The principle of'utmost good faith' has always been the crown of the field of Marine Insurance Law, which derived from the case of Carter v Boehm (1776). With the codification of the Marine Insurance Act 1906, the principle found expression in ss 17 to 20 : s 17 presents the general duty to observe the utmost good faith, with the following sections introducing particular aspects of the doctrine,namely, the duty of the assured (s 18) and the broker (s 19) to disclose material circumstances, and to avoid making misrepresentations (s 20).