In the case Valley Forge Insurance Co.v.Great American Insurance Co.,the court ruled that:

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The court ruled that title had not passed to Kennedy as the full purchase price had not been paid. In this case, Kennedy had only paid a portion of the purchase price and still owed the seller for the car. Therefore, until the full payment was made, the title remained with the seller and the risk of loss also remained with the seller.

In the Case Valley Forge Insurance Co