8.1 Over the years, the courts have developed the definition of storm, beginning with the ordinary and natural meaning of the Oxford English Dictionary and refining it to include rain and wind.1 The FOS seems to decide storm cases in the same way, although because it does not mention any case law, it is questionable whether this is only a coincidence most likely to happen because the court adopts an ordinary and natural meaning and because the FOS, especially with its non-legal staff, is unlikely to adopt anything else.