People

Dominic Bright

Dominic’s practice includes commercial, property and personal injury (including credit hire). He is a registered Civil and Commercial Mediator with the Civil Mediation Council, and offers online and telephone mediation services at www.ResolvedOnline.com.  Dominic also edits Jus Cogens, the online journal providing news, expert analysis and compelling opinion on public and private international law for those with an international aspect to their practice.

His Honour Judge Dight CBE, Resident and Designated Civil Judge, Central London and Mayor’s & City of London Courts, concluded that the second edition of ‘A Practical Guide to the Small Claims Track’ is “essential reading … for all practitioners who handle small claims [and that] the judges of the county court (whether salaried or fee-paid) would benefit considerably by reading this book and keeping it by their side”.  The second edition received four judicial testimonials.

The first edition received one judicial testimonial, and two Five Star reviews.

Dominic can be instructed directly, without having to involve a solicitor.  He is registered on the Direct Access Portal.  Dominic is also a member of Advocate (the Bar’s national charity), matching him with members of the public who need help, are unable to obtain legal aid, and cannot afford to pay.

Prior to pupillage, Dominic was judicial assistant in the Court of Appeal to Sir Brian Leveson, the former President of the Queen’s Bench Division.  He was also researcher in construction law at a leading set of barristers’ chambers, public international law at the British Institute of International and Comparative Law, and national implementation measures (nuclear disarmament, non-proliferation, development and use of chemical weaponry) at the Verification Research, Training and Information Centre. Dominic is an Associate of King’s College London.

Connect with Dominic on LinkedIn and follow him on Twitter.

 

Publications

Dominic assists authors to publish academic articles and professional texts on national and international law.  He also publishes in his own right.

Books

Articles

Seminars / training

Dominic accepts invitations to present seminars / training from professional clients. He also attends other professional events.

Recent invitations

  • ‘Small Claims Training’ – Seminar One, 8 September 2020 (admissions; interim payments; and remote final hearings); Seminar Two, 30 September 2020 (when, how and benefits of making an oral application for strike out and / or summary judgment; judicial intervention v entering the arena; and departure from fixed costs following a finding that a party has behaved unreasonably); and Seminar Three, 23 October 2020 (appearing against litigants in person)
  • Training for a niche commercial and residential property law firm on forfeiture, trespass and assured shorthold tenancies (July 2020)
  • ‘Future of International Dispute Resolution’ (discussant analysing the effects of the COVID-19 pandemic on international commercial contracts with the International Dispute Resolution Group, June 2020)
  • ‘Jurisdiction and Choice of Law Clauses in International Commercial Contracts’ (seminar to City lawyers, November 2019)
  • Defence barrister in a mock trial following a road traffic collision and claim for credit hire (training for a leading law firm of about 2,500 employees and an insurer with over 166,000 employees, July 2019)

Recent events

Further information

Dominic holds two postgraduate qualifications, is an active member of various domestic and international professional associations, and enjoys gardening, travelling and learning about geopolitics when time permits.

Qualifications

  • Master of Laws (LL.M) in Professional Legal Practice (incorporating the BPTC), BPP University Law School, London Holborn, awarded Distinction
  • Master of Laws (LL.M), King’s College London, School of Law, awarded Distinction
  • Law (LL.B Hons) with European Legal Studies, King’s College London, School of Law (incorporating an Erasmus exchange at Uppsala University, Sweden)

Memberships

Interests

Dominic’s personal injury practice is founded upon repeat instructions by professional clients acting for insurers, where there are often allegations of “fundamental dishonesty”, or that, upon a claim being struck out, the conduct of a claimant is alleged to be “likely to obstruct the just disposal of proceedings”, so as to depart from the general rule of qualified one-way costs shifting (“QOCS”).

Fast track and multi-track trials frequently include claims for credit hire, where there are disputes relating to rate, impecuniosity, mitigation of loss, enforceability, storage and recovery charges, and delivery and collection charges.

Dominic is frequently instructed by defendant insurers to apply for strike out, and substantial costs on the basis that the claimant has behaved unreasonably, where – although there is no claim for pain, suffering and loss of amenity – there is a significant claim for credit hire.

