Sun Life Assurance Company of Canada v. CX
Reinsurance Company
[2003] EWCA Civ 283 Court of Appeal Ð March 2003

Draft treaty wording was agreed between representatives of the parties but was never signed by Sun Life, although the parties agreed that the reinsurance had incepted. Sun Life subsequently issued proceedings seeking to avoid
and/or rescind the treaty for material misrepresentation and non-disclosure. The defendant applied for a stay of proceedings, relying on a clause in the unconcluded treaty wording which provided for arbitration in Chicago.
It was held that whilst the parties' representatives were authorised to agree the original contract for reinsurance, which was partly oral and partly written, they did not have ostensible authority to bind the parties to additional terms unless they were contained in a signed treaty. The arbitration provision was not within such a treaty and was not therefore binding. This was an unusual case as it was agreed between the parties that there was a contract between them, notwithstanding that it had incepted without either a slip or written treaty having ever been signed.