“…td [1929] AC 534 at 539. In modern times, the leading case on concurrent causes is JJ Lloyd Instruments ltd v Northern Star Insurance Co. Ltd (The Miss Jay Jay)[1987] 1 Lloyd’s Rep 32. There, the yacht was lost due to adverse sea conditions (which fell within the scope of the insurance) and unseaworthiness due to design defects (which was no…”
“…Employers Liability Assurance Corp. Limited [1974] QB 57 and The Miss Jay Jay [1987] 1 Lloyd’s Rep 32. But for the reasons which I have explained, that analysis simply does not arise here because there were not two concurrent causes.…”