Simmonds v. Cockell (1920) All ER Rep. 162

Simmonds v. Cockell (1920) All ER Rep. 162

FACTS-

  • The plaintiff sues an underwriting member of Lloyd's under a policy of insurance against burglary, housebreaking, and theft dated May 1, 1919.
  • During the policy's currency, the premises were broken into, and approximately £475 worth of the plaintiff's goods were stolen.
  • The defendant's defence revolves around one point: whether the warranty of continuous occupancy of the premises has been breached.
  • The defendant argues that any absence constitutes a breach of the warranty, while the plaintiff contends that the warranty refers to continuous residential use of the premises.

 

ISSUE-

  • The crucial issue is whether the plaintiff's absence from the premises during the burglary constitutes a breach of the warranty of continuous occupancy.

 

RULE-

  • Ambiguities in clauses drawn by a party for their own protection must be construed against them.
  • If the language of a warranty in a policy is ambiguous, it should be interpreted against the underwriter who inserted it for their own protection.

 

HELD-

  • The warranty in question states that the premises must be "always occupied."
  • The plaintiff and his wife were absent from the premises for several hours on the day of the burglary.
  • The judge interprets the warranty as requiring continuous occupation for residential purposes, not continuous physical presence on the premises.
  • If the warranty were construed differently, it would be highly ambiguous and would be interpreted against the defendant under the principle of insurance law.
  • The judgment is in favour of the plaintiff, with costs awarded