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THE PRINCIPLE OF INDEMNITY IN VALUED

MARINE POLICES
Abstract
A policy of assurance has long been held not be a perfect contract of indemnity. This article
examines this truism in the context of value policies. It can be seen that in this context
imperfection is allowed or even encouraged in the interest of commercial efficacy.

Introduction
The principles of insurance law are an idiosyncratic mixture of contract, law and practice. 1
In the context of marine insurance the contract embodied in the policy of assurance is given
prime of place and is fostered by the Marine Insurance Act 1906 and market practice. The
parties to the policy, the assured and the insured, are given relative freedom to mould the
agreement to their specifications. However, this freedom is not without limitation.
Mandatory rules of public policy come into play. These rules serve to bind this freedom and
bring a sense of homogeny to what could otherwise be an extremely varied tapestry of
contracts. In insurance practice overriding public policy concerns against profiteering
centred on the prohibition of gaming and wagering, unlawful adventure and fraud act to
curb any policy arrangements which are considered too illicit to be allowed.2 In a context
which outright declares that it is governed by the concept of indemnity, public policy
endeavours are servants to this governance creating clashes with the freedom of the parties
to contract. The theorist and practitioner are hence presented with various microcosms in
which this struggle between the contracting parties and public policy is perceptible. In this
article the struggle between the marine insurance laws wider concern of adhering to the
concept of indemnity as based on public policy and the freedom to contract given in the
valued policies will be described and examined. In the context of valued policies, where the
parties agree the indemnity to be paid between themselves credence often lies is favour of
their agreement on this issue. The law seeks to uphold such agreements so long as they do
not infringe any of the public policy motives set out above. In doing so, the principle of

1 F.D. Rose. Marine Insurance Law and Practice, 2nd ed.


2 Ibid.
indemnity takes a backseat in face of the parties freedom of contract. Given the pre-
eminence with which the concept is regarded this result is seemingly surprising. However,
the law of marine insurance has a disposition toward sensibility and in this spirit it is
recognized that the objective to strictly adhere to the indemnity principle is incongruous
with the necessities of practice. The result has been that the assurance policy is regarded as
an imperfect contract of indemnity.3 Nonetheless, this affirmation is not the be all end all for
the concept as it is also simultaneously regarded that the concept of indemnity is and
remains the basis of a policy of assurance throughout. 4

A Marine Policy as a contract of indemnity

The Contract: its nature and purpose


In section 1 of the Marine Insurance Act 1906 we are presented with a definitive statement
detailing the nature of a policy of marine insurance. Therein, the Act declares that:

A contract of marine insurance is a contract whereby the insurer undertakes to indemnify the
assured, in the manner and to the extent thereby agreed, against marine losses, that is to say
losses incident to the marine adventure.

Expressly, the contract agreed by the insurer and the assured is one of indemnity. The
insurer agrees to provide protection against stipulated losses the assured may incur by
reason of being connected to a marine adventure. As consideration for this protection, the
assured pays a premium calculated by reference to the nature and degree of risk involved in
the adventure. The ultimate objective behind this exchange is to ensure that in the event
that a peril for which provision is made causes loss or damage to the subject matter the
assured would be compensated under the policy. In effect, the policy transfers the risk of
loss or damage occurring to the subject matter from the assured to the insurer who will
bear it should it actualize.

Historically, the transfer of risk by way of marine insurance policy was vital to the
development and preservation of international trade. This was so given the high degree of

3 Irving v Manning (1847) 1 HL Cas 287.


4 British & Foreign Marine Insurance Co Ltd. v Wilson Shipping Co. Ltd [1921] 1 AC 188
danger associated with maritime enterprise and is no less true in modern times. Marine
adventures of any nature remain fraught with danger despite advancements in safety and
technology made over the centuries. Thus the incentive to guard ones interest in the
adventure proves a contemporary and perennial concern. Such caution ensures that the
assured is encouraged to carry on ventures in relative security without the fear of loss or
damage arising through an insured peril leading to financial vulnerability.

Under the policy should a loss occur the insurer is to pay compensation to the assured. In
the context of indemnity insurance, traditionally that compensation is to be such that the
assured is returned to the position occupied at the commencement of the risk. In Castellain
v Preston5 Mr Justice Brett expressed this concept in these terms:

The contract of insurance contained in a marine or fire policy is a contract of indemnity, and
of indemnity only, and this contract means that that assured, in the case of loss for which the
policy has been made, shall be fully indemnified, but shall never be more than fully
indemnified.

