Civil Law and Aircraft Leasing Portfolio Default Litigation in Europe

1. Introduction

Aircraft leasing portfolio default litigation arises when an airline, operator, sub-lessee, or related group defaults under several aircraft or engine leases forming part of one leasing portfolio.

A typical dispute may involve:

Multiple aircraft leases → missed rentals → Events of Default → cross-default → termination → repossession/redelivery → damages → insurance/security claims → insolvency → enforcement

Aircraft-leasing litigation is particularly complex because the aircraft may be physically located in one country, the lessor in another, the lease governed by English or another national law, financing governed by a different law, and insolvency proceedings opened in yet another jurisdiction.

There is no single European civil-law regime specifically governing all aircraft portfolio defaults. Instead, disputes are governed by a combination of:

national contract and property law;

EU jurisdiction rules;

EU insolvency law;

aviation regulations;

Cape Town Convention/International Registry rules where applicable;

contractual governing-law and jurisdiction clauses;

guarantees, letters of credit and security arrangements;

insurance law;

sanctions law; and

procedural rules concerning recognition and enforcement.

Recent litigation illustrates how these issues interact. In CIT Group Finance (Ireland) Unlimited Company v SpiceJet Ltd [2026] EWHC 1277 (Comm), the English Commercial Court dealt with unpaid aircraft lease rentals, early termination, redelivery condition, repossession expenses and contractual damages. (BAILII)

2. Meaning of Aircraft Leasing Portfolio Default

An aircraft leasing portfolio may contain:

several aircraft;

aircraft engines;

spare engines;

replacement parts;

multiple operating leases;

finance leases;

subleases;

guarantees;

security deposits;

letters of credit;

maintenance reserves;

insurance arrangements; and

cross-default provisions.

A portfolio default occurs when financial or contractual failure affects more than one transaction.

Example

Suppose Airline A leases:

Aircraft 1 from Lessor X;

Aircraft 2 from Lessor X;

Aircraft 3 from Lessor Y;

Aircraft 4 from Lessor Z.

The leases contain cross-default clauses.

Airline A stops paying rent on Aircraft 1.

The consequences may be:

Aircraft 1 payment default → Event of Default → cross-default under Aircraft 2/3/4 agreements → termination rights → repossession → damages claims

The important question is whether the individual contracts legally permit this chain reaction.

3. Main Legal Issues

4. Contractual Default Is the Starting Point

Aircraft leases are highly detailed commercial contracts.

Common Events of Default include:

failure to pay rent;

failure to maintain insurance;

failure to maintain the aircraft;

breach of financial covenants;

insolvency;

unauthorized subleasing;

failure to comply with registration requirements;

loss of required licences;

breach of sanctions provisions;

cross-default under another transaction.

The lessor generally must establish:

Contract + obligation + breach + valid Event of Default + contractual consequence.

This is important because a court does not ordinarily treat financial difficulty itself as equivalent to legal default.

5. Cross-Default in a Portfolio

Cross-default provisions are particularly important in portfolio litigation.

Example

Lease A:

Airline fails to pay €2 million.

Lease B provides:

Any default under another material financing or leasing arrangement constitutes an Event of Default.

The lessor may therefore argue:

Default A → Cross-default B → termination B

But the exact wording matters.

Courts examine:

what constitutes the underlying default;

whether notice/cure periods have expired;

whether the other agreement qualifies;

materiality requirements;

whether the clause requires acceleration or termination;

whether the relevant default was actually established; and

whether the lessor complied with contractual notice requirements.

6. Repossession and Redelivery

Aircraft leasing disputes frequently distinguish between:

Redelivery

The lessee voluntarily returns the aircraft in accordance with the lease.

Repossession

The lessee fails to return it, and the lessor exercises its contractual rights to recover possession.

This distinction can affect:

insurance;

costs;

liability;

damages;

maintenance obligations;

storage;

ferrying;

legal expenses.

In AerCap Ireland Ltd v AIG Europe SA [2025] EWHC 1430 (Comm), the English Commercial Court considered the distinction between redelivery and repossession and the meaning of insurance wording concerning aircraft being “in the course of repossession.” (BAILII)

7. Damages Following Aircraft Lease Default

A lessor may potentially claim:

A. Unpaid rent

Rent accrued before termination.

B. Default interest

Interest payable under the lease.

