One view has been that it is covered by the sue and labour clause of an ordinary policy, by which the insurer agrees to bear his proportion of expenses voluntarily incurred "in and about the defence, safeguard and recovery" of the insured subject.
The view seems to have been that the insurer is liable for salvage and G.A.
This bases the claim against the insurer upon a fiction, for there has been no loss of the subject insured; in fact, the payment has been for averting such a loss.
And it suggests that the insurer is not liable for salvage where the policy is free of particular average, which does not accord with practice.
The liability of the insurer was thus made to depend, not upon the character of the loss, but upon the fact or possibility of contribution.