Can an insurance policy be terminated without a written request or delivery of the policy?

Statutory Condition 5(1) of the policy, put there by Section 235 of The Insurance Act, provides that the insurance “may be terminated … by the insured at any time on request”. The action of the insured’s agent, subsequently ratified by the insured, thus was effective without a written request or the delivery of the policy. Construing the identical Ontario provision in Baptist Convention of Ontario v. Hartford Fire Insurance Company [1978] I.L.R. 1279 Holland, J. said at 1282: “I do not find anything in the Statute which requires that in these circumstances the insured sign a receipt for cancellation or that the policy be delivered up. Further, there is nothing in the Statute which requires the agency to deliver the policy to the company for cancellation.”