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Before and after.

The House of Lords has found that the duty of utmost good faith varies depending on the stage of negotiations between insurer and client, but John Butler (below) discovers that uncertainty still surrounds post-contractual duty.

The application of the duty of utmost good faith after the conclusion
of an insurance contract was one of the issues to come before the House of
Lords in Manifest Shipping Co. Ltd v Uni-Polaris

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