In Axa Insurance UK Plc v Financial Claims Solutions Ltd & Ors [2018] EWCA Civ 1330 the Court of Appeal held that an insurance company was entitled to exemplary damages against parties who had attempted to defraud it.
"the present case ... is a paradigm case for the award of exemplary damages. ...
Good – I’m pleased to see the insurers fighting back for once, though I doubt they’ll ever see any of the exemplary damages awards.