Ralph Morley

Sustained experience in international arbitration includes led and unled representative and advisory work across a range of arbitral rules and sectors, as well as relief in support of arbitration, including anti-suit injunctions, “Vasso” orders and jurisdiction challenges:

• Acting for respondent insurers in a $160m Bermuda Form arbitration.
• Instructed in parallel US$50m LCIA arbitrations concerning a shareholders’ agreement and an asset operations agreement.
• Instructed in a US$90m LCIA arbitration concerning warranties in a share purchase agreement.
• Appearing for the successful claimants in a US$300m business interruption insurance arbitration concerning an offshore oil pipeline, involving detailed consideration of technical questions as to design and engineering of the pipeline and its control system, as well as questions of New York law.
• Appearing for claimants seeking anti-suit relief from an arbitral tribunal in respect of proceedings brought by counterparties to a joint venture in Saudi Arabia, led by Stephen Houseman KC and John Bignall.
• Acting  in ancillary relief matters including disclosure orders, enforcement by committal, anti-suit injunctions, and section 44(2) “Vasso” order applications.
• Section 67, section 68 and section 69 challenges to arbitration awards.
• Advice on emergency injunctive relief.
• Challenge (as sole counsel) to tribunal jurisdiction.
• Ralph is also the author of a series of practice notes on insurance arbitration for Lexis PSL.

Shipping is a core part of Ralph’s practice. His writing on admiralty law has been cited with approval in the Supreme Court in The MSC Flaminia [2025] UKSC 14. Ralph regularly acts in both wet and dry shipping matters, including charterparty disputes, cargo claims, salvage, limitation and collision work. Ralph has acted (in respect of a number of high-profile casualties over recent years. Work highlights include:

• Acting for slot charterers MSC in limitation proceedings concerning The X-Press Pearl [2024] EWHC 3174 (Comm).
• Currently instructed in relation to ownership interests concerning claims in respect of wreck and salvage relating to a high-profile historic casualty.
• Acting as sole counsel representing slot charter interests in limitation proceedings concerning the grounding of the container ship “EVER GIVEN” in the Suez Canal in March 2021.
• Instructed (as junior to John Russell KC) in an LMAA arbitration concerning detention of a bulk carrier in Ukraine.
• Acting (as junior to Michael Holmes KC) in an LMAA arbitration worth in excess of US$10m concerning a containership casualty arising out of dangerous cargo shipped aboard a container vessel.
• Acting (as junior to Robert Bright KC) in a multi-million-dollar arbitration concerning suspected bunker fraud.
• Acting as sole counsel in a range of charterparty and vessel sale/purchase disputes including: unsafe ports; force majeure and frustration, including several cases connected with the outbreak of war in Ukraine; laytime and demurrage; unseaworthiness (including fitness to receive cargo); hatch cover damage; damage to main engines; speed warranties and weather performance; failure to pay hire; wrongful early redelivery; performance and contract options; hold cleaning; and overloading.
• Admiralty advice and representation has included matters relating to: collisions and groundings; salvage and wreck, including proper subjects of wreck, interactions with the Receiver of Wreck, and liability under the Salvage Convention; jurisdiction disputes; vessel arrests; advice on letters of undertaking; general average; advice on the interrelationship between insolvency proceedings against a shipowner in Germany and arrest in the Admiralty Court; advice on the interrelationship of contractual agreements to arbitrate with Admiralty limitation actions.
• Cargo claims, including questions of whether the Hague or Hague-Visby Rules apply, defences under Article IV of the rules and limitation of liability.
• Advice concerning coverage under a fixed premium P&I policy in respect of liabilities arising from a high-profile fatal casualty.
• Advice and drafting (as sole counsel) on appeals from LMAA arbitrations, including simultaneous applications under sections 68 and 69 of the Arbitration Act to challenge the striking-out of an arbitration claim for inordinate delay; a section 67 challenge to an LMAA ruling on jurisdiction; and a section 68 challenge to an arbitrator’s decision on costs under the LMAA small claims procedure.
• Advice on the true construction of a jurisdiction agreement in a letter of undertaking for Pacific islanders seeking redress against a vessel which had collided with their coral atoll.
• Ralph spent three years as a member of Cambridge University Royal Naval Unit, holding the honorary rank of Midshipman in the Royal Naval Reserve and gaining practical experience of navigation and seamanship (including passage planning, pilotage and ship handling).
• Ralph has been published in the Lloyd’s Maritime and Commercial Law Quarterly on the Collision Regulations and is editor of the English Admiralty and Merchant Shipping Law section of the International Maritime and Commercial Law Yearbook.

