The insured must establish that the loss for which a claim is made is proximately caused by an insured peril. 1 Recovery is subject to the parameters of the insurance contract as defined by its contractual terms. The determination of the ‘cause’ of loss is, however, not always an easy task. A loss may result from a series of events, 2 and as observed by Lord Justice Lindley in Reischer v Borwick, 3 it is sometimes difficult to distinguish between causes which cooperate in a given result when they succeed each other at intervals. Further, analysis of what has been called the ‘causeevent-result’ combination is less than clear. There exists no prevailing agreed and settled criteria for selecting from the existing circumstances, those events genuinely relevant to interpretation and application of the provisions at issue in a given context. 4