In the July 2026 column, George Spence-Jones considers the direction of multi-claimant omnibus claims in the context of motor finance commission, common issues and unfair relationships following the Court of Appeal decision in Angel and others v Black Horse and others [2026] EWCA Civ 831.
The Court of Appeal’s decision in Black Horse Ltd v Angel and others [2026] EWCA Civ 831 (30 June 2026) provides important practical lessons on the future of multi-claimant “omnibus” claims in the motor finance commission litigation. Although the appeal was dismissed, the judgment is far from a straightforward endorsement of the claimants’ procedural route. Instead, it confirms the breadth of the CPR 7.3 “convenient disposal” test while emphasising the limits of common issues in claims based on section 140A of the Consumer Credit Act 1974 (CCA), where unfairness remains a fact-specific inquiry.
This column considers the procedural history of the Angel litigation, the significance of the alleged common issues concerning CONC, unfairness and section 56 of the CCA, and the Court of Appeal’s apparent reluctance to treat the decision as a model for future omnibus motor finance claims.
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