Allianz Australia Insurance Limited v AIG Australia Limited
The Federal Court has dismissed a claim by Allianz Australia Insurance Limited for equitable contribution from AIG Australia Limited, holding that no double insurance existed between the two policies. The dispute arose from a Brighton, Victoria construction project, where a gate modified by subcontractor Built Tech Hoardings Pty Ltd fell and seriously injured a traffic controller. Allianz, which insured Built Tech directly, paid settlements of 1 million dollars and 650,000 dollars plus defence costs, then sought contribution from AIG, which insured the broader Icon construction group under an annual public liability policy.
Business implications
Insurers and brokers arranging liability cover for construction or similar projects with multiple layers of insurance may wish to review how difference in conditions and other insurance clauses are drafted and how courts are likely to construe them where wording refers to named insureds but is intended to apply more broadly. Where a client is insured under more than one policy for the same risk, it may be worth checking whether the policies are intended to operate concurrently or sequentially, and whether that intention is clearly reflected in the drafting, before a contribution dispute arises following a claim.
