Alan Davies & Ors v Ford Motor Company & Ors [2026] EWHC 1531 (KB)

[2026] EWHC 1531 (KB)Case No QB-2021-002678
IN THE HIGH COURT OF JUSTICE
KING’S BENCH DIVISION
Venue Royal Courts of Justice, Rolls Building, Fetter Lane, London, WC4A 1NLDate 19 June 2026MR JUSTICE BRIGHT
ALAN DAVIES & othersClaimantsFORD MOTOR COMPANYDefendantsFORD MOTOR COMPANY LIMITEDDefendantFORD-WERKE GmbHDefendantFORD MOTOR COMPANY OF AUSTRALIA LIMITEDDefendantFORD RETAIL LIMITEDDefendantFCE BANK PLCDefendantALD AUTOMOTIVE LIMITEDDefendantAUTHORISED DEALERSHIPSDefendant
Oliver Campbell KC, Freya Foster, Kate Gardiner (instructed by Leigh Day, Pogust Goodhead) for ClaimantsSonia Nolten KC, George Hilton, Benjamin Phelps (instructed by McGuireWoods London LLP) for DefendantsHearing Hearing dates: 16 June 2026
Approved JudgmentThis judgment was handed down remotely at 2pm on 19 June 2026 by circulation to the parties or their representatives by e-mail and by release to the National Archives..............................

Introduction

[1]This judgment is concerned with the Claimants’ application for permission to amend their case against the Defendants (collectively, “Ford”). The relevant application notice was issued on 10 April 2026.[2]I am very grateful to both legal teams, in particular Mr Campbell KC for the Claimants and Miss Nolten KC for Ford, for their very great assistance and efficiency.

Procedural background

[3]The application arises in proceedings involving group litigation concerned with the levels of oxides of nitrogen (“NOx”) emitted by vehicles in normal operation and use. The proceedings include numerous separate actions. Pursuant to a group litigation order (“GLO”) made at a very early stage, on 23 November 2023, these actions are all being managed together, by two designated judges: initially, Cockerill J (as she then was) and Constable J; now, Constable J and me. Taken together, the actions are said to form one of the biggest sets of group proceedings claims ever brought in this country, if not the biggest.[4]There has, accordingly, been active case management from the outset, with carefully considered progress dates imposed, and strict adherence to these dates being required by the court.[5]The main complaint against Ford and against the other motor manufacturers involved has always been that their vehicles incorporated design elements which, under Regulation 715/2007 (“the Emissions Regulation”), amounted to a prohibited defeat device (“PDD”), which had the effect that NOx levels in normal vehicle operation and use were materially higher than in regulatory testing.[6]At a case management conference in March 2024, the court gave directions which led to the issues being tried in tranches.(1) Tranche 1 was to concern various issues relating to decisions made by the Federal Motor Transport Authority of Germany. The trial for this was fixed to take place in October 2024.(2) Tranche 2 was to concern liability issues relating to PDDs. The trial for this (originally 10 weeks, later expanded so as to last considerably longer) was fixed to take place commencing in October 2025.(3) The trial Tranche 3 was to concern causation and quantum in respect of the PDD claims and the PDD liability issues decided at the PDD trial in Tranche 2. This was directed to take place in October 2026.[7]The Tranche 2 trial concluded in March 2026. Judgment in relation to the PDD liability issues tried in Tranche 2 has not yet been handed down, but it is hoped that it may be available in July.[8]The Tranche 2 trial was intended to capture the core complaints of the many Claimants (i.e., the Claimants in other proceedings, as well as those bringing claims against Ford). However, it was always understood that there were other claims and other issues, which would not be captured by the Tranche 2 and Tranche 3 trials, some or all of which might need to be tried later – always depending on the outcome of Tranche 2.[9]Accordingly, a further case management hearing is provisionally due to take place at the end of July 2026 (if the Tranche 2 judgment is available in good time). Its purpose will be to consider what directions are required for the unresolved issues which still need to be determined.

