LM-2024-000066 - [2025] EWHC 1551 (Comm)

Explain precisely how any qualifying misrepresentation under the Consumer Insurance (Disclosure and Representations) Act 2012 (‘CIDRA’) was communicated to the Defendant; and (if and when it was) exactly how, and in what way, anyone, and if so who, at the Defendant relied upon it.

If and to the extent that the Defendant relies upon s. 2 (3) of CIDRA, explain precisely how it claims to be entitled to do so.

Plead that the loss or damage to the Property was caused by or resulted from the contract works, with full and proper particulars as to how this came about.

Set out the Defendant’s case as to precisely how: (i) the estimated cost of the contract works exceeded 20% of the buildings sum insured and/or (ii) the contract works altered the square footage of the house.

The Further Particulars shall be no longer than is strictly necessary, and, in any event, no longer than six pages in length, employing a font size of no less than 12 points, without any foot-notes or annexures; and they shall be verified by a Statement of Truth.

By 4.00 pm on 25 July 2025 the Claimants may file and serve an application for any further directions in response to the Further Particulars, such application to be determined by HHJ David Hodge KC if available.

Upon the Defendant filing and serving the Further Particulars in compliance with paragraph 2 above, and subject to any Order made pursuant to any application under paragraph 4 above, the Application shall be dismissed.

Any written submissions in support of any application for permission to appeal, with concise draft grounds of appeal, are to be filed and served by 4.00 pm on 25 June 2025. Unless otherwise directed, any such application shall be determined on paper. The Parties’ time for applying to the Court of Appeal for permission to appeal, if so advised, is extended until 4.00 pm on 16 July 2025.