PRINCIPLE STATEMENT

A contract of non-marine insurance is created where there is an unqualified acceptance by one party of an offer made by the other. Once a proposal is accepted without qualification, the contract is complete.

RATIO DECIDENDI (SOURCE)

Per Kutigi, JSC, in Ngillari v. National Insurance Corporation of Nigeria (1998) NLC-721992(SC) at pp. 10–11; Paras A–D.
"A contract of insurance, like any other contract, is created where there has been an unqualified acceptance by one party of an offer made by the other… Where a proposal in the normal form is accepted without qualification, the contract is complete and the insurers are bound to issue, and the proposer to accept, a policy in accordance with the stipulations of the proposal."
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EXPLANATION / SCOPE

Insurance contracts follow ordinary contract principles. Offer and acceptance create the contract. The policy document is evidence, not the contract itself. The principle applies to non-marine insurance. The insurer cannot later impose new terms. The rule protects proposers who rely on acceptance.

CASES APPLYING THIS PRINCIPLE