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The Members of the Probitas Syndicate 1942 at Lloyd's for the 2022 Underwriting Year of Account v Pro 2 Care Ltd [2025] EWHC 1921 (Comm) (25 July 2025)

Source: Open mirrored case · Original bailii.org

Sanctions ✓ Geo ✓

Executive Summary

  • The High Court granted summary judgment to Probitas Syndicate 1942, ruling Pro 2 Care Ltd has no entitlement to business interruption cover under their insurance policy for water pipe damage at a property intended as a children’s care home.
  • Probitas argued the policy did not include business interruption cover, and no business was operational at the property to justify a claim.
  • Pro 2 Care claimed delayed opening constituted business interruption and alleged Probitas waived defenses by reconsidering the claim.
  • The court rejected Pro 2 Care’s claim for indemnity but refused summary judgment on Pro 2 Care’s counterclaim alleging unreasonable delay by Probitas in paying property damage sums under section 13A of the Insurance Act 2015.
  • The case clarifies insurance coverage boundaries and insurer obligations under UK law.

Sanctions Highlights

  • No direct sanctions imposed or referenced.
  • Sanctions implications flagged due to BIS (UK’s Department for Business, Innovation & Skills) relevance in insurance regulatory oversight.
  • Potential indirect impact on underwriting practices subject to regulatory compliance and sanctions risk management in UK and US markets.

Emerging Risks

  • Risk of misinterpretation or mis-selling of business interruption cover in property insurance, especially for new or planned businesses.
  • Insurers may face increased scrutiny on policy clarity and disclosure obligations.
  • Potential litigation risk from insured parties alleging waiver or implied coverage due to insurer conduct.
  • Delays in claims payments may trigger statutory breach claims under Insurance Act 2015, increasing insurer liability exposure.

Geopolitical Impact

  • Case reinforces UK’s regulatory and judicial framework governing insurance contracts, influencing cross-border underwriting standards.
  • US insurers and reinsurers operating in UK markets may face heightened compliance demands regarding policy wording and claims handling.
  • UK’s legal precedent may affect international insurance dispute resolution and contract interpretation, impacting transatlantic insurance relations.

Economic Intelligence

  • Probitas Syndicate 1942, a Lloyd’s underwriter, maintains strict underwriting discipline, potentially limiting exposure to ambiguous business interruption claims.
  • The ruling may reduce insurer payout liabilities in similar cases, preserving capital for Lloyd’s syndicates.
  • Insured businesses, especially startups, may face challenges securing comprehensive interruption cover without explicit, detailed underwriting disclosures.
  • Potential increase in insurance premiums or demand for specialized delay-in-start-up cover products.

Strategic Recommendations

  • Insurers should ensure explicit, documented client communication regarding business interruption coverage scope and exclusions.
  • Brokers must rigorously verify insured’s business operations and revenue details before quoting or renewing policies.
  • Legal teams should monitor claims handling timelines to mitigate breach of Insurance Act 2015 risks.
  • Insured entities should maintain clear business plans and evidence of operational status to support future claims.
  • Regulators and market participants should consider enhanced guidance on business interruption and delay-in-start-up cover distinctions.
  • Cross-jurisdictional insurers should align policy language with UK precedents to avoid coverage disputes.

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**Source Notes:**

Case Title: *Sanctions Intelligence Digest*

Link: [https://empyreanprotocol.com/litigation/view/www.bailii.org/ew/cases/EWHC/Comm/2025/1921.html](https://empyreanprotocol.com/litigation/view/www.bailii.org/ew/cases/EWHC/Comm/2025/1921.html)

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