As for the argument that it was the insurance agent’s duty to follow up, that duty was found in cases like Clark v. Hargreaves where it was clear that the insured had requested coverage. Since the coverage was not immediately available, but would be later, it was the agent’s duty to follow up when the coverage became available. But not in a situation where the agent had discharged its duty to advise with respect to a certain coverage and had quoted it. There was no more follow-up for the agent to do. At that point, the onus shifted to the insureds to make sure their instructions were received.
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