The extended contribution principle from the AMP case applies where two different insureds are entitled to indemnity from two different insurers in respect of separate liabilities for the same injury, and an uncrystallised liability is sufficient for double insurance purposes where the failure to crystallise is due to the injured party's choice. Where a second insurer concurs in the first insurer's admission of liability and quantum, the second insurer cannot later dispute the first insurer's obligation to indemnify in contribution proceedings. The question whether contribution is available where the first insurer voluntarily assumed a burden it did not have, absent the second insurer's concurrence, remains open.
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