The new SOx allegations

[10]As noted above, the main complaint to date has been in relation to PDDs. The PDDs are said to have had the effect that the vehicles emitted materially higher levels of NOx in normal operation and use than in regulatory testing. The regulators and relevant authorities (notably, in the UK, the Vehicle Certification Agency, “VCA”) therefore were misled as to the true level of NOx emissions. So were the Claimants.[11]The proposed amendments also relate to excessive NOx emissions in normal operation and use, but arising from a different cause – i.e., not because of PDDs. It is said that some Ford vehicles contained a Lean NOx Trap (“LNT”), which, over time, adsorbed oxides of sulphur (“Sox”) such that the LNT no longer functioned adequately. Furthermore, the On Board Diagnostics (“OBD”) systems of these vehicles failed to identify this malfunction. The result was that affected vehicles could not effectively limit NOx emissions. This is referred to as the “SOx Defect”.[12]The proposed amendments also allege that the relevant vehicles have had various updates installed (“the SOx Updates”) with the result that they do not comply with their Type Approval, and their Certificates of Conformity (“CoCs”) do not conform to the attributes promised and required by the Type Approval. The Claimants wish to allege that Ford was aware of the SOx Defect by mid-June 2016, and had confirmed the cause by January 2017. They developed the SOx Updates (including the adoption of an existing update), which were then applied to the relevant vehicles. The Claimants say that the SOx Updates were not wholly effective, and had other consequences (e.g. increased fuel consumption), but are significant because(i) they demonstrate Ford’s knowledge of the SOx Defect but(ii) neither the effects of the updates nor the reasons for introducing them were communicated to the VCA, leading to further non-compliance in relation to Type Approval.[13]The SOx Defect, and the associated allegations relating to the SOx Updates, are said to give rise to a number of causes of action:(1) Breach of statutory duty: the Claimants say that Ford breached specified European and Domestic regulations by manufacturing and supplying vehicles affected by the SOx Defect, failing to rectify the SOx Defect and/or failing to update the Type Approval to reflect the impact of the SOx Updates.(2) Breach of contract: the Claimants say that the SOx Defect and the SOx Updates meant that the affected vehicles were not of satisfactory quality, did not correspond to their description, and breached their statutory guarantees.(3) Breach of the Consumer Protection from Unfair Trading Regulations 2008: the Claimants say that the SOx Defect amounted to a breach of the Consumer Protection from Unfair Trading Regulations 2008.(4) Deceit: the Claimants who acquired a vehicle affected by the SOx Defect after 14 June 2016 say that Ford thereafter deliberately concealed the SOx Defect, and permitted vehicles affected by it to be put into service, registered and/or sold, despite having a duty to speak to customers.(5) Unfair relationship: the Claimants say that the SOx Defect gave rise to, or contributed to, an unfair relationship within Section 140A Consumer Credit Act 1974.