Taking this statement into consideration, it is evident that where the assured is to receive
compensation the sum paid is not to be more than is necessary to return the assured to the
aforementioned position. By returning the assured to the position as at the commencement
of the risk the marine insurance policy has effect its aim by providing the assured with a
full indemnity. It follows from this objective to fully indemnify that assureds are also not to
receive an indemnity which is not sufficient to return them to this position. Ideally, the
assured is hence not to be made any worse or better off by the indemnity received. In
placing such limits on recovery under the policy the principle of indemnity ensures that the
assured receives adequate protection from loss or damage incurred while ensuring that the
assured is not over-indemnified, allowing a profit, nor under-indemnified, still leaving the
assured exposed to loss.6

5[1883] QBD 380 at p. 386.


6Rhidian Thomas, The concept and measure of indemnity in marine insurance policies, The
Mordern Law of Marine Insurance. Vol. 3.
The principle of indemnity is often cited as the keystone upon which much of the law of
marine insurance and insurance law at large was constructed. 7 In Castellain v Preston, after
stating that it was the fundamental principle of insurance law, Mr Justice Brett went on to
declare that any proposition which departed from the principle denying the assured a full
indemnity or giving the assured more than and full indemnity is, with certainty, wrong. 8 In
Rickards v Forestal Land, Timber and Railways Co. Ltd9, Lord Wright also conveyed the
importance of the principle. Lord Wright averred that the object of both the legislature and
the courts have been to give effect to the idea of indemnityand to apply it in the diverse
complications of fact and law. Despite this aim the principle of indemnity is not immune
from conflict with the law and practices of marine insurance. In section of the MIA 1906, it
is indicated from the outset that the principle of indemnity is contractual in nature and can
therefore be controlled by the parties.10 This factor allows for the existence of valued
policies, which by their nature give the assured and insurer the room to overturn the
traditional concept of indemnity by agreeing a measure of indemnity outside the
parameters of full indemnification. In such cases the departure is not considered wrong
with such conviction as submitted by Justice Brett. The parties freedom to contract is
respected and in the absence of fraud or contravention of other provisions within the MIA
1906, the measure of indemnity agreed to is allowed to stand.

Valued Policies Defined


Section 27(1) of the MIA states that a policy may be either valued or unvalued, thus first
acknowledging a division that bears significant implications for the traditional
conceptualization of the indemnity principle. The Act then goes on to define what is meant
by the term valued policy. In this regard it declares that a valued policy is a policy which
specifies the agreed value of the subject matter insured. Importantly, it is further stated that
the agreed value, as determined by the assured and insurer, is to be conclusive to the
insurable value of the subject matter insured in the case of a total or partial loss.

7 Castellian v Preston (1883) 11 QBD 380, Rickards v Forestal Land, Timber and Railway Co Ltd
[1941] 3 All ER 62.
8 Castellain v Preston (1883) 11 QBD 380 at 386.
9 [1941] 3 All ER 62 at p. 76.
10 Rhidian Thomas. The concept and measure of indemnity in marine insurance policies. The

Modern Law of Marine Insurance. Vol. 3.


As noted above the value of the subject matter insured is fixed or agreed between the
parties to the policy of assurance. The sum then stands as the insurable value of the subject
matter. By way of contrast, in the case of an unvalued policy, the insurable value of the
subject matter is fixed in accordance with the criterion set out in section 16 of the MIA
1906. In an insurance policy the insurable value represents the actual market value of the
insured subject matter as it stood at the commencement of the risk. Under a valued policy
the insurable value is dictated by the parties and does not necessarily have to bear any
relation to the actual value of the subject matter on the market. It may be set higher or
lower than such value. Often business efficacy and practicality necessitate that the agreed
value be greater or lesser than the actual market value of the subject insured. For instance,
in order to discourage the making of small claims the insurer may insist on a high agreed
value to bolster the protection from such claims offered by deductible clauses. 11 Also, in
favour of the assured, setting the agreed value high may offer security against market
fluctuations. This can be seen in the case of ships where value rises and falls dependent on
the strength of the freight market.12 Consequently, in light of the range it may span, an
agreed value is said to transform the nature of the financial bargain.13 Where the value is
fixed between assured and insurer the nature of the bargain is not to return the assured the
position occupied at the commencement of the risk. Instead the agreement becomes one to
indemnify the assured to the extent of the parties choosing.

