UK Court rejects contention that party may be an additional insured as an undisclosed principal

A broker was directed to procure a policy on a vessal for the benefit of two parties as co-insureds. It failed to have one party named as an insured. When a loss occurred and the claim of the unnamed party was denied, litigation unsued. The UK Court of Appeal held that losses of the unnamed party resulted from breach of duty by the broker, and that the unnamed party could not be considered to be a co-insured based upon its status as an undisclosed principal of the policy's beneficiary. Talbot Underwriting Ltd. v. Nausch, Hogan & Murray, Inc., [2006] EWCA 889 (June 29, 2006).