Legal Watch - Personal Injury - Issue 37

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Legal Watch: Personal Injury 23rd October 2014 Issue: 037


Mental capacity Since the introduction of the Mental Capacity Act 2005 there has been a presumption in favour of a claimant having mental

In This Issue:

(2014) EWCA Civ 1313 serves to illustrate how hard it is for a

• Mental capacity

capacity. The case of Ali (Protected Party) v Caton and another defendant to assert that a claimant has capacity, once that presumption has been displaced.

When he was seventeen, the claimant/respondent, suffered a

severe brain injury in a road traffic accident caused by the first

• Civil procedure/‘without prejudice’ • Fraud/contempt proceedings • Limitation/product liability

defendant’s negligence. The first defendant was uninsured and the MIB (the appellant) had conducted the defence. Liability

had been admitted, subject to a deduction for contributory negligence. The only issue at trial had therefore been quantum. Various experts had treated the claimant during the seven years between the accident and the trial. They all gave evidence

that he suffered from significant cognitive disabilities. Shortly

before the trial, the claimant had taken the UK Citizenship Test

and passed it. The experts all agreed that it was surprising that he had passed the test and that his having done so appeared to be inconsistent with his apparent level of cognitive disability.

The claimant claimed that he had passed the citizenship test

with “improper assistance”, the nature of which was not identified. However, the judge found that he had passed the test without assistance, having learned answers by rote and

having struck lucky in the questions that came up. He found

that the claimant lacked mental capacity and had no residual earning capacity. Damages were assessed.

The MIB appealed and submitted that if the judge had attributed the correct weight to the citizenship test he would

have found that the claimant had either been malingering or consciously exaggerating and that he did not suffer from significant cognitive deficits. He should have found that the claimant did not lack mental capacity and that the award of damages should be reduced accordingly.

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Rejecting the appeal, the Court of Appeal held that on the

evidence before him, the judge had been entitled to make the finding that the claimant had passed the citizenship test

unaided. The judge had been bound to take into account all the features of the evidence in the context of his finding that the claimant had somehow passed the citizenship test.

He had been acutely aware of the need to factor the test

success into the rest of the evidence. To focus upon the citizenship test almost to the exclusion of anything else

would not have been the correct approach. There could be no doubt that the claimant had suffered a very severe

brain injury. He was not a person who could have kept up a pretence of incapacity, capable of fooling so many people,

for so long. The citizenship test had to be put into context with all of the other evidence. The judge had been entitled to conclude that the claimant lacked capacity, having regard to

the sum total of the evidence, including the expert evidence and evidence from other quarters as to how he presented and functioned in his day-to-day life. he award of damages was upheld.

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Civil procedure/‘without prejudice’ When is marking a communication ‘without prejudice’

to operate, but the operation of the rule could be limited or

privileged? This was the issue in Avonwick Holdings Ltd v

scope and could include the “opening shot”. Whether

ineffective when later claiming that its contents were

extended by agreement. The term “dispute” was of wide

Webinvest Ltd and another [Lawtel 21/10/2014].

there was a dispute had to be determined on an objective

The respondent/claimant company had made a loan of

$100m to the appellant/first defendant, a company controlled

by the second defendant, to enable the first defendant to make a loan to another company. The first defendant’s

obligations were guaranteed by the second defendant. The first defendant defaulted and proposed a rescheduling. The

claimant did not agree to the proposed terms and required the provision of security. The claimant then demanded

repayment from the defendants, who alleged a collateral oral agreement that the first defendant’s obligation to repay was conditional on it being repaid in full by the third party company. That company had also defaulted and the first

defendant had commenced arbitration proceedings against

it which had been settled. Disclosure had been ordered of correspondence leading up to the settlement agreement

between the first defendant and the third party company; it

was accepted that the settlement itself was disclosable. The judge held that the second defendant had waived privilege

basis. The judge was right that there had been no dispute in existence at the time of the correspondence in issue.

Freedom of contract was a basic principle of English law

and the courts recognised the efficacy of clauses such as

non-reliance, confidentiality and entire agreement clauses. However, an agreement that documents could not be used in court proceedings could not be unilaterally imposed. The

argument that there was such an agreement in the instant

case was undermined by the fact that the documents were marked “subject to contract” as well as “without prejudice”. The appellants said that that related only to

the “heads of terms” put forward for the rescheduling. In the circumstances it was clear that the words “without

prejudice” were not intended to create an agreement that

the documents would not be used in proceedings in court, but indicated that the lender’s rights were being reserved in relation to the proposed rescheduling. Therefore the documents were admissible.

in certain documents. The appellants appealed against that

The appeal against the decision of the first judge was

leading up to the unsuccessful rescheduling, which was

defendant had waived privilege. It was doubtful whether the

should be admissible. He found that the correspondence

the effect that an offer to settle had been received and his

because there was at the relevant time no dispute about

privilege was not the second defendant’s to waive. The third

defendant’s liability under the guarantee. The appellants

that it was not relying on the documents as admissions.

decision. A second judge directed that correspondence

allowed only in relation to the finding that the second

marked “Without prejudice and subject to contract”,

words relied on amounted to a waiver. They were only to

was not covered by the “without prejudice” privilege

lawyers had advised that it was a good one. In any event the

the first defendant’s liability under the loan or the second

party had not consented to waiver. The claimant argued

appealed on the without prejudice issue.

