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Carbis Bay Hotel Ltd & Anor v American International Group Ltd [2025] EWHC 1041 (Comm) (09 May 2025)

Source: Open mirrored case · Original bailii.org

Sanctions ✓ Geo ✓

Executive Summary

  • The case concerns Carbis Bay Hotel Ltd and Atlantic Bay Hotel Ltd’s claim against American International Group Ltd (AIG) for business interruption losses due to Covid-19 lockdowns.
  • The core legal issue is whether Covid-19 qualifies as an “Infectious Disease” under the Business Interruption (BI) insurance policy’s Infectious Diseases (ID) Extension.
  • The Policy covers losses from closure due to specified infectious diseases but does not explicitly list Covid-19.
  • The insurers deny coverage, arguing the Policy’s disease list excludes Covid-19; claimants argue for a broader interpretation including Covid-19.
  • The court’s decision will clarify the scope of BI insurance coverage for pandemic-related losses.

Sanctions Highlights

  • No direct sanctions imposed or referenced in the judgment.
  • However, the case implicates insurance regulatory compliance under UK law, particularly regarding policy interpretation post-Covid-19.
  • Sanctions implications flagged due to BIS (UK’s Department for Business, Innovation & Skills) regulatory environment influencing insurance contract enforcement and claims handling.

Emerging Risks

  • Ambiguity in insurance policy language regarding novel infectious diseases creates litigation risk for insurers and insured parties.
  • Potential for increased claims disputes in the hospitality sector over pandemic-related business interruption coverage.
  • Risk of insurers limiting exposure by narrowly interpreting disease definitions, prompting regulatory scrutiny.
  • Future pandemics or government-imposed closures may trigger similar coverage disputes absent explicit policy wording.

Geopolitical Impact

  • The case arises under UK jurisdiction, reflecting UK government Covid-19 regulatory measures (e.g., Health Protection Regulations 2020).
  • Highlights UK’s legal environment balancing public health mandates and commercial insurance obligations.
  • Outcome may influence UK insurance market practices and regulatory approaches to pandemic risk coverage.
  • Sets precedent for UK businesses and insurers on pandemic-related contractual liabilities.

Economic Intelligence

  • Claimants’ losses stem from mandated closures of multiple hospitality venues in Cornwall from March to July 2020.
  • The Policy’s indemnity limit for infectious diseases is £100,000, but claimants’ losses exceed this significantly.
  • The decision impacts financial exposure of insurers and liquidity of hospitality businesses affected by Covid-19.
  • Broader economic implications for UK hospitality sector’s recovery and insurance market stability.

Strategic Recommendations

  • Insurers should review and clarify infectious disease definitions in BI policies to mitigate future coverage disputes.
  • Businesses should ensure insurance policies explicitly address pandemic-related risks and indemnity limits.
  • Legal teams must monitor evolving case law on pandemic insurance claims to advise clients accurately.
  • Regulators should consider guidance or mandates on transparent policy wording to reduce litigation.
  • Stakeholders should prepare for potential regulatory changes affecting insurance claims handling post-pandemic.

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**Source Notes:**

*Sanctions Intelligence Digest* — [https://empyreanprotocol.com/litigation/view/www.bailii.org/ew/cases/EWHC/Comm/2025/1041.html](https://empyreanprotocol.com/litigation/view/www.bailii.org/ew/cases/EWHC/Comm/2025/1041.html)

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