C. Repossession costs

Such as:

legal expenses;

aircraft recovery;

ferrying;

storage;

inspection.

D. Restoration costs

Costs of returning the aircraft to contractual redelivery condition.

E. Maintenance-related amounts

Including unpaid maintenance reserves or restoration expenses.

F. Lost rentals

Depending on the lease and applicable law.

G. Diminution in value

Where the aircraft's value has been affected.

H. Other contractual indemnities

Subject to contractual wording and applicable law.

The 2026 CIT v SpiceJet judgment is particularly useful because the lease expressly provided remedies following an Event of Default, including unpaid amounts, possession-recovery costs, restoration costs, storage, insurance and enforcement expenses. (BAILII)

8. Case Law

Case 1 — CIT Group Finance (Ireland) Unlimited Company v SpiceJet Ltd [2026] EWHC 1277 (Comm)

Facts

CIT was the lessor of Boeing 737-8MAX aircraft leased to SpiceJet.

SpiceJet failed to pay various rent and supplemental-rent amounts. Default notices were issued, and the parties subsequently entered into early termination agreements.

The aircraft were eventually repossessed.

CIT claimed, among other things:

unpaid rent;

supplemental rent;

default interest;

repossession costs;

restoration costs;

replacement-engine costs;

reconfiguration costs;

insurance costs; and

legal expenses. (BAILII)

Principle

The court held that the contractual mechanism permitted CIT, following breach of the early termination arrangements, to revert to remedies available under the original leases.

The case demonstrates that an aircraft-leasing settlement or early-termination agreement does not necessarily extinguish pre-existing contractual remedies.

Importance

This is one of the most directly relevant recent authorities for portfolio-default litigation.

Exam point:

Default + contractual remedies + defective redelivery = potentially substantial lessor claim.

9. Case 2 — FW Aviation (Holdings) 1 Ltd v VietJet Aviation Joint Stock Company [2024] EWHC 1823 (Comm)

This dispute concerned four Airbus A321 aircraft leased under Japanese Operating Lease with Call Option arrangements.

The transactions involved financing by banks and security interests connected with the aircraft and leases.

Following COVID-related financial difficulties, VietJet defaulted on rental payments. The financing positions were subsequently transferred, and the new claimant sought to exercise alleged rights to:

terminate leases;

demand return of aircraft;

recover debts;

claim damages; and

enforce indemnities. (BAILII)

Legal significance

The case illustrates that aircraft leasing can involve three overlapping contractual layers:

Lease + financing + security

Therefore, a default may create disputes not merely between lessor and airline but also involving:

financiers;

assignees;

security holders;

sub-lessors;

guarantors.

Portfolio relevance

Where a portfolio has been financed through securitisation or assignment, the identity of the person entitled to enforce the lease becomes a major litigation issue.

10. Case 3 — TWC Aviation Capital Ltd v SpiceJet Ltd [2024] EWHC 721 (Comm)

TWC leased aircraft and engines to SpiceJet.

SpiceJet experienced serious financial difficulties and failed to make agreed payments despite previous restructuring/addenda to the leasing arrangements.

TWC relied upon the resulting defaults and sought termination and redelivery. (BAILII)

Legal significance

The case demonstrates the importance of:

amended payment arrangements;

payment restructuring;

continuing defaults;

termination rights; and

contractual extension provisions.

A lessee cannot necessarily rely on previous concessions or restructuring arrangements indefinitely if the revised payment obligations themselves are subsequently breached.

Portfolio lesson

A lessor should maintain a precise chronology:

Original lease → amendment → payment concession → revised payment date → missed payment → notice → cure period → termination.

This chronology can determine whether the termination was valid.

11. Case 4 — Peregrine Aviation Bravo Ltd v Laudamotion GmbH & Ryanair Holdings PLC

This litigation concerned several aircraft leases during the COVID-19 crisis.

The airline indicated that it would not accept delivery of four aircraft. The lessors sought to exercise termination rights and relied on cross-default provisions concerning the different leases. Claims included the net present value of rentals. (Courts and Tribunals Judiciary)

Important issues

The case involved:

contractual termination;

threat to suspend payment of debts;

cross-default;

failure to take delivery;

damages;

mitigation.

Legal principle

An aircraft lessor must establish the contractual foundation for termination and damages.

A lessor cannot simply rely on a different ground for termination later without considering whether the contractual termination notice actually relied upon that ground.

