How have courts interpreted the phrase “care, custody or control” in the context of an insurance policy?

There are other cases interpreting the phrase “care, custody or control”, but they are distinguishable on their facts. In Excel Cleaning Service v. Indemnity Insurance Co. of North America, 1954 CanLII 9 (SCC), [1954] S.C.R. 169 a rug cleaning company, in the process of carrying out its duty of cleaning, ending up destroying a rug. They were covered by an insurance policy which excluded coverage for “damage to or destruction of property owned, rented, occupied or used by or in the care, custody or control of the insured”. Rand J. stated at para. 14: The obligation to do work upon the property is in contemplation of law to do it while a property remains within the exclusive care and control of the owner. Clearly custody was not transferred; the only care called for was in the execution of the service, not towards the property as such; and no control, in a proprietary sense was intended. Either care or control would have involved some degree of responsibility towards the property, apart from and in addition to that relating to the application to it of the cleaning process. The situation was one in which all proprietary relations remained in the owner and only an operating responsibility towards the property arose. The court noted that this was a commercial liability policy, and if the exclusion applied then the insurance would be worthless. Estey, J. defined “care” as a measure of protection and preservation, “custody” as safe-keeping and protection, and “control” as direction or domination. The court concluded that merely undertaking the cleaning the rug did not involve taking the care, custody or control of the rug.