Insurance (motor) – Negligence – Damages for hiring of replacement vehicle pending repairs to claimant’s vehicle – Defendant offering claimant replacement vehicle – Claimant refusing offer – Whether claimant failed to mitigate loss.

Insurance (fire) – Assured using false invoice to obtain funding from finance company, secured on machinery – Machinery damaged by fire – Assured using invoice to assist in claim – Whether false invoice used for finance was a material fact – Moral hazard – Fraudulent claim – Use of fraudulent means or devices.

Insurance – Arbitration – Anti-suit injunction – Policy governed by law of Brazil and subject to exclusive Brazilian jurisdiction – Mediation and arbitration clauses – Law applicable to arbitration clause – Whether mediation a condition precedent to arbitration – Scope of arbitration clause – Whether arbitration clause prevailed over jurisdiction clause.