Ranked in the Legal 500, Ralph’s experience spans a wide range of physical damage, business interruption and liability insurance matters, including Bermuda Form work and complex marine, aviation and engineering casualties, acting for both policyholders and insurers. Highlights include:

• Acting for insurers in a US$160m Bermuda Form dispute.
• Acting for policyholders in a US$120m physical damage and business interruption insurance dispute concerning a chemical plant.
• Acting for insurers defending liability insurance claims brought by owners of nightclubs in the USA alleged to have engaged in discriminatory conduct.
• Acting for insurers AIG as part of the team led by Gavin Kealey KC and Andrew Wales KC in respect of insurance coverage disputes under lessor policies concerning aircraft leased to Russian operators.
• Acting for the successful claimants in a US$300m all risks physical damage and business interruption insurance arbitration concerning an oil pipeline, involving detailed consideration of technical questions as to design and engineering, governed by New York law.
• Acting for claimant insureds in a US$30m claim under a political risk insurance policy brought by owners of a factory complex occupied by rebels in the Syrian Civil War, led by James Brocklebank KC, which also raised questions of reinsurance coverage and broker negligence.
• Advising insureds under a fixed premium marine P&I policy in relation to coverage issues following a high-profile fatal collision.
• Acting (as junior to Michael Holmes KC) for successful insurers in a £3m dispute as to insurers on risk under different policy years for professional indemnity policies issued to a firm of solicitors.
• Advising a firm of accountants on claims for defence costs under a professional indemnity insurance policy.
• Advice on directors’ and officers’ liability insurance policies.
• Advice on business interruption policies.
• Advice to insurers and prospective policyholders as to whether proposed insurance policies cover the risks intended to be insured.
• Ralph is also the author of a series of practice notes on insurance arbitration for Lexis PSL and co-author with Michael Holmes of practice notes on liability insurance.

Ralph’s experience in a wide range of high-value and high-profile commercial litigation has seen him recognised in commercial litigation by the Legal 500 as “a superstar”. Highlights include:

• Libyan Investment Authority v Credit Suisse & Others [2021] EWHC 2684 (Comm): acting for a defendant in a successful jurisdiction challenge to a multi-million-dollar claim alleging bribery, led by Michael Holmes KC.
• Origin Packaging Ltd v Secretary of State for Health and Social Care: Ralph is instructed as junior counsel for DHSC in this £36m contract dispute.
• Carillion plc v KPMG: junior counsel representing KPMG in defence of anticipated claim arising from the insolvency and collapse of the Carillion Group, as well as in related matters. The dispute is currently at the pre-action stage but a large professional negligence claim is anticipated and Ralph is instructed, with other members of 7KBW, on behalf of KPMG to act in its defence. Ralph was part of the 7KBW team which successfully resisted an application for pre-action disclosure [2020] EWHC 1416 (Comm).
• Seahorn SARL v Navios Corporation: acting for the Claimant and Third Party in a dispute over a consultancy agreement, including allegations of breach of fiduciary duty.
• Crumpler v Candey: an appeal concerning how services supplied by a firm of solicitors under a fixed fee agreement are to be valued under section 245 of the Insolvency Act 1986, led by Gavin Kealey KC.
• Cunningham v Ernst & Young & Others [2018] EWHC 3188 (Comm): Ralph represented Ernst & Young in its successful application to strike out a £39m claim alleging conspiracy to defraud and breach of fiduciary duty, led by James Brocklebank KC.
• Acting for parties to shareholder agreements, share sale and purchase agreements, and asset operation agreements.
• Advice and representation challenging jurisdiction in respect of proceedings brought by a company before it was incorporated at Companies House.
• Ralph has experience of a wide range of ancillary proceedings, having acted as sole counsel in applications including anti-suit injunctions, disclosure orders and contempt proceedings.
• Acting (as junior to James Brocklebank KC) for a Nigerian oil services company bringing multi-million dollar claims of breach of contract, breach of duty and dishonest assistance against its bankers.
• Advice to a telecoms network engineering company regarding its liability for claimed indirect losses of £48m to a mobile phone company whose network had suffered an outage.
• Advice on the true construction of standby letters of credit and the demands necessary to trigger them.
• Advice on whether a gambler is owed a duty of care by bookmakers.
• Advice on the true construction of commission agreements.

• Libyan Investment Authority v Credit Suisse & Others [2021] EWHC 2684 (Comm): acting for a defendant in a successful jurisdiction challenge to a multi-million-dollar claim alleging bribery, led by Michael Holmes KC.
• Acting for a consultancy/audit holding company challenging jurisdiction on grounds of forum non conveniens
• Advising on whether the Admiralty Court has jurisdiction in respect of salvage outside UK territorial waters.
• Appearing for claimants seeking anti-suit relief from an arbitral tribunal in respect of proceedings brought by counterparties to a joint venture in Saudi Arabia, led by Stephen Houseman KC and John Bignall.
• Obtaining (as sole counsel) anti-suit injunctive relief on both an interim and a final basis.
• Advice on whether the English Admiralty Court has jurisdiction in respect of damage done by a vessel to a subsea cable located outside British territorial waters but within the United Kingdom’s Exclusive Economic Zone.
• Advice as to whether service of a claim form aboard an aircraft registered in a foreign jurisdiction about to take off from an English airport was service within the jurisdiction.
• Advice on the proper law governing questions of agency.
• Advice on the scope of a letter of undertaking conferring exclusive jurisdiction in respect of a collision claim on a foreign court.
• Advice on whether English or Egyptian law governed an insurance contract.
• Advice on the proper law of a contract for sale of fruit from Egypt for delivery in Rotterdam and Tilbury.

