Managed Legal Solutions Limited v Darren Hanison

Decision date: 16 October 2025

Neutral citation: [2025] EWHC 2645 (Comm)

Court: High Court (Commercial Court)

Insurance classification confidence: high

Overall AI summary confidence: medium

AI notice: Any short overview, ratio decidendi summary, or obiter dicta summary on this page is AI-generated. It is provided solely to help users assess possible relevance and may be inaccurate or incomplete. It is not legal advice. Users should read the original judgment and obtain appropriate legal advice before relying on any summary.

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 application by HDI Global Specialty SE to be joined as a second defendant in Managed Legal Solutions Limited’s claim against Darren Hanison trading as Fortitude Law so HDI can be heard on whether Fortitude owed MLS a freestanding tortious duty. The court found there was a conflict of interest between HDI and Mr Hanison on that issue, and granted joinder, directing MLS to amend the claim form and HDI to file the draft defence exhibited in the application.

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’s decision that an insurer may be joined as a defendant to defend a discrete issue (here, whether the insured owed a freestanding tortious duty) where a real conflict of interest exists between insurer and insured, and where joinder is not unfair notwithstanding the insured having been debarred from defending, is the binding reasoning apparent from the judgment.

Obiter dicta

Judicial observations that were not necessary to the outcome, where they can safely be identified.

AI confidence in this obiter summary: low

No clear obiter dicta can safely be identified from the judgment.

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, which may omit material reasoning or facts relevant to the application.

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