Marine insurance: fair presentation and war risks

The decision of the Court of Appeal in Delos Shipholding SA and Others v Allianz Global Corporate and Specialty SE and Others [2025] EWCA Civ 1019; [2025] Lloyd's Rep IR 505 is the first detailed consideration at an appellate level of the meaning of "knowledge" for the purposes of the duty of fair presentation under the Insurance Act 2015. Other issues discussed by Dias J at first instance ([2024] Lloyd's Rep IR 525) were not, however, resolved.

The other aspect of the case was the proper interpretation of the American War Risks Clauses. On each point the conclusions of Dias J were affirmed.