Claimant alleging breach of contract by insurer refusing to honour claim for allegedly stolen vehicle ; Insurer purporting  to avoid liability for misrepresentation and material non - disclosure and/ or breach of warranty in declaration on proposal form; whether materiality is relevant where the defence is breach of warranty in proposal form; application of the principle enunciated in Dawsons v Bonnin.

Action for Libel; whether words libelous on their face or by innuendo;

whether if libelous, defendant may avail itself of defence of Qualified

Privilege as extended by Reynolds v Times Newspapers Ltd;

whether apology made fulfils the terms of section 2 of the Libel and

Slander Act; whether Exemplary or Aggravated Damages appropriate

in this case; whether damages for libel may be updated as in the case

of damages for personal injuries; quantum of damages.