiss the whole claim, including

any ‘legitimate’ element, unless the claimant would suffer ‘substantial injustice’. It also modifies substantially the Supreme Court ruling in Summers v Fairclough Homes Ltd (2012). It had been held that the court had power under

the civil procedure rules and under its inherent jurisdiction

to strike out a statement of case at any stage of the proceedings, even when it had already been determined

that the claimant was, in principle, entitled to damages in an 04

ascertained sum. However, that power was to be exercised only where it was just and proportionate to do so, and that

was likely to be only in very exceptional circumstances. The power had not been exercisable in that case.

The new provisions do not apply to proceedings started by the issue of a claim form before 13 April but are otherwise retrospective.


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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, CR0 2NA. Parabis Law LLP is authorised and regulated by the SRA.


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