Carbis Bay Hotel Limited & Anor v American International Group Limited
Decision date: 9 May 2025
Neutral citation: [2025] EWHC 1041 (Comm)
Court: High Court (Commercial Court)
Insurance classification confidence: high
Overall AI summary confidence: high
Short overview
A short description of the case, material issue, and outcome where supported by the judgment.
AI confidence in this overview: high
This case concerned whether the Business Interruption "Infectious Diseases" extension in an AIG policy covered losses from government-ordered closure due to Covid-19. The central issue was whether the capitalised defined term "Disease" is limited to a closed list of 33 named diseases in the policy or extends more generally to any human infectious or contagious disease. The High Court held that the defined, closed list governs and that Covid-19 is not covered under the ID extension; the insurers' construction succeeded.
Ratio decidendi
The legal reasoning necessary to the outcome, where it can safely be identified from the judgment.
AI confidence in this ratio summary: high
A capitalised, defined contractual term introduced into an extension and expressed using definitional wording (for example "means") will ordinarily be treated as exhaustive and to govern scope, so as to restrict coverage to the specific items listed, unless there are compelling interpretative reasons to displace that ordinary approach; minor drafting redundancy (such as "AIDS or an AIDS-related condition") does not suffice to override an otherwise clear, closed defined list of diseases.
Obiter dicta
Judicial observations that were not necessary to the outcome, where they can safely be identified.
AI confidence in this obiter summary: medium
Headings (such as "Infectious Diseases") are merely labels and should not be allowed to override clear operative language that follows; provisional decisions of the Financial Ombudsman Service on similar wordings may reflect a reasonable policyholder understanding but are not binding on the court, though they can be indicative.
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; the court's full reasoning and any additional factual or legal material in that omitted section are not available for this summary.