Many people find it difficult to accept that a war risks case presents anything more than the usual challenge of determining the proximate cause. There will of course be no difficulty where a missile strikes the ship, or a shell hits it. There will of course be no difficulty where a missile strikes the ship, or a shell hits it. The surrounding circumstances and the damage speak for themselves. The Marine Insurance Act 1906 contains in section 55(1) a succinct encapsulation of the importance of establishing the proximate cause. In describing the test of the proximate cause of the casualty, judges have used different expressions (and have given some warnings) as to how the proximate cause or the excluded risk is to be established. The modern approach is to focus with precision on establishing the proximate cause in a flexible manner.