Section 27 of the MIA 1906 hearkens back to the contractual nature of indemnity as pointed
to in section 1 of the same act where it is stated that the insurer undertakes to indemnify
the assured, in the manner and extent thereby agreed. By concluding an agreed value the
parties effectively bring the terms of indemnity within their control. Where this is done
their agreement is regarded as conclusive and binding not only in respect of the measure of
indemnity receivable under the policy but also in respect of all monetary matters
concerning the subject matter insured. 14Hence, both parties are prevented from denying
that the insurable value of the subject matter is other than that stated in the policy.15 The
courts are protective of the parties freedom to contract in this regard and thus will aim to
uphold the agreed value by following the measure of indemnity as set by the inclusion of

11 Thames & Mersey Insurance Co Ltd v Gunford Ship Co Ltd [1911] A.C. 529
12 Howard Bennett. The Law of Marine Insurance
13 Ibid.
14 F.D. Rose. Marine Insurance: Law and Practice. 2nd ed.
15 Irving v Manning(1847) 1 HL Cas 287.
such value in the policy. Nonetheless, as provided in section 27(3), the conclusiveness of the
agreed value may be tested in face of subjection to the provisions of the MIA 1906 and
where there may be fraud.16 That being so, where the agreed value appears to have been set
against a background of misrepresentation for instance or through fraudulent endeavours
the court may interfere to put the measure of indemnity right. However, the old adage of
contract law that the courts are not tasked with the duty of policing bad bargains must be
borne in mind and the parties, in this regard, should be wary of the terms of the policy.

It should further be noted that an agreed value is not the same as a sum insured. The
function of a sum insured is to place an overall limitation on recovery under the policy.
Unlike an agreed value, a sum insured bears no relation to the value of the subject matter
insured. Where a policy contains an agreed valued it is likely that the policy is a valued
policy. On the other hand where the policy contains a sum insured it is likely that the policy
is an unvalued policy. However, ultimately, the question of which category a policy falls
under is a matter of construction, as the distinction at times is not as unambiguous. 17
Nevertheless a crucial distinguishing factor between the two is that whereas under an
unvalued policy that assured has to prove the actual value of the subject matter while under
a valued policy that need not be done.18 This factor makes the valued policy in an attractive
means of insurance as the parties are saved the time and expense of having to inquire about
the actual value of the subject matter. In light of this it is not surprising that that some of the
most commonly used standard form policies are valued policies.19

Over-valuation
As a brief but important note, that fact that the agreed valuation constitutes an
overvaluation of the subject matter insured is not itself grounds to re-open the agreed
value. In the ordinary case the fact of over-valuation serves as an indicator flagging up some
underlying contravention of the rules of marine insurance law as they flow from public

16 Further discussion below.


17 F.D Rose. Marine Insurance: Law and Practice. 2nd ed.
18 Gilman, John, Robert Merkin and Claire Blanchard. Arnoulds Law of Marine Insurance and Average.

17th ed.
19 Rhidian Thomas, The concept and measure of indemnity in marine insurance policies. The

Modern Law of Marine Insurance. Vol. 3.


policy concerns. As stated above section 27(3) of the MIA 1906 lists two circumstances in
which the agreed value is not conclusive. The first is where may be subject to other
provisions of the MIA 1906. Expressly, this would include situations where: (1) the assured
has not insurable interest in the subject matter so as to make the policy a gaming or
wagering contract; or (2) where a material fact has been misrepresented or not disclosed by
the assured and the assured stands to gain in light of the agree value. The second
circumstance is where the assured attempts to profit from the policy by fraudulently
overvaluing the subject matter. The inclusion of an over-valuation in a valued policy is in
keeping the parties freedom to contract. Therefore, interference will not be permitted
unless a case for one of the above can be made. Where such a contravention is alleged the
remedy is often to set aside the policy entirely and not merely a reappraisal of the agreed
value. 20

Measure of Indemnity under Valued Policies


By examining the measure of indemnity in the context of valued policies we are able to
observe how the agreed value operates. Through this observation it becomes evident that
the agreed value is an active contributor to the distortion of the traditional concept of
indemnity.