The time-bar issue

[14]Ford’s objections to the application centre around their contention that the claims are time-barred, because of the six-year limitation period under the Limitation Act 1980 (notably, Sections 2 and 5). To this, the Claimants have two responses.[15]The first is that the claims of some Claimants arose less than six years ago. The Claimants are unable to produce a definitive list naming all the relevant Claimants, but their evidence from Mr Gregory Alan Lewis of Pogust Goodhead (one of the two lead firms acting for the Claimants) is as follows:
“On the information currently available to me, I estimate that at least around 8,630 Claimants would have a cause of action accruing after 16 June 2020. … This figure is based on the figures from the Leigh Day cohort and applied pro rata to the wider cohort.”
[16]My understanding from this is that there is a definitive figure for the number of Claimants recruited by Leigh Day whose claims are said not to be time-barred, but the exercise of identifying all the relevant individual Claimants from the Pogust Goodhead cohort has not been undertaken. Mr Lewis therefore has extrapolated.[17]In proportional terms, 8,630 represents a small minority of the Claimants. However, a total of 8,630 claims is nevertheless significant, in that it is too large to be considered negligible.[18]Miss Nolten KC suggested that, because the Claimants cannot presently say definitively how many Claimants fall into this category, or give their names, I should disregard their evidence that there are such Claimants. That submission has no weight. Mr Lewis’s evidence appears to mean that the relevant Leigh Day Claimants could be identified now, if necessary; and I infer that at least some of the relevant Pogust Goodhead Claimants could also be identified now if necessary, albeit there may be further Pogust Goodhead Claimants whose status is not clear.[19]If it were important to Ford to have the names of those Claimants who can, now, definitely be said to have claims that did not arise until after 16 June 2020, they could have asked. They chose not to. It seems obvious that, if they had, the number of names that could have been produced might well have fallen short of 8,630, but I infer that it would still have been a substantial number. By this I mean, a small minority of the Claimants, but still too large to be negligible.[20]The Claimants’ second answer is that all the Claimants can rely on section 32 of the Limitation Act 1980, in that facts relevant to their claims were deliberately concealed by Ford. They also rely on the fact that some Claimants have claims in deceit.[21]The Claimants’ position on deliberate concealment is that Ford knew of the SOx Defect from at least mid-June 2016, but concealed it from the Claimants (as well as others, including the VCA) until documents relating to the SOx Updates were disclosed in this litigation. Firmware which included the Sox Updates was disclosed in July 2024, and further firmware was disclosed in November/December 2024. Further non-firmware documents relating to the Sox Updates were disclosed in April/May 2025.[22]Neither side suggested that I could or should decide the issue of deliberate concealment. In effect, the Claimants accepted that Ford has an arguable limitation defence (save in relation to the approximately 8,630 Claimants whose claims arose after 16 June 2020); Ford accepted that the Claimants have an arguable case under Section 32 of the Limitation Act 1980.

S. 35 Limitation Act 1980; CPR 17.3, 17.4

[23]The real battle-ground was, rather, in relation to ‘relation back’, in the light of section 35(1)(b) of the Limitation Act 1980 and CPR 17.3 and 17.4.[24]The relevant provisions in section 35 are as follows:
“35. New claims in pending actions: rules of court. (1) For the purposes of this Act, any new claim made in the course of any action shall be deemed to be a separate action and to have been commenced— (a) in the case of a new claim made in or by way of third party proceedings, on the date on which those proceedings were commenced; and (b) in the case of any other new claim, on the same date as the original action. (2) In this section a new claim means any claim by way of set-off or counterclaim, and any claim involving either— (a) the addition or substitution of a new cause of action; or (b) the addition or substitution of a new party; and “third party proceedings” means any proceedings brought in the course of any action by any party to the action against a person not previously a party to the action, other than proceedings brought by joining any such person as defendant to any claim already made in the original action by the party bringing the proceedings. (3) Except as provided by section 33 of this Act or by rules of court, neither the High Court nor the county court shall allow a new claim within subsection (1)(b) above, other than an original set-off or counterclaim, to be made in the course of any action after the expiry of any time limit under this Act which would affect a new action to enforce that claim. For the purposes of this subsection, a claim is an original set-off or an original counterclaim if it is a claim made by way of set-off or (as the case may be) by way of counterclaim by a party who has not previously made any claim in the action. (4) Rules of court may provide for allowing a new claim to which subsection (3) above applies to be made as there mentioned, but only if the conditions specified in subsection (5) below are satisfied, and subject to any further restrictions the rules may impose. (5) The conditions referred to in subsection (4) above are the following— (a) in the case of a claim involving a new cause of action, if the new cause of action arises out of the same facts or substantially the same facts as are already in issue on any claim previously made in the original action; and (b) in the case of a claim involving a new party, if the addition or substitution of the new party is necessary for the determination of the original action.” (a) in the case of a new claim made in or by way of third party proceedings, on the date on which those proceedings were commenced; and (b) in the case of any other new claim, on the same date as the original action. (a) the addition or substitution of a new cause of action; or (b) the addition or substitution of a new party; (a) in the case of a claim involving a new cause of action, if the new cause of action arises out of the same facts or substantially the same facts as are already in issue on any claim previously made in the original action; and (b) in the case of a claim involving a new party, if the addition or substitution of the new party is necessary for the determination of the original action.”
[25]It follows from section 35(3) that, except as provided by Section 33 or by rules of court, the court has no power to allow a “new claim” as defined (other than an original set-off or counterclaim) to be made in the course of any action after the expiry of any time limit which would affect a new action. However, in imposing this restriction on the court’s power, section 35(3) refers expressly to a new claim “within subsection 1(b) above”. It therefore is necessary to consider not only the definition in section 35(2), but also section 35(1)(b), in order to understand the true ambit of section 35(3) and its restriction of the court’s power.[26]The court’s general power to allow amendments is confirmed under CPR 17.3. This provides at 17.3(2) that the power to permit amendments is subject to CPR 17.4.[27]While CPR 17.3 does not expressly refer to the court’s power to permit amendments subject to conditions, the general power to impose conditions under CPR 3.1(3)(a) is also relevant.[28]CPR 17.4 relates specifically to amendments after the end of a limitation period. The relevant limbs are 17.4(1) and (2), which provide as follows: “17.4(1) This rule applies where – (a) a party applies to amend their statement of case in one of the ways mentioned in this rule; and (b) a period of limitation has expired under – (i) the Limitation Act 1980; (ii) the Foreign Limitation Periods Act 1984; or (iii) any other enactment which allows such an amendment, or under which such an amendment is allowed.(2) The court may allow an amendment whose effect will be to add or substitute a new claim, but only if the new claim arises out of the same facts or substantially the same facts as are already in issue on as a claim in respect of which the party applying for permission has already claimed a remedy in the proceedings.” (a) a party applies to amend their statement of case in one of the ways mentioned in this rule; and (b) a period of limitation has expired under – (i) the Limitation Act 1980; (ii) the Foreign Limitation Periods Act 1984; or (iii) any other enactment which allows such an amendment, or under which such an amendment is allowed.[29]The condition in CPR 17.4(2) reflects sections 35(4) and (5)(a) of the Limitation Act 1980.

