On 30 June 2026 the Court of Appeal handed down its much-anticipated judgment in Angel & Ors v Black Horse Ltd & Ors, an important appeal for the motor finance industry and legal proceedings more generally. A number of lenders appealed the decision of Mr Justice Ritchie, which had allowed thousands of motor finance commission “unfair relationship” claims brought under sections 140A-C of the Consumer Credit Act 1974 to proceed together as a “multi-claimant” claim on one claim form. Ritchie J had overturned the decision in the county court that the claims should be severed and run separately as small claims.

Coulson LJ (with whom the President of the Family Division and Stuart-Smith LJ agreed) dismissed the lenders’ appeals. The Court held:

• The claims involved common issues of law and fact because they engaged the same statutory provisions and gave rise to the same general issues (non-disclosure of discretionary commissions paid by lenders to motor dealers). Points of difference identified by the lenders were likely to arise in many claims so as to form common issues themselves.
• The trial of lead cases was plainly a sensible step and a clear pointer towards the convenient disposal of the claims on a multi-claimant basis. Lead cases that were carefully selected so as to reflect the range of fact patterns would produce results that were commercially persuasive and encourage settlement of the remainder. They did not need to produce binding results.
• There was a juxtaposition between the value of the individual claims and the court resources and costs required to resolve them. The lenders’ opposition to common disposal could only have reflected the commercial advantage to them of the claims running separately, which would likely lead to many of them falling away. The most practical way of ensuring a measure of justice for the claimants was to efficiently case manage their claims to a convenient disposal on a multi-claimant basis.
• Ritchie J was also entitled to make the further case management directions he made, which included requiring the defendants to disclose the key contractual documents applicable to each individual claim in advance of the selection of lead cases.

The appeals represent a significant win not just for the claimants but for consumers pursuing relatively low value claims with common issues of law and fact.

Jonathan Butters was led by David Cavender KC (One Essex Court) for the successful claimants, instructed by Barings Law.

A copy of the judgment is available here.