Does consent in the contractual sense need to be obtained from a jeweller?

In Lake v. Simmons consent in the contractual sense was found missing on the part of the jeweller and therefore it was held that the goods were not “entrusted” to the recipient of them, but rather that she obtained them through larceny by a trick.

Certain American authorities which were cited to me place a more liberal interpretation on the word “entrusted”. According to them the sole test is whether the property was voluntarily handed over to the recipient, notwithstanding that the handing over was induced by deceit. Exclusionary provisions of insurance policies are to be interpreted strictly. The interpretation of “entrusted” in Lake v. Simmons, meaning more than bare physical delivery, is therefore to be preferred to the wider meaning adopted in the American authorities.