Recent instructions

  • R v C – successfully submitted that less than half of the sum claimed for credit hire should be awarded, and that the defendant should not have to pay the hearing fee.  Email from professional client, dated 4 December 2020: ‘Fantastic result on this one especially with them losing out on the hearing fee’.
  • A v W – successfully submitted that failure to provide an engineer’s report, and evidence in support of the pleaded plea of impecuniosity, should be marked by awarding fixed costs and disbursements proportionate to the judgment sum, as opposed to the amount that was claimed (November 2020).
  • A v E – successfully resisted an application for relief from sanctions, and submitted that less than one-third of the sum claimed for credit hire should be awarded (November 2020).
  • O v W – successfully submitted that the claimant should be awarded about half of the issue fee, despite the defendant driver being held liable for causing a road traffic collision.  Email from professional client, dated 16 November 2020: ‘Thank you for noticing the position re the Claimant’s costs as well – a small win!’
  • S v J – successfully made an oral application to rely on evidence that only came to the judge’s attention on the morning of the hearing, that less than half of the sum claimed for credit hire be awarded, and that a recital should be included in the order that ‘an engineer’s fee is not a head of loss’ (November 2020).
  • F v A – successfully submitted that less than half of the sum claimed for credit hire should be awarded, and that the defendant should not be ordered to pay the hearing fee, due in part to the claimant’s conduct and limited success (November 2020).
  • C v H – successfully submitted that the claim for credit hire in the sum of over £23,000 be dismissed as it should have been pleaded as a claim for loss of profit, and that the claimant pay the defendant’s costs of about £3,500 (October 2020).
  • T v W – successfully submitted that about one-quarter of the sum claimed for credit hire should be awarded (October 2020).
  • C v A – successfully submitted that: the claimant was able to travel to work over a seven-day period by walking half an hour from home to the tube using public transport, and walking half an hour from the tube back home, therefore the claimant had not overcome the low hurdle of need in Giles v Thompson; that the defendant should not have to pay the legal representative’s costs or the hearing fee; and that a recital should be included in the order that ‘the engineer’s fee is not a recoverable head of loss or disbursement on the small claims track’.  Email from professional client, dated 7 October 2020: ‘Thank you ever so much for this – what a fantastic result! … I will be sure to share the recital in the order with the credit hire team, so that hopefully this benefits them.’
  • B v G – successfully made an oral application to rely on the key evidence in the counterclaim, which was filed and served the day before the final hearing, despite a finding that there was a serious and significant breach of a court order, for which there was no good reason. Email from professional client, dated 29 September 2020: ‘Many thanks for the below and your assistance with the above matter.  I look forward to working with you again!’
  • M v C – successfully resisted the claimant’s application for relief from sanctions, and submitted that judgment be awarded on the counterclaim in the sum claimed with interest (September 2020).
  • J v S – successfully submitted that about one-quarter of the sum claimed for credit hire and about four-fifths of the sum claimed for repairs be allowed, and that the claimant’s costs be reduced by about one-fifth as impecuniosity was pleaded but dropped at the final hearing (September 2020).
  • U v H – successfully resisted the defendant’s application for relief from sanctions and invited judgment to be awarded for the full sum claimed with interest (September 2020).
  • S v D – successfully submitted that about a third of the sum claimed for credit hire be awarded, and that the claimant’s costs be reduced so that they were less than half the sum claimed (September 2020).
  • D v E – successfully submitted that the claim for credit hire should be dismissed because the credit hire agreement was unenforceable (September 2020).
  • S v E – successfully resisted two videos being admitted into evidence, alleged to be contemporaneous to the index road traffic collision, supporting the claim and undermining the defence (September 2020).
  • S v L – skeleton argument resisting an appeal against the judgment of the lower court, in which a claim for credit hire in the sum of about £12,000 was dismissed (August 2020).
  • A v M – successfully applied to strike out the claimant’s claim for PSLA, vehicle damage and credit hire in the sum of about £15,000, and that the claimant pay the defendant’s costs of £4,500, on the basis that the protection afforded by qualified one-way costs shifting was disapplied because the conduct of the claimants was likely to obstruct the just disposal of proceedings (August 2020).
