6.1 It has long been the practice for international marine cargo business in Japan to be insured on English policy terms and conditions. By the 1890s, The Tokio Marine Insurance Company, Limited2 was using an English form of policy, similar to the traditional English SG Form.3 The oldest example of such a policy still in existence was issued in 1892 by Tokio Marine for the insurance of bullion for carriage from “San Francisco to Yokohama and/Kobe” with the cargo held covered, “in the event of the treasure being carried to Hong Kong”.4 More recently, the SG Form continued to be widely used in Japan, with the 1963 version of the Institute Cargo Clauses (All Risks).5 It was only in July 2009, when the revised Institute Cargo Clauses of 2009 were widely adopted in Japan, that more modern policy forms were introduced. Although the early form of the Tokio Marine & Fire policy did not express itself to be subject to English law and practice,6 current Japanese policy forms have a partial incorporation of English law as to claims,7 and invariably incorporate the terms of the Institute Cargo Clauses which themselves are subject to English law and practice.8