Before the passing of the Marine Insurance Act, 1906, in U.K., marine Insurance was entirely governed by common law. When any practical difficulties arose which could not be resolved by reference to precedents, the Committee of Lloyd’s were consulted by the interested parties for a ruling and these rulings eventually were issued in the form of “Customs of Lloyd’s. These customs so issued covered only features on which the existing case law was silent or obscure. However, when the particular feature was subsequently decided upon the Court the particular custom became superfluous and was no longer applicable.