Total Loss
In the context of marine insurance a total loss can take one of two forms, either actual total
loss or constructive total loss. In both cases the subject matter insured is considered
completely lost to the assured and upon that loss the assured is entitled to the full agreed
value under the policy. As noted the agreed value under the policy is representative of the
insurable value of the subject matter under the policy. It is this to which the assured is
entitled in face of a total loss regardless of whether the policy is valued or unvalued. The
conclusiveness of the agreed value in this case estops the assured or insurer from disputing

20 F.D Rose. Marine Insurance: Law and Practice. 2nd ed.


said value.21 So long as the value agreed has been paid to the assured in this circumstance it
cannot be denied that a full indemnity has be given under the policy.22

Partial Loss
Where the assured suffers a loss which is not a total loss, the loss is said to be partial. In
such a case the assured does not receive the entirety of the agreed value. Instead the
indemnity to be paid to the assured is measured by reference to the agreed value. Such
proportion of the agreed value that is commensurate with the loss sustained is granted to
the assured as compensation. The method used to derive this sum is detail below in regards
to the specific subject matter while simultaneously highlighting the inconsistency between
using such method and the principle of indemnity.

Freight
In dealing with insurances on freight, a partial loss may arise where for instance the whole
of the cargo upon which freight is to be earned is not loaded or is lost. Partial loss of freight
is of particular significance in the context of valued policies when considering that the value
of the freight agreed in the policy is based on a full cargo and the market rates existing at
the time the policy is effected.

In Forbes v Aspinall23 a claim was lodged for total loss and hence payment of the agreed
value of 6,500 under a policy on freight for a cargo of 55 bales of cotton. Only part of the
cargo was load and then lost in due course. It was held by the Kings Bench that the assured
was not in fact entitled to the full value agreed but instead to the proportion of such value
that represented the actual loss suffered. The reason behind this being that the principle of
indemnity required an apportionment to be effected where the agreed value was based on
the loading of a full cargo and only part of the cargo is in fact loaded. 24 In this case had the

21Gilman, John, Robert Merkin and Claire Blanchard. Arnoulds Law of Marine Insurance and Average.
17th ed.
22 Rhidian Thomas, The concept and measure of indemnity in marine insurance policies. The
Modern Law of Marine Insurance. Vol. 3.

23 (1811) 13 East 323


24Howard Bennett. The Law of Marine Insurance
assured received the full agreed value, compensation would have been given not merely for
the freight lost in respect of the part cargo lost but for the freight earnable on the entire
consignment of 55 bales. This would be to grant the assured a profit. In doing so the
assured would be placed in a better position than at the commencement of the risk having
been indemnified in respect of the freight on the part cargo lost and having double the
freight on the part not lost. Espousing the same principle but in regards to more
complicated facts the claimant in The Main25 was also held to be entitle to only a proportion
of the agreed valuation. The case concerned a policy on freight for a voyage between New
Orleans and Liverpool. The agreed value of the freight stood at 5,500 with a sum insured of
1,500. On the outward journey the vessel was damaged and delay incurred during which
time the freight earnable for the specified voyage depreciated to 3,250. Of that sum 925
was payable in advance and hence not risk. Therefore, when the vessel was totally lost
giving rise to loss of the freight, the assureds actual loss was 2,325. The question to be
considered was what proportion of the agreed value was the assured entitle to in light of
the depreciation in value and the actual loss suffered. Consequently, the answer was that
the assured was prima facie entitled to 3, 889, only 1,500 of which could actually be
claimed.26 The end result was that the insurers were bound to pay 639 of this sum as credit
was given for 3,250, which the assured had already recovered under policies with other
insurers. Had the assured been granted the full limit of the policy, an indemnity
commensurate with the full agreed value would be given making no deduction for the
freight not at risk. However, the factor that has greater significance to this discussion is that
in any event the agreed value in this case was not revised in light of the depreciation in the
value of the freight. Hence the claim by the assured was based on a value which far
exceeded the actual value of the subject matter ensured and hence the value of the loss.
Thus, unlike in Forbes v Aspinall above, the apportionment did not prevent the assured for
receiving more than a full indemnity in the traditional sense.