The 4-stage test applicable to CPR 17.4

[30]It was common ground that, when considering whether to permit an amendment to add or substitute a new claim under CPR 17.4, there are four stages to follow, as set out by the Court of Appeal in Ballinger v Mercer Limited [2014] EWCA Civ 996 and again in Mulalley & Co Ltd v Martlet Homes Ltd [2022] EWCA Civ 32, per Coulson LJ at [38]:
“i) Is it reasonably arguable that the opposed amendments are outside the applicable limitation period? ii) Did the proposed amendments seek to add or substitute a new cause of action? iii) Does the new cause of action arise out of the same or substantially the same facts as are already in issue in the existing claim? iv) Should the Court exercise its discretion to allow the amendment?”
[31]The Claimants accepted that, subject to the approximately 8,630 Claimants already mentioned, the amendments are arguably outside the applicable limitation period.[32]The Claimants also accepted that the amendments seek to add a new causes of action.[33]For reasons that I explain later in this judgment, I would otherwise allow the amendments in the exercise of my discretion.[34]Most of the submissions from both sides therefore were concerned with the third stage of this test.

Do the amendments arise out of the same or substantially the same facts?

[35]I find this question entirely straightforward. The amendments largely if not entirely arise out of the alleged SOx Defect. The fact (if it be a fact) that some vehicles were affected by this defect is not a fact that has previously been in issue.[36]It was not an issue in the PDD trial in Tranche 2. It will not be an issue at the causation and quantum trial in Tranche 3.[37]In argument, Mr Campbell KC pointed to the fact that, in paragraphs 108 and 109 of their Generic Defence, Ford have themselves asserted that the LNT traps not only NOx but also SOx, and that trapped SOx reduces the LNT’s ability to store NOx.[38]However, this is not an issue. In paragraph 49 of their Generic Reply, the Claimants admit paragraphs 108 and 109, at least at a high level. Paragraph 49 goes on to aver that the concentration of SOx is extremely small and a vehicle might be driven hundreds of miles before it affects performance, but this does not put paragraphs 108 and 109 of the Generic Defence in issue.[39]More to the point, none of this really resembles the case that the Claimants now wish to bring, or the controversial facts that the proposed amendments seek to assert. As the statements of case currently stand, there is no suggestion that any Ford vehicles are subject to a SOx Defect. Specifically, the effect over time of SOx on the LNTs of the relevant vehicles is not currently alleged to be a defect.[40]I therefore accept Ford’s case that the amendments cannot be allowed under CPR 17.4 – subject to the approximately 8,630 Claimants.