Ralph has experience of a wide range of aviation claims, with a particular focus on aircraft damage claims (include hull loss and damage and engine damage claims) and aircraft chartering/leasing arrangements. Highlights include:

• Acting for insurers AIG as part of the team led by Gavin Kealey KC and Andrew Wales KC in respect of insurance coverage disputes under lessor policies concerning aircraft leased to Russian operators.
• Acting (as sole counsel, against a KC) in a multi-million-pound aircraft damage case in the Technology and Construction Court concerning the total loss of a helicopter.
• Acting as sole counsel in an engine damage claim brought against aircraft maintainers.
• Acting as sole counsel in an aircraft damage claim brought against ground handlers.
• Acting for charterers under an ACMI wet lese agreement.
• Flight delay claims under Regulation 261/04.
• Advice as to whether service of a claim form aboard an aircraft registered in a foreign jurisdiction about to take off from an English airport was service within the jurisdiction.
• Advising sub-lessee of a pair of Airbus airliners as to whether it could obtain emergency injunctive relief from an LCIA arbitral tribunal preventing the head lessor from placing the aircraft under arrest.
• Acting for a major auditor in defence of a multi-million pound claim brought by the liquidators of an insolvent airline.

• Origin Packaging Ltd v Secretary of State for Health and Social Care: Ralph is instructed as junior counsel for DHSC in this £36m public procurement sale of goods contract dispute concerning COVID-19 testing kits.
• Acting for a seller of wheat in an arbitration appeal concerning failure to supply a cargo consequent upon outbreak of war in Ukraine.
• Acting for a purchaser of aviation oil that was unable to take delivery of the goods after the vessel discharging the oil broke free of her moorings and damaged the subsea discharge pipeline.
• Acting for a manufacturer of garments in a dispute with a major fashion brand purchaser.
• Obtaining (as sole counsel) asset disclosure orders against purchasers of commodities in the High Court following default on an arbitration award.
• Advice and drafting in a wide range of sale of goods matters, including steel, oil, coal, fruit, grain and feed, spanning several sets of institutional rules, including via the Bar Pro Bono Unit (now Advocate).
• As pupil to Richard Sarll, Ralph assisted with the successful defence of claims for losses incurred on a hedge taken out against the physical sale of biofuel in Vitol SA v Beta Renowable SA [2017] 2 Lloyd’s Rep 238.

Ralph has been appointed to the Attorney-General’s C Panel and has provided advice across private and public law areas, including contract, maritime law, the international law of the sea, and public law issues in judicial review.

• Origin Packaging Ltd v Secretary of State for Health and Social Care: Ralph is instructed as junior counsel for DHSC in this £36m public procurement contract dispute concerning COVID-19 testing kits.
• Advising an oil exploration company on whether its activities constitute “dealing in land” for the purpose of Seed Enterprise Investment Scheme relief.
• Advising a political consultancy on the registration requirements of the European Commission’s Transparency Register.
• Advising (via the Bar Pro Bono Unit, now Advocate) on the duties owed to leisure users of a reservoir by the water company statutorily responsible for it under the Water Industry Act 1991.

Described as an “accomplished” junior in professional negligence and an “excellent team player”, Ralph has acted in a number of the most complex and high-profile professional negligence cases of recent years, including:

• Carillion plc v KPMG: junior counsel representing KPMG in defence of anticipated claim arising from the insolvency and collapse of the Carillion Group, as well as in related matters. Ralph was instructed, with other members of 7KBW, on behalf of KPMG to act in its defence of this claim, which was successfully settled. Ralph was also part of the 7KBW team which successfully resisted an application for pre-action disclosure [2020] EWHC 1416 (Comm), and also appeared for KPMG in FRC v KPMG, related disciplinary proceedings that were one of The Lawyer’s Top 20 cases for 2022.
• Cunningham v Ernst & Young & Others [2018] EWHC 3188 (Comm): Ralph represented Ernst & Young in its successful application to strike out a £39m claim alleging conspiracy to defraud and breach of fiduciary duty, led by James Brocklebank KC.
• Acting for a major auditor in its defence of a £40m claim brought by liquidators of the audited insurance company.
• Acting for a major auditor in defence of a multi-million pound claim brought by the liquidators of an insolvent airline.