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Fraud - June 2010

A review of the Court of Appeal case of Hussain v Sarkar

Insurers will have been forgiven for feeling slightly dishevelled given the recent Court of Appeal decisions in the cases of Noble –v- Owens, in which it was said that evidence of fraud had to be either admitted or incontrovertible so as to be allowed on appeal, and Axa –v- Suleman, which followed the widely publicised case of Ul Haq v Shah. These cases are all rather unforgiving of Insurers attempting to, as is their right, defend fraudulent claims in the best way that the law permits. 

Amongst the rubble of these decisions however some relief may be found by Insurers in the recent Court of Appeal decision of Hussain & Anor –v- Sarkar and Anor.

This claim had all the tell tale signs of fraud that Insurers have become so used to. Mr Sarkar had hired a van for the day.  Shortly afterwards the vehicle had been involved in a collision with a car driven by Mr Hussain.

Suspicions on the part of the Defendant Insurer, Brit, although unproveable at this stage were that; the parties knew each other, that there was no reason for either party to be at that specific location where the collision was said to have occurred and that the First Claimants claim for what amounted to £1800 a week for loss of income (a total of more than £90,000 per annum) was fraudulent.

As is often the case, at the stage of pleading the Defence there was not sufficient evidence upon which Brit were able to base a formal aversion of fraud against the parties.  As such the Claimants were put to proof without any firm evidence of wrongdoing.  Shortly prior to trial however, following the exchange of witness evidence, having received responses to Part 18 requests, and carried out searches in respect of the Claimants employer, Brit found themselves in a position where they were able to make an application to amend the Defence.

The Recorder hearing the application from the insurers said there was not sufficient evidence so as to materially affect the case and to interfere with the trial date with the application having been made at such a late stage, and having been heard just 2 days prior to trial.  Wishing to avoid “fishing expeditions” that may “discourage legitimate Claimants” he considered what “hard facts” as opposed to mere “suspicions” were put before the Court.  Accordingly the application was refused and Brit were not permitted to raise at trial any assertion that the collision may have been staged.

The trial proceeded some two days later, and, while the Claimants credibility was put in question Counsel for Brit  was not permitted to suggest that the incident was staged.  The Judge found in favour of the Claimants awarding Mr Hussain £33,204 and his passenger Claimant Mr Shah £3,155.

The grounds for appeal centred on the recorders comments that there were “no hard facts” to support an allegation of serious fraud.  Brit asserted that the application to amend the Defence was timely, on the basis that the evidence they sought to adduce could not have been obtained any earlier than it was.  The witness evidence and Part 18 requests were accounted for within a Court order that was outside the control of Brit, in addition renewed companies searches revealed the company the first Claimant had alleged that he had received payments of £1,800 per month from had in fact filed a dormancy notice and was not in fact trading for the period.

On appeal it was stated that “the fundamental objective of the Civil Procedure Rules…is to do justice” and the Court referred to the comments of LJ Gibson in Cobbold v London Borough of Greenwich to the effect that justice ordinarily requires that issues which either party properly wishes to be raised ought be heard.  Two questions were considered:-

1.On the material put forward (by Brit), was there a substantial risk that it would suffer injustice…if it should not be allowed to make the amendments? and;

2. If so, was it right that Brit should bear that risk because of the lateness of the application?

LJ Toulson recites that the test should be observed conscientiously by practitioners.

In this case the Lord Justice did not consider that the expedition by Brit was simply fishing but that there were “enough rum things for them to entertain a reasonable belief, rather than a mere suspicion, that the accident was staged.”

On the basis the application was made once and as soon as evidence  became available to the Insurer that provided them  with a reasonable belief that the accident was staged the Insurer could not be criticised for making its application to put forward its formal case, in spite of the close proximity of the case to trial . LJ Toulson sets out the position more eloquently.

“The nature of a case built on circumstantial evidence is that there will often be no simple hard fact demonstrative of guilt; but in such cases the fact-finder is asked to consider whether the assembly of facts points to the probability of guilt.  The fishing expedition metaphor much loved by English lawyers, conjures up the picture of a person casting a hook in the chance of catching something.  Used in the present content, it applies making an allegation for which there is insufficient foundation in the hope of being able to strengthen it through cross examination.  I do not regard that as a fair description of the insurer’s position, they submitted that on the material which had emerged, there were enough rum things about the claims to cause them to entertain a reasonable belief rather than mere suspicion that the accident was staged”.

In short providing the Insurer can say that they have acted diligently and pleaded a case in accordance with evidence or information in which they have a reasonable belief, and in a timely fashion, it is hoped that where such concerns are sufficient they ought be permitted to plead them at trial.

Alex Rostron is a solicitor specialising in Fraud at Weightmans’ Manchester office.