The Mastercard approach

[41]Miss Nolten KC said that it followed that I must dismiss the Claimants’ application. However, the Claimants had a fall-back position, which was that I should grant permission to amend on terms that the new claims in the amendments are brought only on the date of the application to amend, i.e., 10 April 2026.[42]This is often referred to as the Mastercard approach, after the decision of Field J in WM Morrison Supermarkets plc v Mastercard Inc [2013] EWHC 3271 (Comm) and that of the Court of Appeal in Mastercard Inc v Deutsche Bahn AG [2017] EWCA Civ 272, per Sales LJ at [4]. In both those cases, such an approach was implemented with the agreement of both parties, albeit the precise formulation used was different.(1) In WM Morrison Supermarkets plc v Mastercard Inc, the amendment was allowed on terms that it must be expressed to be limited to claims that arose within the last six years (contrary to the terms of the amendment as originally proposed). Field J accepted this as a sensible approach, to avoid the claimant having to issue a separate claim and have it consolidated.(2) In Mastercard Inc v Deutsche Bahn AG, the amendment was allowed on terms that it only related back to the date of service of the application to amend. It is this form of Mastercard order that Mr Campbell KC suggests I should make. See also Advanced Control Systems, Inc v Efacec Engenharia e Sistemas S.A. [2021] EWHC 914 (TCC), where the order was that the amendments were to take effect from the date of the application to amend.[43]Miss Nolten KC accepted that the Mastercard approach can be adopted with the agreement of the parties. However, she submitted that the court has no power to follow this approach where one of the parties objects. She said that the court’s power to permit an amendment which introduces a new claim, after the limitation period has expired, is limited by section 35 of the Limitation Act 1980 to the circumstances set out in that provision; and that, having decided that the Claimants’ application does not fall within CPR 17.4(2) (because it does not arise out of the same or substantially the same facts), the application must be dismissed.[44]The question whether the Mastercard approach can only be adopted with the parties’ agreement has been considered at first instance in Advanced Control Systems, Inc v Efacec Engenharia e Sistemas S.A., in DR Jones Yeovil Ltd v Drayton Beaumont Services Ltd [2021] 1 WLR 2659 and by Fancourt J in Duke of Sussex v News Group Newspapers Ltd [2024] EWHC 1208 (Ch).[45]In his judgment in Advanced Control Systems, Mr Ter Haar QC referred to WM Morrison Supermarkets plc v Mastercard Inc and to Mastercard Inc v Deutsche Bahn AG, and also to the comment of Nugee LJ in Libyan Investment Authority v King [2020] EWCA Civ 1690, at [22]. He then said:
“[42] There can be no doubt that if the pleading says in terms that no claim is put forward in respect of a cause of action arising before a stipulated date, the problem under Section 35 of the Act can be avoided. However none of the three cases explains the basis upon which an order of the Court has the effect of avoiding the problem presented by Section 35, but I would infer that it is that the pleading is to be read with the order and therefore as containing an express reservation equivalent to the terms of the order. [43] What is clear is that there is authority in the two cases in the Court of Appeal that an amendment can be allowed on the basis that it does not “relate back” to a date earlier than that fixed by the court. [44] I do not understand the reasoning of the court in any of the three cases to limit the circumstances in which this course can be permitted to cases where there is agreement between the relevant parties: indeed the agreement of the parties could not validate a manner of proceeding if it were prohibited by statute. [45] Nor do I regard the reasoning in any of the three cases to limit the application of the “Mastercard exception” to particular types of claim. [46] Accordingly, I regard it as open to me in principle to permit amendments upon the basis that the Court orders that the doctrine of relation back is limited to a particular date.”
[46]I agree with Mr Ter Haar QC’s point at [44]. The agreement of the parties could not validate a manner of proceeding if it were prohibited by statute. Therefore, the fact that the parties agreed to the Mastercard approach in Mastercard Inc v Deutsche Bahn AG (and in some of the other cases) cannot have been decisive in principle. However, it may well have had a bearing on the exercise of the court’s discretion.[47]In his judgment in DR Jones Yeovil at [55] and [58], HHJ Russen QC referred to and agreed with paragraph [44] of the judgment in Advanced Control Systems. However, he did not entirely accept Mr Ter Haar QC’s view that the Mastercard approach is not limited to particular types of claim (Advanced Control Systems at [45]). He took the view that there are some types of claim where the court should not exercise its discretion in favour of the Mastercard approach:
“[62]. However, in my judgment there is a class of case where the court should not exercise its discretion in a way which side-steps the conventional approach to deciding the limitation point at the amendment stage. This is where the defendant contends it has a reasonably arguable limitation defence to the entirety of the new cause of action sought to be introduced, having regard to the date of its accrual, which cannot be overcome by recourse to CPR 17.4(2). [63]. Both the conventional approach and the Mastercard basis of amendment are aimed at preserving a defendant’s limitation defence. The conventional approach is in my judgment the appropriate one to adopt where the defendant has a serious argument that the whole of the new claim is statute barred. As the relevant works were undertaken in 2010 and 2011, that is DBS’s position on the present application.”
