Greggs Plc v Zurich Insurance Plc
Decision date: 17 October 2022
Neutral citation: [2022] EWHC 2545 (Comm)
Court: High Court (Commercial Court)
Insurance classification confidence: high
Overall AI summary confidence: medium
Short overview
A short description of the case, material issue, and outcome where supported by the judgment.
AI confidence in this overview: medium
This is an expedited trial of preliminary issues in Greggs' claim against Zurich for business-interruption losses under a Marsh Resilience policy arising from Covid-19. The court accepted Greggs' primary aggregation case that the relevant "occurrences" can be the different governmental announcements/regulations, held that the PRCM Costs sub‑limit of £75,000 applies in addition to the Limit of Liability and (so) per SBIL, and ruled that government support (CJRS furlough payments and business‑rates relief) must be taken into account in assessing Greggs' loss before application of any SBIL limit.
Ratio decidendi
The legal reasoning necessary to the outcome, where it can safely be identified from the judgment.
AI confidence in this ratio summary: medium
The court held (1) that Greggs' primary case — aggregation by reference to different governmental announcements/regulations as the relevant occurrences — is accepted for the purposes of these preliminary issues; (2) that the PRCM Costs sub‑limit of £75,000 applies in addition to the Limit of Liability and therefore applies per SBIL; and (3) that CJRS and BRR government support are to be taken into account in assessing loss before application of the SBIL limit.
Obiter dicta
Judicial observations that were not necessary to the outcome, where they can safely be identified.
AI confidence in this obiter summary: low
The judge observed (non-decisively) that assigning losses to multiple relevant occurrences is not shown to be impossible and that a Marsh-produced regulation-by-regulation calculation suggests the exercise can be performed.
Warning
The automated summary was prepared from the beginning and end of a long judgment; consult the original decision for the complete reasoning. The middle of the judgment was omitted from the judgment; that omission may exclude relevant reasoning or additional conclusions.