intention was to reduce the liability of both parties. The intention of both parties was that the Third Party (carrier) takes out an insurance policy. Counsel submitted that the commercial purpose of insurance is to reduce liability by arranging for compensation in an event leading to loss. Defendant's submission that whether or not the value of the goods had been declared or not, whether or not insurance that had been taken out for the full value of the goods, this would not in any way limit the liability of the Third Party to indemnify the Defendant for the full value of the Goods. Counsel contends that this undermines the very essence of insurance and does not make any business sense. Counsel prayed that the court on the basis of The Interpretation of Contracts 2nd Ed by Kim Lewinson Q.C. para 6.13 pages 189-191 finds that clause 8.3 is of no binding effect on the parties. Counsel prayed that this court dismisses the Defendant's claim for indemnity against the Third Party and in the alternative if judgment is entered it should not exceed USD. 55,000. The Defendant's Counsel in rejoinder responded that the Insurance was to be taken out by the Carrier, who is the Third Party in this case in the names of the Third Party. This was never done. Therefore there was a valid policy for Threeways Shipping and not the Third Party and no evidence was led to show that this policy was capable of assignment or that the same was indeed assigned to the Third Party. The argument that the Third Party and Threeways Shipping company Ltd are sister companies is not relevant. 'There is nothing in Law or under the Companies Act called “sister companies”. The Third Party is a Body Corporate capable of contracting in its own corporate name and no reason was ever given why the Third Party never took out the Insurance in its own names as required under the provisions of Exhibit "Dl". Secondly phrase “Full Insurance Cover” means insurance that covers the loss as fully as opposed to that which would cover a portion of the loss. The definition is not rocket science and counsel relied on Black’s Law Dictionary, 8th Edition, where full coverage is defined as “Insurance protection that pays for the full amount of a loss with no deduction'. Therefore the Invitation to the Court to have the phrase rejected is not justifiable especially since it appears to be informed by a lack of understanding of its true meaning and import. Thirdly it is alleged that out an Insurance policy in the names of Threeways Shipping Exhibit TPl but a reading of the 46

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