  • B & Anor v A – successfully applied to strike out the claimants’ claims of £16,000 (to which the defendant admitted liability), and that the claimants pay the defendant’s full costs of about £5,200, on the basis that the protection afforded by qualified one-way costs shifting was disapplied because the conduct of the claimants was likely to obstruct the just disposal of proceedings (August 2020).
  • W v H – successfully resisted the claimant’s application for relief from sanctions, so that the claimant was debarred from asserting impecuniosity, and about one-quarter of the sum claimed for credit hire was awarded (August 2020).
  • M v A – successfully submitted that the claim for credit hire be dismissed as it should have been pleaded as a claim for loss of profit. Email from professional client, dated 21 August 2020: ‘What an excellent win Dominic. Thank you so much for your hard work.’
  • W v H – successfully applied for an order for pre-action disclosure on the basis that the applicant and respondent are likely to be parties to proceedings, standard disclosure extends to the documents sought and disclosure is desirable, and that £1,700 costs be paid to the applicant (August 2020).
  • G v A – successfully submitted that the claimant had not proved that she was impecunious, so that the basic hire rate was awarded (August 2020).
  • N v T – successfully submitted that the claim for credit hire be dismissed on the ground that the credit hire agreement was unenforceable, and that the claimant had behaved unreasonably, so that the defendant was awarded costs (July 2020).
  • B v A – successfully submitted that impecuniosity was not made out, so that about one-third of the amount claimed for credit hire was awarded (July 2020).
  • F v P – successfully applied to set aside an order granting relief from sanctions, so that the claim remained struck out, and that the claimant pay the defendant about £1,800 costs (July 2020).
  • S v L – successfully submitted that the claim for about £12,000 should have been pleaded as loss of profit, so that the claim was dismissed and the other heads of loss including PSLA were less than the defendant’s Part 36 Offer to settle. Email from professional client, dated 22 July 2020: ‘Thank you very much Dominic. Fantastic result.’
  • V v T – successfully submitted that an intervention letter was received, Copley-compliant, and that it was reasonable to accept the offer that it contained, so that about one-fifth of the amount claimed for credit hire was awarded. Email from professional client, dated 13 July 2020: ‘Great result!
  • H v R – in the words of the judgment: During careful cross-examination by defence counsel, the claimant was taken to various inconsistencies in her evidence, accepting ultimately … that certainly the documents exhibited were not the full account of her financial position.” There was no finding of impecuniosity, the basic hire rate was awarded amounting to about one-third of the amount claimed for credit hire, and the other two heads of special damage were dismissed (July 2020).
  • L v V – successfully represented the defendant, so that, despite the court awarding judgment for the full amount, the claimant was nevertheless found to have behaved unreasonably and ordered to pay the defendant’s costs of about £800. Email from professional client, dated 7 July 2020: ‘I have read through your report and all I can say is wow.  Just wow.’
  • W v B – successfully invited the court to award about one-third of the sum claimed for credit hire and dismiss the other head of special damage (June 2020).
  • L v H – successfully submitted that the basic hire rate should be awarded, so that only about one-quarter of the sum claimed for credit hire was awarded, and the hearing fee was not awarded because there was no evidence of impecuniosity and the claimant failed to beat an offer that was made before the hearing fee was due (June 2020).
  • L v A – successfully submitted that about one-fifth of the sum claimed for credit hire should be awarded (June 2020).
  • R-B v N – successfully submitted that the claim should be dismissed for the reason that, on a balance of probabilities, liability had not been established (June 2020).
  • Advice on causation, quantum, responding to a Part 36 Offer to settle, and making a Part 36 Offer to settle following the proposed claimant’s alleged fall in a fruit and vegetable shop (June 2019).
  • A v A – successfully resisted the claimant’s application for relief from sanctions and permission to rely on evidence that was filed and served before the final hearing was relisted; and applied for the claimant to pay the defendant’s costs on the basis that the claimant had behaved unreasonably.  Email from professional client, dated 29 May 2020: ‘Thank you, great result as always!
  • H v T – successfully submitted that about a quarter of the amount claimed for credit hire be awarded, and nothing for three of the other heads of loss (May 2020).
  • J & Anor v A – successfully applied for the defendant’s costs following the claimant’s application to adjourn (May 2020).
  • C v H – successfully applied to exclude the claimant’s statement that was filed and served three days after the date for exchange; and applied for the claim to be struck out because the claimant had no evidence.  Email from professional client, dated 15 May 2020: ‘Great results.
