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07 August 2026 / Ceri Morgan
Issue: 8173 / Categories: Opinion , Consumer , Collective action
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All aboard the omnibus claim form?

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© Getty images
Could omnibus claim forms become the new vehicle for group litigation? Ceri Morgan assesses the impact of Black Horse Ltd v Angel

In a significant decision for UK class action litigation, the Court of Appeal has given the green light for some 5,800 motor finance commission claims to be brought together using omnibus claim forms in Black Horse Ltd v Angel [2026] EWCA Civ 831. The judgment endorses a procedural mechanism, which may be easier and cheaper for multi-party claimants to use than traditional methods (such as group litigation orders), impacting the profile of not only motor finance litigation, but other large-scale group actions.

Background

The claims are brought by more than 5,000 individual consumers who purchased motor vehicles funded by a credit agreement entered into with one of eight motor finance providers (the defendants). It is alleged that, without the claimants’ knowledge, the defendants and the relevant car dealers operated discretionary commission arrangements. Central to the claims is the allegation that the defendants failed to disclose the existence/terms of the commission arrangements to the claimants adequately or

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