The Angel v Black Horse appeal concerns the procedural handling of mass consumer claims over undisclosed discretionary motor finance commissions. It centers on whether thousands of claimants can use single “omnibus” claim forms against lenders, or if each individual must file a separate form.

High Court Decision (2025)

In March 2025, Mr Justice Ritchie in the High Court overturned a lower court ruling that had ordered the separation of around 5,800 claimants.

The Ruling: He ruled that the “omnibus” claim forms were permissible under Civil Procedure Rule 7.3, as the mass claims could be “conveniently disposed of” in the same proceedings.

The Reasoning: He determined that case-managing generic issues, such as the nature of the broker commission arrangements, is highly beneficial and that previous restrictive interpretations were no longer binding.

Court of Appeal Decision (2026)

Following the High Court’s decision, lenders including Black Horse Limited appealed, seeking to overturn the ruling permitting omnibus claim forms.

The appeal was heard by the Court of Appeal in April 2026, with the judgment eagerly anticipated across the legal, financial and consumer sectors.

The Court has now upheld the High Court’s approach, confirming that, where appropriate, large groups of consumers with common issues can proceed using omnibus claim forms.

The decision provides long-awaited certainty on the procedural framework for one of the UK’s largest consumer redress programmes and represents a significant milestone in the evolution of collective litigation.

For Nera Capital, this is an outcome we have supported from the very beginning.

As one of the earliest funders to recognise the importance of motor finance commission claims, we have consistently believed that consumers should have access to an efficient process that allows common legal issues to be determined together rather than forcing thousands of individuals to navigate identical procedural hurdles independently.

The Court of Appeal’s judgment is not simply a procedural victory. It is a practical solution that benefits every stakeholder involved in the litigation process.

For consumers, it removes unnecessary barriers to accessing justice. Rather than requiring thousands of separate claims to be issued and managed individually, common issues can be determined collectively, reducing delay and improving consistency while allowing consumers to pursue legitimate claims more efficiently.

For law firms, the decision provides a clear procedural pathway for managing large-scale litigation. Firms can devote greater time and resources to advancing the substantive legal issues rather than duplicating administrative processes across thousands of identical cases. This enables legal teams to operate more efficiently while maintaining high standards of client service.

The judgment is equally significant for the courts. Managing thousands of individual claims raising substantially identical issues would place considerable strain on judicial resources and inevitably delay outcomes for all court users. The Court of Appeal’s endorsement of omnibus proceedings supports a more proportionate and efficient use of the court system, allowing common issues to be resolved once rather than repeatedly.

For litigation funders, the decision brings welcome certainty. Efficient case management is fundamental to ensuring that meritorious consumer claims can be funded responsibly and progressed in a timely manner. Greater procedural clarity allows capital to be deployed with increased confidence while supporting access to justice for claimants who may otherwise struggle to pursue complex litigation.

More broadly, the judgment reinforces an important principle within the civil justice system: where thousands of consumers have suffered substantially the same alleged wrongdoing, the legal process should facilitate efficient resolution rather than create unnecessary procedural obstacles.

Motor finance litigation has the potential to become one of the most significant consumer redress programmes seen in the UK. The Court of Appeal’s decision provides the framework needed to ensure these claims can progress fairly, consistently and efficiently.

At Nera Capital, we remain committed to supporting litigation that improves access to justice while delivering practical solutions for consumers, law firms and the wider legal system. The Angel decision is an important milestone, not only for motor finance claims, but for the future of collective consumer redress in England and Wales.

As the litigation progresses towards the determination of the substantive issues, this judgment provides a strong foundation for ensuring that valid consumer claims can be resolved on their merits, rather than becoming mired in unnecessary procedural complexity.