  • A v C – successfully applied for the Stage 3 hearing to determine quantum for credit hire, recovery and storage, loss of earnings, and general damages for pain, suffering and loss of amenity to be vacated, and that the Part 8 claim be transferred to Part 7 (May 2020).
  • S v S – started to cross-examine the claimant on discrepancies in the evidence before he left the hearing, and successfully submitted that the claim should be dismissed as the burden of proof had not been discharged, and that the claimant had behaved unreasonably by leaving the hearing, so that the court should award an amount of costs to the defendant (April 2020).
  • S v Z – successfully submitted that, although the claimant had substantially succeeded, no costs should be awarded to mark that the claimant had behaved unreasonably for three reasons, first the failure to file and serve key documents, secondly the erroneous allegation that the defendant had not served any evidence, thirdly the failure to inform the defendant or the court that the claimant’s statement was materially incorrect before it was adopted (without amendment) as her evidence in chief (April 2020).
  • C v A – successfully submitted that there was no evidence that the claimant needed to hire a credit hire vehicle, and although the matter was adjourned to allow further evidence, it was on the condition that the claimant pay the defendant’s costs to be assessed if not agreed (April 2020).
  • W v C – successfully submitted that less than half the amount claimed for credit hire be awarded (March 2020).
  • V v R – successfully applied for relief from sanctions about a month before trial, after admission of serious and significant breaches of court directions without good reason, in relation to disclosure and service of witness statements, successfully made an oral application for permission to rely on documents evidencing the claim for special damages that had only been filed and served three days previously, and successfully resisted the defendant’s application for costs (about £8,000) that exceeded fixed recoverable costs (£300) (March 2020).
  • Advice on quantum following a road traffic collision, in which a minor suffered physical injuries, including to his lower back, right hip and right leg, and psychological injuries, including initial acute stress symptoms and contribution towards Autism Spectrum Disorder symptoms, namely separation anxiety and enuresis (March 2020).
  • A v S – successfully submitted that the court should dismiss the claim, and that the claimant behaved unreasonably, so that the claimant should pay the defendant’s costs (March 2020).
  • M v C – successfully submitted that about one-fifth of the amount claimed for credit hire be awarded (March 2020).
  • K v E – successfully submitted that less than half the amount claimed for credit hire be awarded (February 2020).
  • S v N – successfully submitted that about one-fifth of the sum claimed for credit hire be awarded (February 2020).
  • W v B – successfully submitted that the claim for diminution in value, policy excess and interest should be dismissed, and that the counterclaim for the defendant’s policy excess, the defendant insurer’s outlay, and interest should be allowed (February 2020).
  • B v A – successfully submitted that the claims for credit hire, engineer’s fee and interest should be dismissed, and that the hearing fee should not be awarded as the claim for repairs was admitted in the defence (February 2020).
  • C v L – successfully applied to add a second defendant and Part 20 claimant (February 2020).
  • T v C – successfully represented the defendant so that the claim for credit hire was dismissed. Email from lay client, dated 13 February 2020: ‘Great result!’
  • W v C – successfully made an oral application to strike out the claim as an abuse of process and successfully applied for a finding that the claimant behaved unreasonably, so that the court ordered the claimant to pay £1,000 in costs to the defendant (February 2020).
  • L v P – successfully applied to disallow the hearing fee after the court awarded judgment in the sum of about £6,000 (February 2020).
  • Advice on prospects of success ahead of a multi-track trial following a claim for general damages for personal injury and special damages for medical expenses, the pre-accident value of a vehicle, credit hire charges of about £30,000, storage and recovery charges, and loss of use of a vehicle, where there was an allegation of fundamental dishonesty, application to strike out and disapply QOCS on the basis that the claimant’s conduct was likely to obstruct the just disposal of proceedings (February 2020).
  • G v T – successfully invited the court to dismiss the claim on the basis of the evidence elicited in cross-examination that the offside of the claimant’s vehicle collided with the front nearside of the defendant’s vehicle on a roundabout (January 2020).
  • P v M – successfully applied to strike out the only head of loss in dispute, and successfully applied for the defendant’s costs on the basis that the claimant behaved unreasonably (January 2020).
  • E v A – successfully resisted an application to add another defendant, invited the court to strike out the claim, and applied for the defendant’s costs on the basis that the claimant behaved unreasonably (January 2020).
  • C v W – successfully submitted that the claim for credit hire should be dismissed as need was not made out (January 2020).
