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Mode Management Ltd & Anor v AXA Insurance UK PLC [2025] EWHC 2035 (Comm) (31 July 2025)

Source: Open mirrored case · Original bailii.org

Sanctions — Geo ✓

Executive Summary

  • The case concerns Mode Management Ltd and Gary Tregunno’s claim against AXA Insurance UK Plc regarding a Property Investor’s Protection Plan Insurance policy.
  • The claim arises from a fire on 7 February 2018 that destroyed/damaged industrial units owned by Mr Tregunno and insured under the policy held by Mode.
  • AXA avoided the policy ab initio citing misrepresentation and non-disclosure related to ownership, planning permissions, and county court judgments.
  • The claimants seek declaratory relief, specific performance, damages under FSMA, and other reliefs.
  • AXA applied for summary judgment and/or strike out on grounds including limitation periods and lack of prospects of success.
  • The court narrowed the issues, focusing on specific performance, FSMA damages, and a claim under the Fire Prevention (Metropolis) Act 1774.
  • The judgment addresses procedural and substantive legal principles relevant to summary judgment and strike out applications.

Sanctions Highlights

  • — No sanctions implications identified in the case.

Emerging Risks

  • Potential reputational risk for insurers in handling claims involving complex ownership and disclosure issues.
  • Legal uncertainty around insurance contract enforcement where policy avoidance is based on alleged misrepresentation.
  • Risk of protracted litigation due to evolving jurisprudence on insurance claims and statutory remedies.
  • Challenges in proving claims under older statutes (e.g., Fire Prevention Act 1774) in modern commercial contexts.

Geopolitical Impact

  • The case is situated within the UK legal system, specifically the England and Wales High Court (Commercial Court).
  • Reflects ongoing UK judicial scrutiny of insurance industry practices and consumer protection under UK law.
  • Highlights the role of UK courts in balancing insurer rights and policyholder protections amid complex commercial disputes.
  • No direct international geopolitical ramifications, but underscores UK’s robust legal framework for commercial insurance disputes.

Economic Intelligence

  • The dispute involves significant commercial property insurance claims, with implications for risk assessment and underwriting in UK property markets.
  • AXA’s avoidance of the policy may influence insurer approaches to due diligence and risk disclosure requirements.
  • Potential financial exposure for insurers if courts limit the scope of policy avoidance or expand remedies for policyholders.
  • The case may affect insurance premium pricing and claims handling strategies in the UK commercial insurance sector.

Strategic Recommendations

  • Insurers should enhance transparency and documentation during underwriting, especially regarding ownership and planning permissions.
  • Legal teams should monitor evolving case law on insurance contract avoidance and statutory claims under FSMA and historic statutes.
  • Policyholders and corporate owners must ensure clear, accurate risk disclosures to avoid policy avoidance risks.
  • Litigation strategies should consider summary judgment thresholds and focus on narrowing issues to core legal questions.
  • Stakeholders should prepare for potential regulatory scrutiny on insurance claim practices in the UK market.

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**Source Notes:**

Sanctions Intelligence Digest — [https://empyreanprotocol.com/litigation/view/www.bailii.org/ew/cases/EWHC/Comm/2025/2035.txt](https://empyreanprotocol.com/litigation/view/www.bailii.org/ew/cases/EWHC/Comm/2025/2035.txt)

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