Utmost good faith

Affirmation

The decision of Stanley Burnton J in Spriggs and others v Wessington Court School Ltd [2004] EWHC 1432 (QB) raises an important issue of principle in relation to the affirmation of liability policies despite a breach of the duty of utmost good faith on the part of the assured: must the acts that allegedly amount to affirmation be addressed to the assured, or is it enough that they are addressed to a potential claimant against the assured?