  • P v T – successfully reduced the amount awarded to about one-eighth of the sum claimed for credit hire, and successfully applied to reduce fixed costs to those relevant to the judgment sum (as opposed to the sum claimed). Email from professional client, dated 22 January 2020: ‘Another brilliant result, thank you!
  • G v A – successfully cross-examined the claimant, eliciting evidence of other accidents around the time of the index accident, so that the court could not be sure that the index accident caused the damage alleged in the particulars of claim, and successfully applied for costs on the basis that the claimant behaved unreasonably (January 2020).
  • O (A Minor) & Anor v H & Anor – successfully applied for costs on behalf of the defendant after an infant settlement approval hearing (January 2020).
  • P v S – successfully applied for professional client to come off the record as acting for the claimant on the day of trial, where the defendant indicated that he would apply to strike out the claim, disapply QOCS and seek costs of about £6,000 (December 2019).
  • B v P – successfully secured about one-ninth of the sum claimed for credit hire on behalf of the defendant, and successfully applied for a reduction in the amount of the claimant’s fixed costs. Email from professional client, dated 15 November 2019: ‘Many thanks Dominic really appreciate all your efforts on this one and fantastic result!’
  • M v A – successfully represented the defendant, who saw a gap behind her, and began to reverse, before there was a collision with the claimant’s vehicle. Email from professional client, dated 29 October 2019: ‘Thanks Dominic – great job !’
  • B v L – successfully made an oral application at a directions hearing to strike out, £4,000 costs be awarded to the defendant, and QOCS be disapplied, on the basis that the claimant disclosed no reasonable grounds for bringing the claim, and his conduct was likely to obstruct the just disposal of proceedings (October 2019).
  • K v B & Anor – successfully applied to strike out the claimant’s claim for about £12,000 in respect of credit hire, on the basis that there was a legitimate concern with the claimant’s level of English, and, in absence of a translated witness statement, the court could not place any weight on it (October 2019).
  • Y & Anor v E – successfully applied for permission to rely on expert evidence in a low-value claim, despite a failure to apply to amend / vary directions for trial (that did not grant permission to rely on an expert) and finding that the application was not prompt (October 2019).
  • B v M – successfully settled on the defendant’s terms for about one-third of that claimed (October 2019).
  • H v A – successfully submitted that a Copley-compliant intervention letter was sent to the claimant’s solicitors, who were acting as agents for their client, and so, due to the agent’s failure to pass this letter on to the claimant, about an eighth of the amount claimed for credit hire should be awarded (October 2019).
  • S v I – successfully settled on the defendant’s terms (September 2019).
  • M v G – successfully represented a taxi driver in an alleged “low velocity impact”, who was awarded: about £2,300 general damages for pain, suffering and loss of amenity; about £6,700 special damages for credit hire, vehicle repairs, physiotherapy and miscellaneous expenses; and about £9,000 for costs, disbursements and witness expenses (September 2019).
  • P v E – successfully resisted application to adjourn trial, so that, in response to the claimant’s arguments, the court found opined that: “I have never heard such rubbish in my life … That is total nonsense” (August 2019).
  • S v R – successfully resisted admission of a handwritten, contemporaneous note, allegedly admitting liability, on the basis that it was not on the defendant’s list of documents (August 2019).
  • P v W – successfully cross-examined, so that the judge did not need to hear closing submissions from the defendant before dismissing the claim, allowing the counterclaim (August 2019).
  • B v H – successfully secured the full amount that was claimed for credit hire, on the basis that the claimant was impecunious, despite the judge finding that, as no wage slips were provided, and only incomplete bank statements were provided, the claimant had committed a serious and significant breach of the court’s directions, for which there was no good reason (August 2019).
  • B v L – successfully made an oral application to strike out the case as an abuse of process, and successfully submitted that the claimant behaved unreasonably, so that the court awarded the defendant costs of £2,500. Email from professional client, dated 14 August 2019: ‘What a brilliant result! I have a happy client.’
  • R v I – successfully secured a court award of about one-seventh of that claimed on behalf of the defendant, after liability was admitted, and the judge found that an accident management company was acting as an agent for the claimant, so that this agent should have passed the defendant’s intervention letter on to the claimant (August 2019).
  • S v A – successfully cross-examined the claimant in a fast track trial, in which the judge found that the claimant answered questions “in an unnecessarily argumentative way”, and his claim was dismissed (July 2019).
