ABSTRACT
In the case, Lord Shaw explained the proximate cause as a "real efficient cause" and stated that "causation is not a chain, but a net". The issue of causation dates back to the sixteenth century and, thus, it is significant to examine this issue in detail in order to identify how the law has changed since then. Previously, in the common law of marine insurance, the causation test was challenged by way of case law; in particular, a range of contributing factors in a time chain was assessed. Lord Shaw in Leyland Shipping made it clear that "causation is not a chain but a net", and thus, where the contributing factors in the chain may compete equally in determining the real proximate cause of the loss. Complex causation issues may also arise with certain types of project cargoes where there has been progressive damage to the insured property as a result of movement or vibration of the vessel.