The mode of apportionment by reference to the agreed value in the policy came to be
embodied in section 70 of the MIA 1906. The provision states that where there is a partial
loss of freight under a valued policy, the indemnity to be paid to the assured is to be
calculated by reference to the agreed value stipulated by the parties. Expressly, the section

25 [1894] P 320.
26Howard Bennett. The Law of Marine Insurance
prescribes that the indemnity the assured receives is to be that proportion of the agreed
value that correlates to the ratio of the freight lost by the assured versus the whole of the
freight at risk on the adventure. While the apportionment method takes account of the
principle of indemnity it is easy to see that in some cases the assured may be over-
indemnified. This would occur where the value agreed on freight is set high or where the
value of the freight depreciates with the result that the value in the policy is higher than the
market value of the freight as seen in The Main above.27 Explicitly, in these situations should
a partial loss of the freight occur, the apportionment would be made against an agreed value
that does not reflect the actual value of the freight at the time of loss. Thereby the assured
gains in excess of the loss actually suffered, thus eschewing the concept of indemnity.
However, in modern practice attempt is made to abate this effect. In the Institute Voyage
Clauses Freight 95 at 10.1 and the Institute Time Clauses Freight 95 at 14.1 clauses are
introduced which place a limit on the amount recoverable to the gross freight actually lost.28
However seeing that the clauses use the gross freight as a means of limitation the assured is
still presented with a windfall in light of the fact that incidentals that would have been
payable if the freight had been earned are included in the tally.29

Goods
Under the MIA 1906, partial loss of goods is governed by section 71. As is the case in
regards to freight, the indemnity payable to the assured is also apportioned by reference to
the agreed value. Under the section 71 a distinction is made between goods which are
partially lost by reason of part of a whole consignment being totally lost or by reason of a
part or the whole of the goods being damaged but not a total loss. Where a part of the goods
becomes a total loss, the measure of indemnity under a valued policy is determined by
taking the insurable value of the part of the goods lost set against the insurable value of the
whole of the goods. This sum is then compared to the agreed value set in the policy and an
appropriate proportion of the agreed value becomes the indemnity payable to the assured.
In the case of a partial loss incurred by damage to a part or whole of the goods the measure
of indemnity is calculated by taking a proportion of the agreed value that corresponds with

27 Rhidian Thomas, The concept and measure of indemnity in marine insurance polices, The
Mordern Law of Marine Insurance. Vol. 3.
28 Ibid.
29 Ibid.
sum of the damaged value of the goods subtracted from the gross value the goods would
have had in their undamaged state.

As highlighted above in regards to the method of measuring the indemnity payable for a
partial loss of freight, the use of the agreed value provides an affront to the tradition
concept of indemnity in marine insurance. The same is true in context of partial loss of
goods. Where a high agreed value is placed on the goods in the policy the assured stands to
gain more than would be necessary to indemnify against the partial loss suffered. 30 Also
where market values are subject to fluctuation the assured may well receive more or less
than a full indemnity.31 In this scenario, the market value of the subject matter insured may Commented [KR1]: Needs to be finished!
no longer closely straddles the agreed value but instead stands markedly above or below
such value. Hence, where the market value stands much above the assured may receive an
indemnity not nearly sufficient to compensate for the partial loss of the subject matter.
Inversely, where the market value is much below the agreed value the indemnity given will
result in a profit to the assured.

Ships

Under section 69 of the MIA 1906 the measure of indemnity in cases of partial loss of ships
is addressed. The Act envisages three situations. First, where the damage to the ship has
been wholly repaired the measure of indemnity is the reasonable cost of repairs not
exceeding the sum insured in respect of any one casualty. Second, where the ship is only
partially repaired, the assured is again entitled to the reasonable cost of repairs in addition
to being indemnified for the reasonable depreciation in the value of the ship in light of the
unrepaired damage. The total sum payable in this regard is not to exceed the cost of fully
repairing the damage. Third, where the ship has been neither repaired nor sold during the
currency of the risk the assured is entitled to a sum reflecting the reasonable depreciation
in respect of the unrepaired damage but not exceed the reasonable cost of repairing the
damage sustained. Not included in the Act however is a third situation which is however
addressed at common law. Namely, where the ship has been wholly or partially repaired
and has been sold during the currency of the risk. In Pitman v Universal Marine Insurance Co

30 Rhidian Thomas, The concept and measure of indemnity in marine insurance policies, The
Mordern Law of Marine Insurance. Vol. 3.
31 Ibid.
it was held that the assured in such a case would be entitled to the depreciation in value of
the vessel occasioned by the damaged incurred. In addition in deference to section 75 of the
MIA the assured in this case is not to be entitled indemnified beyond the estimated costs of
repairing the ship.