  • S v E – successfully secured a court award of damages that was not greater than the defendant’s final offer in a stage 3 hearing, and nothing was awarded for six sessions of cognitive behavioural therapy, which were recommended by a consultant psychologist, so that the claimant was ordered to pay the defendant’s costs (July 2019).
  • V v A – successfully adjourned when the defendant’s witnesses did not attend, and, on behalf of the defendant, successfully secured a finding of unreasonable behaviour, so that the claimant was ordered to pay the defendant’s costs of resisting the claimant’s (successful) application for relief from sanctions (July 2019).
  • H v A – successfully cross-examined, so that, in the words of the judge, the claimant accepted that his pleaded case was “completely incorrect”, and his claim was dismissed (July 2019).
  • G v U – successfully challenged the claimant’s witness statements (on the basis that neither complied with court directions, including stating the names of the parties, case number, and the address of the witness), and successfully submitted that there was no evidence of loss in respect of damages for a fleet vehicle, so that, although the cost of repairs was allowed, the claimant was limited to half of his fixed costs (July 2019).
  • K v H – successfully challenged the claimant’s written witness evidence, which attempted to rebut the defendant’s basic hire rates evidence, on the basis that that witness was employed by a subsidiary of a relevant company, and so was not independent (July 2019).
  • Advice on the defendant’s strike out application, the claimant’s relief from sanctions application, quantum (headaches for two years, neck injury for two years, jaw injury for six months, chest injury for six weeks, driving anxiety for six years and four months, and post-traumatic stress disorder for an indeterminate period), and making a Part 36 offer to settle (July 2019).
  • K v R – successfully secured a court award of damages that was not greater than the defendant’s final offer in a stage 3 hearing, so that the claimant was ordered to pay the defendants costs, plus interest (July 2019).
  • M v H – successfully rebutted allegation of impecuniosity, by eliciting in cross-examination that statements for a relevant bank account had not been disclosed; and successfully rebutted fast track costs, despite Particulars of Claim for more than £10,000, so that the ‘normal track’ was the fast track (June 2019).
  • Y v N – successfully applied for permission to resile from pre-issue admission of liability, after judgment had been entered, the judgment sum paid, and the key evidence had not been filed with the court or served on the other party (June 2019).
  • Advised a medium-sized business on liability, contributory negligence, quantum, mediation, and offers to settle, following alleged facial injuries (March 2019).
  • N v W – successful application for specific disclosure, and costs awarded.  Email from professional client, dated 5 February 2019: ‘Thank you for providing your very detailed attendance note. We are pleased with the fantastic outcome and the way in which you conducted the hearing on our behalf.  I will certainly recommend you to my colleagues for similar instructions in the future.’
  • D v K – successfully submitted that the claim should be dismissed, as need was not established.  Email from professional client, dated 18 February 2019: ‘Many thanks Dominic for you [sic] attendance, detailed note of the outcoming [sic] of the hearing and result the client will be extremely pleased with the result.’
  • K v E – successful oral application to strike out evidence, as the claimant could not understand questions in cross-examination, his directions questionnaire did not confirm that an interpreter was required, and his statement of case and witness statement did not conform to the CPR, so that, upon a further successful oral application, costs were awarded pursuant to a finding of unreasonable behaviour (April 2019).
  • A v G & Anor – email from professional client, dated 23 November 2018: ‘Thank you for your very detailed attendance note and assistance yesterday.  I really appreciate your thoroughness in preparation and attempts to salvage the case when it became apparent that our client was not going to turn up at Court.  Although I always worry whether parties will turn up on the day, we could not anticipate that our client would not actually attend and, ultimately, her non-attendance cost us the case, despite your best efforts.’
  • S v B – fast track trial, where personal injury was alleged to have been caused as a result of breach of the common law duty of care, and statutory duty (owed to lawful visitors) under the Occupiers’ Liability Act 1957 (July 2018).
  • H v M – fast track trial, where personal injury was alleged as a result of breach of the duty of care that an occupier owes to an unlawful visitor under the Occupiers’ Liability Act 1984 (June 2018).
  • M v C – fast track trial, where the claimant alleged personal injury following a low velocity impact (“LVI”) road traffic collision, which the defendant alleged was fundamentally dishonest (April 2018).

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