Court of Appeal
Smith and another v Royal Bank of Scotland Plc
[2021] EWCA Civ 1832
2021 Oct 14; Dec 3
Macur, Coulson, Birss LJJ
Fair tradingConsumer creditAgreementClaimants entering into credit card agreements with banks and taking out related payment protection insuranceMonthly insurance premiums charged to claimants’ credit cardsBanks not disclosing to claimants extent of commission paid to it by insurerClaimants seeking repayment of premiums pursuant to statutory provision allowing court to order repayment of sum paid by virtue of credit or related agreement if relationship between creditor and debtor unfairCredit card agreements continuing after provision brought into force but insurance policies terminated beforeWhether court permitted to take account of policies when assessing fairness of relationshipWhether insurance premiums paid by virtue of credit card agreement as well as insurance policyWhether claimants having cause of action Consumer Credit Act 1974 (c 39), s 140A, 140B Consumer Credit Act 2006 (c 14), Sch 3, paras 14, 16
Limitation of actionStatute, action onAccrual of cause of actionClaimants entering into credit card agreements with banks and taking out related payment protection insuranceBank not disclosing to claimants extent of commission paid to it by insurersClaimants contending non-disclosure rendering relationships between them and bank unfair and seeking repayment of premiumsTime when cause of action accruingWhether premiums paid before six-year limitation period recoverableWhether relationships unfair for entire length of credit agreements even after termination of insurance policiesWhether claims brought more than six years after termination of policies statute-barred Limitation Act 1980 (c 58), s 9

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