Portfolio significance

It demonstrates why cross-default clauses must be drafted and exercised carefully.

12. Case 5 — UniCredit Bank GmbH v Constitution Aircraft Leasing (Ireland) 3 Ltd [2026] UKSC 10

This is an important recent Supreme Court authority concerning aircraft leasing, letters of credit and sanctions.

Russian airlines failed to comply with their aircraft lease obligations following the invasion of Ukraine.

Events of Default occurred.

The lessors terminated the leases and made demands under letters of credit. Several aircraft remained in Russia, while others were repossessed. (BAILII)

Legal significance

The case demonstrates the interaction between:

aircraft lease defaults;

letters of credit;

sanctions;

termination;

payment obligations;

aircraft located in Russia.

Portfolio lesson

A lessor's recovery strategy may involve separate enforcement tracks:

Aircraft claim + lease claim + guarantee/LC claim + insurance claim

The failure to recover the physical aircraft does not necessarily eliminate claims against financial security.

13. Case 6 — Celestial Aviation Services Ltd v UniCredit Bank GmbH [2024] EWCA Civ 628

Aircraft leases were terminated following defaults during the Russia-related sanctions crisis.

Letters of credit were called, with claims involving tens of millions of US dollars.

The bank argued that sanctions prevented or affected payment. Relevant licences were subsequently obtained and payments were made. (BAILII)

Legal significance

This authority demonstrates that aircraft-leasing default litigation can move beyond the underlying lease.

The litigation may involve:

Lease default → termination → LC demand → sanctions defence → regulatory licence → payment

Portfolio importance

Financial security can therefore become a central part of recovery when physical repossession is difficult.

14. Case 7 — WWTAI Airopco II DAC v Global Aerospace Underwriting Managers (Europe) SAS [2025] IEHC 452

This Irish High Court litigation concerned leased aircraft and engines located in Russia after the invasion of Ukraine.

Default and cancellation notices were issued and the lessors demanded return of the aircraft and engines.

The litigation also concerned insurance arrangements and the inability to recover the aircraft. (BAILII)

Importance

The case illustrates the interaction between:

lease termination;

repossession;

aircraft insurance;

sanctions;

physical possession;

loss of aircraft.

It is especially relevant where a portfolio default results in non-return rather than ordinary financial default.

15. Case 8 — AerCap Ireland Ltd v AIG Europe SA [2025] EWHC 1430 (Comm)

This case involved insurance claims relating to aircraft leased to Russian airlines.

The court considered whether aircraft remained in the lessees' possession and whether they could be considered to be “in the course of repossession.”

The court emphasised the distinction between:

termination/demand for return

and

actual repossession activity. (BAILII)

Importance

For aircraft portfolios, insurance wording can become crucial after default.

The lessor may argue:

“The aircraft have been lost because the lessee refuses to return them.”

The insurer may respond:

“The policy only covers particular circumstances of possession or repossession.”

The precise policy wording therefore becomes decisive.

16. Olympic Council of Asia v Novans Jets LLP [2022] EWHC 88 (Comm)

This dispute involved termination of an aircraft lease-to-purchase agreement following non-payment of an invoice.

The court considered the contractual termination dispute and the underlying payment issue. (BAILII)

Principle

Aircraft leasing litigation is not limited to large airline defaults.

Even a relatively specific payment dispute can determine whether termination rights have arisen.

Lesson

The lessor should prove:

contractual obligation;

amount due;

due date;

non-payment;

contractual default;

notice;

termination;

resulting remedy.

17. Insolvency and Aircraft Portfolio Defaults

Aircraft portfolios become especially complicated when the airline enters insolvency proceedings.

The EU Insolvency Regulation, Regulation (EU) 2015/848, provides rules concerning:

jurisdiction for insolvency proceedings;

applicable law;

recognition;

effects of insolvency;

creditors' rights.

Article 7 generally connects the effects of insolvency proceedings with the law of the State where proceedings are opened, subject to the Regulation's exceptions. (EUR-Lex)

But aircraft receive special treatment.

Aircraft registration

Article 14 provides that the effects of insolvency proceedings on rights concerning an aircraft subject to registration in a public register are determined by the law of the Member State under whose authority that register is kept. (EUR-Lex)

This creates an important distinction between:

contractual lease rights

and

proprietary/registration rights concerning the aircraft.

