The undisclosed principal doctrine

In Insurance Law Monthly (Volume 18: May (pp3–7)) there was detailed discussion of the decision of Cooke J in Talbot Underwriting v Nausch Hogan & Murray, The Jascon 5 [2005] EWHC 2359 (Comm). The outcome was the virtual denial of the possibility that the undisclosed principal doctrine applies to insurance contracts. That case has now been before the Court of Appeal ([2006] EWCA Civ 889), which approved the reasoning of the trial judge and considered other matters as well. The leading judgment was given by Moore-Bick LJ. The case proceeded on facts which were assumed to be correct for the purposes of the action.