[48]Any attempt by a judge to set out rigid criteria for the exercise of a discretionary power is fraught with difficulty, because it so often subsequently becomes apparent that future cases may throw up distinct circumstances that are relevant to the exercise of the discretion, which were not previously foreseen. I agree with HHJ Russen QC that a case where it is reasonably arguable that all the new causes of action for which amendments are sought are entirely time-barred is likely to be one where the court will be reluctant to adopt the Mastercard approach. However, I am not convinced that it is helpful to characterise such a case as falling into a type or category, such that it can only be proper to exercise the discretion in one way – viz., by following the conventional approach, and requiring the claimant to bring the new causes of action in fresh proceedings, by issuing a new claim form.[49]In his judgment in Duke of Sussex v News Group Newspapers Ltd, Fancourt J confirmed that the Mastercard approach can be adopted even where the parties do not agree, but did not accept HHJ Russen QC’s view that the exercise of the discretion must depend on what ‘type’ the case falls into. He referred to Advanced Control Systems and said:
“[85] Does the court have power to make that order, if one of the parties does not agree to it? [86] Literally, s.35 and rule 17.4 do not permit such an approach. I have considered whether to conclude, as Judge Russen QC did, that the procedure approved by the Court of Appeal should only be exercised in a true Mastercard case (as a means of defining the non-barred claims that can be added by amendment), and not where the new claims would remain subject to limitation defences. I think that may be too narrow an approach. [87] Where an ACS order is made, the purpose underlying s.35 can be achieved, in that the defendant is not deprived of its ability to rely on limitation as fully as if a new claim form had been issued, but the determination of that issue is deferred. S.35 itself is concerned only with preserving the ability of a defendant to rely on a limitation defence; it is not concerned with protecting the parties from having to investigate the facts relating to the new claim, as they may have to do to some extent if a new claim form is issued instead. On the other hand, the issue of a new claim would provide the defendant with the opportunity to seek to strike it out summarily on limitation grounds, or have a trial of a preliminary issue, without the need to prepare for a full trial on the merits. Early determination of a limitation issue is usually desirable because, if the defence succeeds, it saves the parties from the costs of investigating the merits of a stale claim. [88] It therefore seems to me that the court ought to have power to permit an amendment in ACS form where (but only where) that is just and convenient, even if a relevant party does not consent, because it gives effect to the purpose of s.35 and may be more convenient than requiring a new claim to be issued. Mr Hudson did not argue that the Court could not do it, only that it should not do so on the facts of this case. It is, in my view, nevertheless a power that should be exercised with caution, given its potential to subvert the purpose underlying the Limitation Act. [89] The discretion to permit an amendment in ACS form must be exercised with regard to any prejudice likely to be caused to the defendant, the extent to which in a particular case the purposes of the Limitation Act would be undermined by it, and the consequences for the future management of the trial, both as regards the existing claims and the new claims. If the defendant might be prejudiced by such a course, as compared with its position if a new claim has to be issued, or if it will encumber or possibly delay the trial or add to the burdens of case management, it is unlikely to be appropriate to make such an order. Whether it is appropriate to make an ACS order is likely to depend on the stage that the unamended proceedings have reached, when the trial is due, the nature of the issues for trial as matters stand, the impact of the new limitation issues on the trial, including what further disclosure or evidence might be required, and whether the respondent has a strong case for summary (or prior) determination of the limitation issue. [90] If, having considered those matters, it is more convenient to deal with a limitation issue within the existing proceedings, the court can make an ACS-type order, even if one party unreasonably objects.”
[50]Miss Nolten KC submitted that Fancourt J’s approach at [88] was unprincipled, in that he was effectively saying that the court ought to have the power to make an order based on the Mastercard approach, ergo such a power must exist; despite having acknowledged at [86] that this is not permitted.[51]At [87], Fancourt J rightly identified the statutory purpose behind section 35 as being to ensure that a defendant is not deprived of its ability to rely on limitation as fully as if a new claim form had been issued. This is, indeed, apparent from the judgment in Mastercard Inc v Deutsche Bahn AG, at [35] and [36], where Sales LJ referred to a limitation defence being circumvented by relation back, and the need for restrictions on the circumstances where this can arise (i.e., as per section 35(5)(a) of the Limitation Act 1980, and CPR 17.4(2)).[52]The Mastercard approach, if adopted with care, can be implemented so as not to circumvent any actual or arguable limitation defence. It therefore does not offend the statutory purpose, which is the point made by Fancourt J in Duke of Sussex at [87].[53]I would go further, by reference to the words of the statute. The provision which prohibits allowing new claims by amendment after expiry of a limitation period is section 35(3). As I have noted above, this applies to new claims “within subsection (1)(b) above”. It therefore applies to a new claim which (per section 35(1)) will, for the purposes of the Act, be deemed to have been commenced on the same date as the original action. However, the Mastercard approach means that the new claim will not be deemed to have been commenced on the same date as the original action, for limitation purposes. It therefore will not be a claim that falls within section 35(1)(b).[54]I therefore conclude that the court can, in principle, allow new claims on the basis of the Mastercard approach, even where the parties do not agree. However, whether the court should do so is a matter of discretion. I agree with Fancourt J that the discretion must be exercised with caution.

