ABSTRACT
It was held that the words ‘‘all risks’’, unlike the time-honoured phrase ‘‘all other perils, losses and misfortunes’’ added to the other risks mentioned earlier in the policy. It was not necessary to describe the extent of the additional cover. This was first addressed in Schloss Bros v. Stevens10 where Walton J. held that the words ‘‘all risks’’ were intended to cover ‘‘all losses by any accidental cause of any kind occurring during the transit’’.11 He added: ‘‘There
British & Foreign Marine Insurance Company Limited v. Gaunt where Lord Sumner said:
‘‘There are, of course, limits to ‘‘all risks’’. They are risks and risks insured against. Accordingly the expression does not cover inherent vice or mere wear and tear . . . it covers a risk, not a certainty; it is something which happens to the subject-matter from without, not the natural behaviour of that subject-matter, being what it is, in the circumstances under which it is carried. Nor is it a loss which the assured brings about by his own act, for then he has not merely exposed the goods to the chance of injury, he has injured them himself.’’
