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Scientific American Supplement, No. 288, July 9, 1881 by Various
page 22 of 160 (13%)
it implies _combustion_ as associated with destruction, yet somewhat
distinct from the abstract idea of the resolution of any form of matter
into its elementary constituents. The term, however, as yet takes in the
idea of combustion as a decomposition in but a very limited degree,
and it may be said to be wavering at the line between expansion and
dissociation.

Strictly, in insurance, fire and explosion are different phenomena.
A policy insuring against fire-loss does not insure against loss by
explosion. It thereby enforces a distinction which exists, or did exist,
in the popular mind; and fire, in an insurance sense, as distinct from
explosion, was accurately defined by Justice McIlvaine, of the Supreme
Court of Ohio (1872), in the case of the Union Insurance Company vs.
Forte, i.e., an explosion was a remote cause of loss and not the
proximate cause, when the _fire_ was a burning of a gas jet which did
not destroy, though the explosion caused by the burning gas-jet did
destroy. Earlier than this decision, however (in 1852), Justice Cushing,
of the Supreme Court of Massachusetts, in Scripture _vs_. Lowell Mutual
Fire Insurance Company, somewhat anticipated later definition, and
pronounced for the liability of the underwriter where all damage by the
explosion involves the ignition and burning of the agent of explosion.
That is, for example, the insurer is liable for damage caused by an
explosion from gunpowder, but not for an explosion from steam. The
Massachusetts Judge did not conceive any distinction as to fire-loss
between the instantaneous burning of a barrel of gunpowder and the
slower burning of a barrel of sulphur, and insurance fire-loss is not to
be interpreted legally by thermo-dynamics nor thermo chemistry. While
the legal principles are as yet unsettled, the tenor of current
decisions may be summed up as follows: If explosion cause fire, and fire
cause loss, it is a loss by fire as _proximate_ cause; and if fire cause
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