As can be seen with the exception of the first circumstance, the measure of indemnity in the
case of partial loss of a ship is calculated with reference to the depreciation in value of the
vessel in light of the degree of repairs undertaken. Depreciation in the context marine
insurance is determined by subtracting the damaged value of the ship from the sound value
of the ship as these figures stood at the termination of the risk.32 This formulation reveals an
obvious difficulty for any attempt to adhere to the traditional concept of indemnity. The
calculation is made by reference to values taken at the expiry of the risk. The difference
between these two figures is, in the case of a valued policy, then to be expressed as a
percentage and measured against the agreed value by taking such percentage of the agreed
value that is representative of the difference.33 The problem here is that the sound and
damaged values as taken at the expiry of the risk are used alongside the agreed value which
is determined at the commencement of the risk to ascertain the indemnity payable to the
assured. Thus where the agreed value is highly set the assured is paid an indemnity which
may be well in excess of the loss suffered through the depreciation in the ships value. 34 Commented [KR2]: Expand on this

Ergo, this method of measuring the indemnity is also subject to the same variances as seen
with the apportionment method used in the case of freight and goods.

Conclusion
What the measure of indemnity in the case of valued policies reveals to us is that achieving
full indemnification by reference to the agreed value in most cases produces a result which
does not align with the concept of indemnity in its traditional form. This does not negate the
fact that the agreed value may contribute to an indemnity which is more akin to the
traditional concept and not help to significantly over-indemnify or under-indemnity the

32Rhidian Thomas, The concept and measure of indemnity in marine insurance policies, The
Mordern Law of Marine Insurance. Vol. 3., Lidgett v Stevenson (No. 2) (1871) L.R 6 CP 616, Helmville
Ltd v Yorkshire Insurance Co Ltd (The Medina Princess) [1965] 1 Lloyds Rep 361
33 Howard Bennett, The Law of Marine Insurance
34 Rhidian Thomas, The concept and measure of indemnity in marine insurance policies, The

Mordern Law of Marine Insurance. Vol. 3.


assured by following closely the actual market value of the subject matter insured.
However, the agreed value is a creature of contract and is allowed to be such with near
impunity. In the context of marine insurance law the freedom to contract granted to the
parties in a valued policy has come to supplant the traditional concept of indemnity. While
the insurer still agrees to protect the assured from loss occasioned by insured perils, the
bounds of this protection are not limited to exact indemnification. Instead with their
freedom the parties to the policy of assurance have elected to enlarge this protection as
near the limits as it can safely go. However, this room to stretch is not so restricted. While
the courts do hold the traditional concept within their contemplation, this contemplation
only moves them to act in the face of overt challenges to public policy concerns of
profiteering. Nevertheless, this inaction should not be regarded negatively. It embodies the
courts determination to imbue the law of marine insurance with commercial sensibility in
order that it may sway with the needs of marine insurance in practice.
Bibliography
Cases
British & Foreign Marine Insurance Co Ltd. v Wilson Shipping Co. Ltd [1921] 1 AC 188.
Castellain v Preston [1883] QBD 380 at p. 386.
Forbes v Aspinall (1811) 13 East 323
Irving v Manning (1847) 1 HL Cas 287.
The Main [1894] P 320.
Thames & Mersey Insurance Co Ltd v Gunford Ship Co Ltd [1911] A.C. 529.

Books
Bennett, Howard. The Law of Marine Insurance, 2nd ed. Oxford: Oxford Press, 2006.
Gilman, John, Robert Merkin and Claire Blanchard. Arnoulds Law of Marine Insurance and
Average, 17th ed. Sweet and Maxwell, 2008.
Hodges, Susan, Law of Marine Insurance, 1st ed. London: Cavendish, 1996.
Legh-Jones, Nicholaw. MacGillivray on Insurance Law, 11th ed. London: Thomson Rueters,
2008.
Rose, F.D. Marine Insurance: Law and Practice, 2nd ed. London: Infroma, 2012.
Thomas, Rhidian. The concept and measure of indemnity in marine insurance policies, The
Mordern Law of Marine Insurance. Vol. 3. Informa, 2009. Commented [KR3]: