When can an insurance policy exclude coverage for personal injury caused by explosives?

When we interpret the policy in the instant case under the settled principles applicable to interpretation of insurance policies, Wilson v. Travelers Insurance Co., supra, 183 Cal. 65, 190 P. 366 is controlling. There the policy provided for recovery for personal injury caused by train wreckage but included within the long list of exclusions "injury resulting wholly or partly from any of the following to wit: ... explosives of any kind." (183 Cal. at p. 67, 190 P. 366.) The insured was seated in a passenger car of a train when a violent explosion occurred in the toilet room, with parts of the passenger car causing injury to the insured. The court reasoned: "If we must look for the cause of the injuries to the first cause, it would never be the wreckage of the car which is itself, a result and not a cause." (183 Cal. at p. 68, 190 P. 366.) The court went on to conclude that if the insured had been directly injured by a bomb placed in his lap which then exploded, the exclusion would have been effective to eliminate coverage but where the explosion caused parts of the wrecked car to injure the insured there was coverage under the established rule of construction requiring ambiguities to be construed in favor of the insured. (183 Cal. at p. 69, 190 P. 366.)