Discretion

[55]A key issue in the context of discretion is whether the Mastercard approach might cause prejudice to Ford. Miss Nolten KC submitted that allowing the amendments would require a fresh investigation into all the new issues generated by the amendments, above all in relation to the SOx Defect, including substantial disclosure and further factual and expert evidence.[56]I accept that the new allegations will require a fresh investigation. However, this will be so no matter whether they are brought as amendments in the existing proceedings or in the context of new proceedings. In some cases, refusing the amendment will mean that the allegations are not pursued – generally, because of the claimant’s difficulties in relation to the limitation defence. Here, however, that is not the case, because of the Claimants’ case as to deliberate concealment. I therefore do not accept that allowing the amendments on the basis of the Mastercard approach will cause prejudice to Ford.[57]Miss Nolten KC also submitted that the GLO that covers these proceedings was made on the basis that the essential complaints related to PDDs. She suggested that it would be wrong in principle for the scope of the group proceedings to be expanded by reference to the alleged SOx Defect without the normal processes having been followed. The Claimants, and the lawyers leading the proceedings, should advertise for claimants, assemble the class, obtain funding and then apply for a separate GLO.[58]This would be time-consuming and costly for the Claimants. It would also add to the work-load of the court, by which I mean primarily the work-load of court staff, although it would also lead to increased work for the bench. Furthermore, the object of appointing designated judges to manage the proceedings was that expertise and familiarity would be acquired by the designated judges. The course proposed by Miss Nolten KC therefore would cause significant inefficiencies.[59]Furthermore, it is obvious, and Miss Nolten KC came very close to admitting, that Ford’s main interest in arguing for additional procedural delay, complexity and expense is the possibility that this would lead to some individual Claimants losing heart and deciding not to bring fresh claims. This runs entirely counter to the overriding objective, which stresses that the court must endeavour to make litigation simple, efficient and quick. Any course that would deter individual litigants from pursuing what may be valid claims is one that the court should be wary of following.[60]Conversely, there are two factors that support allowing the amendments on the Mastercard approach.[61]The first is the presence of a significant number of Claimants – approximately 8,630 – whose claims are not time-barred. Thus, this is not a case where it can be said that (per HHJ Russen QC in DR Jones Yeovil) there is no arguable limitation defence to some causes of action. For the great majority of the Claimants, all the new causes of action are arguably time-barred. However, there is a significant minority in relation to whom no claims are arguably time-barred. It is not attractive to require those Claimants to commence fresh proceedings, despite there being no limitation defence to their claims. Nor is it attractive (or practical) to allow those Claimants to amend but refuse permission to amend to the other Claimants.[62]The second is that the proceedings have already made significant progress, and this is in reality a good juncture for the addition of new allegations. Tranche 2 having concluded, the parties are now preparing busily for Tranche 3. It has always been anticipated that there would have to be at least one further Tranche, to resolve additional issues. The case management hearing at which this will be considered is due to take place in approximately six weeks. It will be convenient to take advantage of the knowledge that the parties and the court have acquired to date, and to fold the new allegations into the existing proceedings. This presents the best possible opportunity to manage the new allegations efficiently and in a way that will fit in with, rather than obstructing, the proceedings as a whole.

Delay

[63]Ford suggested that the Claimants have delayed in bringing forward the new allegations, and that this should weigh heavily against the Claimants in the exercise of the court’s discretion.[64]Ford accepts that the Claimants had no reason to know the facts relied on as justifying the allegations in relation to the SOx Defect, until 2024. They say that documents disclosed in July 2024 (which related to a particular update) were sufficient to put the Claimants on notice of the relevant facts, in particular in relation the effect of SOx on the LNTs.[65]The Claimants say that the materials disclosed in July 2024 and November/December 2024 were insufficient to put them on notice, although they accept that more substantial disclosure in relation to the SOx Updates was given in April and May 2025. They also say that it is unrealistic to criticise them for taking some time to formulate the amendments. Most of the allegations for which permission is sought were captured in an earlier draft, in relation to which an application notice was issued in July 2025. Since then, the parties had for a long time were essentially pre-occupied with the trial of the PDD liability issues in Tranche 2. Once that was concluded, the further draft of the amendments (which benefits from additional information acquired in the course of Tranche 2) followed relatively soon.[66]Delay and lateness are relative concepts. They have to be considered in the context of the proceedings. In particular, it is necessary to consider what effect any delay may have had in causing disruption.[67]I am sceptical that the materials disclosed in July 2024 were sufficient to have permitted the Claimants to produce such a draft; but even if they were sufficient to put the Claimants on enquiry, the additional and more substantial materials disclosed in December 2024 would have required the Claimants largely to start again. I do not find it at all surprising that the Claimants then took several months to produce a draft of the amendments, which they first did in July 2025.[68]Thereafter, it is apparent that neither side really had much appetite to become engrossed in dealing with the amendments, when they were preparing for Tranche 2. I find it completely understandable that the Claimants waited until April 2026 before finalising a further version of the amendments and issuing the further application notice which is now before me. Rather than this delay causing disruption, if the Claimants had not delayed, Ford would have complained about the disruption to their conduct of Tranche 2.[69]I therefore reject Ford’s points on delay.

Authority

[70]Ford’s final objection is that they say that the Claimants’ solicitors do not have, or may not have, authority to bring the new claims that arise from the amendments.[71]Ford have no positive evidence to this effect. On the contrary, Pogust Goodhead have confirmed in correspondence that there is such authority, and further confirmation has been given by Mr Lewis, in his second witness statement. This must be sufficient to satisfy the court, not least because the burden of proof is on Ford, not on the Claimants: Zoya Ltd v Ahmed [2016] EWHC 1981 (Ch), per Trower J at [62], [67], [71].

Conclusion

[72]I will allow the Claimants to amend their case in accordance with the draft Generic Particulars of Claim provided to the court, on the basis of the Mastercard approach. The order granting permission therefore will stipulate that the new claims in the amendments are brought only on 10 April 2026.