18. Why Aircraft Location Matters

Suppose:

lessor = Ireland;

airline = France;

lease law = English law;

aircraft registration = Ireland;

aircraft physically located = Germany;

insolvency = France.

A default dispute could potentially involve:

French insolvency law + English contractual law + Irish registration law + German enforcement law + EU jurisdiction rules.

Therefore, aircraft leasing litigation is inherently multi-jurisdictional.

19. Cape Town Convention

For qualifying aircraft transactions in states applying the relevant Convention and Aircraft Protocol framework, the Cape Town Convention can substantially strengthen creditor rights.

It deals with concepts including:

international interests;

registration;

priority;

default remedies;

possession;

sale;

leasing interests;

insolvency-related remedies.

The practical significance is that the lessor's contractual claim can be supported by an internationally recognised security architecture.

Exam formula

LEASE + INTERNATIONAL INTEREST + REGISTRATION + DEFAULT REMEDY = ENHANCED RECOVERY FRAMEWORK

But the exact remedies depend upon:

the Convention;

Aircraft Protocol;

relevant declarations;

national implementing legislation;

transaction documentation.

20. Portfolio-Level Security

Aircraft leasing portfolios commonly use several layers of protection.

1. Security deposit

Cash held by the lessor.

2. Letter of credit

Independent financial security from a bank.

3. Parent guarantee

A group company guarantees the airline's obligations.

4. Maintenance reserves

Payments intended to fund future maintenance.

5. Insurance

Protection against specified aviation risks.

6. Mortgage/security interest

Security over the aircraft or related interests.

7. Assignment

Assignment of:

lease rights;

insurance proceeds;

receivables;

claims.

Therefore:

Portfolio Default ≠ Single Debt Claim

It may produce a network of interconnected claims.

21. Cross-Default and Acceleration

A portfolio lease may provide:

“An Event of Default under Lease A constitutes an Event of Default under Lease B.”

The lessor must still analyse whether:

the clause is valid;

the underlying default occurred;

notice was required;

a cure period expired;

the cross-default threshold was met;

the relevant leases were properly connected.

Example

Airline owes €500,000 under Lease A.

Lease B has a cross-default threshold of €1 million.

If Lease A's default is only €500,000, Lease B's cross-default clause may not automatically activate.

Thus:

Cross-default wording must be interpreted precisely.

22. Redelivery Condition

Aircraft leases commonly contain detailed redelivery conditions.

These may cover:

airworthiness;

maintenance status;

engine condition;

component life;

records;

technical documents;

paint;

configuration;

modifications;

regulatory compliance;

storage condition.

A dispute may therefore arise even after the aircraft has physically been returned.

Example

Aircraft returned:

physically complete but missing technical records and requiring €3 million of maintenance.

The lessor may claim restoration costs.

The CIT v SpiceJet litigation demonstrates how contractual redelivery conditions can generate substantial post-termination claims. (BAILII)

23. Mitigation of Damages

A lessor generally cannot assume that every loss following default is automatically recoverable.

The court may examine:

whether the aircraft could be re-leased;

whether it could be sold;

whether replacement leasing was commercially reasonable;

whether storage costs were reasonable;

whether restoration costs were necessary;

whether the lessor acted reasonably after termination.

This is particularly important in portfolio litigation because the lessor may have dozens or hundreds of aircraft and must demonstrate how individual losses were calculated.

24. Portfolio Valuation Problems

Large aircraft-default litigation may involve sophisticated valuation evidence.

The court may have to determine:

Aircraft value at default

versus

Aircraft value after recovery

versus

Expected lease revenue

versus

Replacement lease revenue

versus

Maintenance/restoration cost

versus

Discounted future cash flow.

Thus:

Damages = Contractual Debt + Recoverable Costs + Proven Loss − Avoided/Mitigated Loss

subject to the governing law and contractual limitations.

25. Insurance Claims

Insurance may cover different risks:

hull loss;

war risks;

political risks;

liability;

repossession-related risks;

contingent risks.

But insurance does not automatically compensate every contractual default.

The policy wording must be examined.

AerCap v AIG demonstrates how intensely courts may analyse the exact meaning of insurance language surrounding possession and repossession. (BAILII)

26. Sanctions and Aircraft Defaults

The Russia-related aircraft litigation shows a particularly important modern problem.

An airline may:

default;

trigger termination;

fail to return aircraft;

become subject to sanctions restrictions;

prevent lessor access;

trigger insurance disputes;

trigger LC/guarantee claims.