The reasonableness of the settlement was in issue and the

The Court of Appeal dismissed the appeal against the decision on the without prejudice issue. There were two

general rule applied. The documents remained privileged even after the settlement.

bases for the operation of the without prejudice rule: public policy and contract. As a matter of public policy it was

necessary for there to be a dispute in existence for the rule 03


Fraud/contempt proceedings The case of Royal & Sun Alliance Plc v Fahad [Lawtel

The High Court judge held that a person was only guilty

a court will allow an application for permission to bring

so. Bringing proceedings had to be in the public interest,

21/10/2014] sets out in some detail the grounds on which

of contempt if a statement was false and he knew it to be

contempt proceedings.

taking into account whether there was a strong case,

The applicant insurance company applied for permission to bring committal proceedings against the respondent for

contempt of court. The respondent applied for relief from sanctions.

The respondent had brought a damages claim after an

alleged road accident. The court found that the accident had been contrived and that the respondent had made false

statements by asserting that the accident had been caused by another driver’s negligence and by stating that he did

not know the other driver, when the evidence was that they were in a relationship. The respondent’s evidence that there had been no collusion was rejected. He failed to give seven

days’ notice in writing of his intention to attend the instant

hearing, or provide a written summary of his submissions as required by CPR 81.14(5). He thus lost his right to be heard. Nevertheless the court allowed him to make submissions.

The day before the hearing the respondent applied for relief from sanctions.

The applicant submitted that there was ample evidence from which permission should be granted and that the

false statements had been proved to be false at trial. It submitted that it was in the public interest to bring contempt proceedings as it was not a case of an exaggerated claim,

but one that had been entirely fabricated, and that the

respondent had also failed to pay costs orders made against him. The respondent submitted that he had faced language

problems at trial, as English was not his first language. With regard to relief from sanctions, he submitted that he had not given seven days notice for good reason as he had been in Iraq and suffering from ill health.

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whether the alleged false statements made were significant in the proceedings, whether the person understood the

likely effect of the statements and considering the deterrent

effect of contempt proceedings. Only limited weight should be attached to the likely penalty and contempt had to

be proved to the criminal standard. The respondent’s arguments went to the merits of the application rather than

whether permission should be granted. There was a strong prima facie case but it was not the job of the instant court

to make findings. It was important to deter false claims.

The public interest not only justified granting permission, but demanded it. There were different types of fraudulent

claims; one where an accident had occurred but it had been

exaggerated and one where there had been no accident at all. That latter category was far more serious. Permission to bring the committal application was granted.

Given that outcome and that the respondent’s submissions had been considered, it made no practical difference if

he was granted relief from sanctions, but it was relevant to costs. The breach had been serious. The respondent’s

medical notes showed that he was no longer unwell. He had

been in the UK shortly before the deadline and in any event

he could have emailed or telephoned from Iraq. The breach had not been an isolated occurrence. Relief from sanctions was refused.


Limitation/product liability In Unwalla v Spire Healthcare Ltd [Lawtel 22/10/2014] the

the terms of S4(2A) of the 1982 Act which provided that

losses arising from alleged breach of contract in relation

that a reasonable person would regard as satisfactory,

claimant claimed damages for personal injury and other to the supply of a hip implant using the Birmingham Hip

Resurfacing System (BHRS). The hip replacement surgery

had been carried out in 2001. The claimant had suffered

an adverse reaction to metal debris (ARMD) and had to have revision surgery in 2007. It was the claimant’s case

that the implant was in breach of the statutory implied

terms of satisfactory quality and fitness for purpose under the Supply of Goods and Services Act 1982 and that the services and/or advice given by the defendant were not

supplied with reasonable skill and care. The defendant

served a defence denying liability, but admitting the

contract for supply of the implant and the implied terms. It denied that it was vicariously liable for the actions of the

consultant and argued that the contract claim was statute-

“goods are of satisfactory quality if they meet the standard taking account of any description of the goods, the price (if relevant) and all the other relevant circumstances”. It was said

that relevant circumstances could include the defendant’s knowledge. Its case was that its defence sufficiently raised the issue as to whether the implant was appropriate for the claimant and that it was inevitable that expert evidence

would be required on that and other issues. The claimant had not produced any incontrovertible evidence on what

were described as the core issues. Permission was given to amend the defence, and on the defence as amended, which put the claimant to proof on the key issues, it could not be

said that there were no reasonable grounds of defence or that the defence had no real prospect of success.

barred under S5 Limitation Act 1980 since proceedings had

not been brought until 2013. The claimant applied to strike

out the defence or for summary judgment on the basis that

the vicarious liability issue was irrelevant, as was S5 which

was disapplied by S11 of the 1980 Act in a personal injury claim. The claimant argued that the defence failed to deal

with the core allegations in the particulars of claim, namely that BHRS was not fit for purpose, in particular because

the claimant had hip dysplasia and that the claimant was not warned that BHRS had an unacceptably high risk of

revision surgery within 10 years. The defendant applied for permission to amend its defence substantially.

The High Court judge held that the original defence was

clearly defective, but the court, before striking it out, had

to consider whether it could be amended. The claimant accepted that there was a triable issue on limitation under S11 and S14 of the 1980 Act, leading to the court being asked to exercise its discretion under S33 to exclude the

limitation period. There were also triable issues of causation

and the assessment of damages. The defendant relied on 05


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