Road Accident claim

Personal Injury case report: Insurer fails in bid to withdraw admission of liability in road accident claim

On 7 June 1996, our client C, who was then nine years old, suffered severe injuries in a road accident. She was standing at the side of the road with two friends and her mother waiting to cross when she was struck by the Defendant's vehicle, which was travelling very close to parked cars and at high speed. The Defendant was later convicted of failing to stop after the accident.

The Defendant's insurers were informed of a claim by C. In November 1997, the insurers were advised by the Claimant's solicitors to make a reserve for the claim of at least £1 million.

After much correspondence, on 4 May 1999, the Defendant's insurers wrote to confirm that they did not intend to dispute liability. As this was now a damages assessment case, we decided to obtain more evidence before issuing proceedings in order to avoid a strict timetable being imposed by the Court under the CPR.

C survived the accident but developed epilepsy and her intellectual progress was a cause for concern. She was eventually sent to a weekly boarding school with a caring and non-competitive environment.

Proceedings were issued on 22nd November 2001 following the Defendant's insurers' refusal to pay any interim payment towards the Claimant's expenses and school fees. In the defence served on 11th January 2002, the Defendant contested liability, alleged contributory negligence by C by running into the road and withdrew the admission in the insurer's letter of 4.5.99. In April 2002, the Defendant served Part 20 proceedings on C's mother, alleging that she was the cause of the accident and claiming a contribution.

We issued an application for the defence to be struck out and for judgment against the Defendant. The hearing took place before Deputy Master Hoffman of the Queen's Bench Division of the High Court on 29 April 2002.

The Master was referred to two Court of Appeal cases, Christopher Malcolm Standerwick v Royal Ordinance PLC Court of Appeal 6 March 1995 (unreported) and Gale v Superdrug Court of Appeal 23 April 1996.

The Defendants contended that they were entitled to change their mind and that the pre-action protocol presumption that the admissions were binding only applied to cases under £15,000. This was a substantial case, possibly worth over £1 million.

The Claimant's counsel argued that a clear and unambiguous admission of liability had been made by an experienced and substantial insurance company after their enquiries were complete with full knowledge of the scale of the claim. The Claimant had relied on the admission and would now be severely prejudiced as all work on liability had ceased in 1999 and the factual witnesses were told at that stage that their evidence would not be needed. A care and schooling plan had been set up on the basis that the Defendants would be paying for it.

Furthermore, as the Defendant was no longer alleging any negligence by C, the Defendant would have to show that he was not even 1% to blame to escape having to pay the whole judgment. There was substantial evidence of negligence against the Defendant including his speeding, swerving and failure to stop. No witness supported the Defendant's account that he had been going slowly, sounded his horn and braked.

In his judgment, Deputy Master Hoffman referred to the two Court of Appeal cases. On the face of it, the Defendants were entitled to change their mind and not giving a reason was only one factor to be taken into account. However, the facts in Gale v Superdrug were different to the facts here. In Gale, the admission was made by insurers and as soon as they instructed solicitors, their solicitors advised that the admission should never have been made because there was evidence of a strong defence. This included the involvement of a van belonging to a third party and contributory negligence by Mrs Gale. The insurer's solicitors acted promptly and sought to avoid any further prejudice by their actions.

In this case, the accident was either caused by the Defendant or the Claimant's mother who had been joined in part 20 proceedings. The Defendants and the insurers had not acted promptly. The insurers had instructed three firms of solicitors over two and a half years and only decided to withdraw the admission of liability following the recent issue of proceedings. They had not acted to avoid prejudice, only withdrawing the allegations of contributory negligence against the child two days before the hearing and promising at the hearing not to seek to recover any interim payment from the child if the Defendant was successful in escaping liability.

The Master found that there was clear and cogent evidence of prejudice to the Claimant in that the factual witnesses had been stood down and that a care and schooling plan had been set up on the basis that the Defendants would pay. That might have to be reversed if the admission was withdrawn.

Accordingly, he ordered that judgment be entered for the Claimant together with costs. He ordered the Defendant to pay an interim payment of damages which will enable the present expenses and school fees to be paid. The insurers indicated after the hearing that they would drop the Part 20 claim against the mother if it was found that she had no insurance to cover her for the claim (as is the case). The case will now proceed as an assessment of damages.

Why is this case important?

An insurer will not be able to withdraw an admission even in a serious case where the Claimant will suffer severe prejudice as a result. If it is possible for insurers to make an admission in open correspondence and withdraw it 2 years later, then sensible negotiations between the parties would be all but impossible. We have to be able to rely on what an insurer or solicitor says when an offer is made in negotiations.

Patrick Allen
Hodge Jones & Allen
May 2002

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