The legal analysis therefore becomes:

Default + Termination + Sanctions + Physical Possession + Insurance + Financial Security

The UniCredit and Celestial Aviation litigation demonstrates this interaction particularly clearly. (BAILII)

27. Civil-Law Perspective

Although much aircraft leasing litigation in Europe is governed by English law and heard in the English Commercial Court, the underlying civil-law concepts are also important.

Continental European systems generally analyse:

Good faith

Parties must exercise contractual rights consistently with applicable good-faith standards.

Contractual force

A valid lease normally binds the parties according to its terms.

Proportionality

Certain termination or enforcement mechanisms may be examined under mandatory national principles.

Abuse of rights

A contractual right may in some jurisdictions be restricted where exercised abusively.

Causation

The claimant must establish the causal connection between default and claimed loss.

Damage

Recoverable damages depend upon the governing national law.

Therefore, the same aircraft-default facts can produce different outcomes depending on the applicable national law.

28. Jurisdiction

Aircraft portfolio agreements often contain:

exclusive jurisdiction clauses;

arbitration clauses;

governing-law clauses;

submission to English courts;

New York law;

Irish law;

French law;

Singapore arbitration clauses.

The FWA Aviation v VietJet litigation is particularly instructive on jurisdictional arrangements in aircraft finance leasing.

The case involved English jurisdiction clauses and competing Vietnamese proceedings; the Commercial Court considered whether the relevant parties could rely upon the jurisdiction agreements despite subsequent assignment of interests. (Courts and Tribunals Judiciary)

Principle

Assignment of a leasing interest does not necessarily destroy the contractual jurisdiction arrangement.

29. Assignment of Aircraft-Leasing Portfolios

Aircraft leasing portfolios are frequently sold or transferred.

A portfolio may therefore move:

Original lessor → financing vehicle → investment fund → new lessor

This creates questions about:

assignment;

novation;

standing;

enforcement rights;

jurisdiction clauses;

security;

notices;

transfer restrictions.

The FWA Aviation v VietJet litigation shows how assignment of interests can become central to aircraft-finance litigation. (BAILII)

30. Typical Litigation Structure

A portfolio default lawsuit may proceed through the following stages:

Stage 1 — Default

Airline misses rental payments.

↓

Stage 2 — Notice

Lessor sends Event of Default notice.

↓

Stage 3 — Cure Period

Airline is given contractual opportunity to cure.

↓

Stage 4 — Cross-Default

Other leases may become affected.

↓

Stage 5 — Termination

Lessor terminates relevant leases.

↓

Stage 6 — Repossession

Lessor seeks aircraft return.

↓

Stage 7 — Security

LCs, guarantees and deposits are called.

↓

Stage 8 — Damages

Lessor claims outstanding and consequential contractual losses.

↓

Stage 9 — Insolvency

Airline may enter restructuring or insolvency.

↓

Stage 10 — Enforcement

Judgment/award must be enforced where the aircraft or debtor's assets are located.

31. Direct vs Analogical Authorities

For accuracy, the case law should be classified.

Highly/directly relevant aircraft-leasing authorities

CIT Group Finance v SpiceJet — [2026] EWHC 1277 (Comm)

FW Aviation v VietJet — [2024] EWHC 1823 (Comm)

TWC Aviation Capital v SpiceJet — [2024] EWHC 721 (Comm)

Peregrine Aviation Bravo v Laudamotion/Ryanair

UniCredit Bank v Constitution Aircraft Leasing — [2026] UKSC 10

Celestial Aviation v UniCredit — [2024] EWCA Civ 628

WWTAI Airopco II v Global Aerospace — [2025] IEHC 452

AerCap Ireland v AIG Europe — [2025] EWHC 1430 (Comm)

These are much more useful for aircraft leasing than general contract cases.

32. Key Legal Principles from the Cases

33. Hypothetical Example

Suppose EuroAir leases 50 aircraft from three lessors.

It stops paying rent.

First question

Was the rent contractually due?

Second

Was the default cured within the contractual period?

Third

Does the default trigger cross-default provisions?

Fourth

Can the lessors terminate?

Fifth

Can they repossess the aircraft?

Sixth

Where are the aircraft?

Seventh

Are there insolvency proceedings?

Eighth

Can security deposits and LCs be called?

