3.    Policy must be interpreted as a whole [ wholistic Rule] – a court of law must interpret an insurance policy in its entirety. All words an phrases must be interpreted and none must be rendered meaningless without good cause. As a general rule a policy should be interpreted to give all clauses a positive meaning so as to give effect to the intentions of the parties.
Hamlyn Vs Crown Accidental Insurance Co.
 [1893] 1 QB 750
The insured had effected insurance against poultry injury caused by violent, accidental, external and visible means. A clause exempted the insurer from liabilities in respect of injuries arising from “natural disease or weakness or exhaustion consequent upon disease.’

The insured had stooped to pick up a mango dropped by a child and dislocated and injured cartridge of his knee. The insurer contended that there was no external or visible means which caused the accident and that it was not liable. It was held that the word ‘external’ was to be contrasted with internal causes of injury such as disease, mentioned in the clause, hence the injury was caused by external means and the insured would recover.

In the words of Atkin L.J., ‘You must look at the document as a whole’

As a generals rule, similar words or phrases bear the same meaning throughout the policy.


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