Ninth

What condition are the aircraft in?

Tenth

What damages can actually be proved?

The resulting litigation may involve 50 aircraft but dozens of individual contractual questions.

34. Important Defences for the Airline

A lessee may argue:

1. No valid default

The amount was not due or was incorrectly calculated.

2. Waiver

The lessor previously accepted late payments.

3. Estoppel

The lessor's conduct created a legitimate contractual expectation.

4. Invalid termination notice

The notice did not comply with the lease.

5. Cross-default not triggered

The contractual threshold was not satisfied.

6. Force majeure / illegality

Applicable law may provide relevant relief depending upon the circumstances.

7. Sanctions

Performance may have been legally restricted.

8. Damages excessive

The lessor failed to prove or mitigate losses.

9. Redelivery condition dispute

The aircraft actually complied with the contractual standard.

10. Insolvency protection

Local insolvency law may restrict individual enforcement.

35. Important Defences for the Lessor

The lessor may argue:

payment was unambiguously due;

cure period expired;

prior concessions were expressly limited;

cross-default clause was triggered;

termination complied with the lease;

aircraft were not properly redelivered;

repossession expenses are contractually recoverable;

losses were caused by the lessee's default;

contractual indemnities cover the claimed expenses;

insurance does not eliminate the lessee's contractual liability.

The CIT v SpiceJet judgment is particularly useful for understanding this type of contractual remedy analysis. (BAILII)

36. EU Insolvency Dimension

A major problem arises when an airline becomes insolvent after default.

Regulation 2015/848 generally provides rules for:

jurisdiction;

applicable insolvency law;

recognition;

creditor treatment.

The Regulation specifically protects certain rights in rem and separately addresses rights concerning registered aircraft. (EUR-Lex)

Therefore:

Lease termination ≠ automatic physical recovery

The lessor must also examine:

insolvency stay;

local enforcement law;

proprietary rights;

aircraft registration;

security interests;

applicable international instruments.

37. Core Civil-Law Liability Formula

Aircraft Leasing Default Formula

LEASE OBLIGATION
→ PAYMENT/CONTRACTUAL DEFAULT
→ VALID EVENT OF DEFAULT
→ NOTICE/CURE
→ TERMINATION
→ REPOSSESSION/REDELIVERY
→ DAMAGE
→ CAUSATION
→ MITIGATION
→ RECOVERY

For a portfolio:

INDIVIDUAL DEFAULT
→ CROSS-DEFAULT
→ MULTIPLE LEASE TERMINATIONS
→ PORTFOLIO REPOSSESSION
→ SECURITY ENFORCEMENT
→ INSOLVENCY
→ CROSS-BORDER ENFORCEMENT

38. Ultra-Basic Exam Notes

Remember:

“D-R-T-R-D-S-I”

D = Default

R = Notice/Remedy

T = Termination

R = Repossession/Redelivery

D = Damages

S = Security

I = Insolvency

One-line definition

Aircraft leasing portfolio default litigation is cross-border contractual and civil litigation arising from default across multiple aircraft-leasing transactions, involving termination, repossession, damages, security enforcement, insurance and insolvency.

39. Conclusion

Aircraft leasing portfolio default litigation in Europe is fundamentally a multi-layered contractual and property dispute.

The most important questions are:

Was there a contractual default?

Did the default trigger cross-default rights?

Was termination valid?

Was the aircraft properly redelivered?

Can the lessor repossess it?

What damages are recoverable?

Can guarantees, deposits or letters of credit be enforced?

Does insurance respond?

Has insolvency intervened?

Which country's court and law govern each part of the dispute?

The recent authorities make clear that aircraft leasing litigation is no longer simply a dispute about unpaid rent. CIT v SpiceJet shows the importance of contractual termination and redelivery remedies; FWA Aviation v VietJet demonstrates the financing and jurisdiction dimensions; UniCredit/Constitution and Celestial Aviation/UniCredit show how sanctions and financial security can dominate recovery; and AerCap v AIG and WWTAI demonstrate the separate insurance and repossession dimensions. (BAILII)

Best exam conclusion:

“In European aircraft-leasing portfolio defaults, liability is determined not merely by non-payment but by the combined operation of lease terms, cross-default provisions, valid termination, redelivery and repossession rights, damages and mitigation principles, security and insurance arrangements, insolvency law, aircraft registration, sanctions and cross-border enforcement.”