What is fire? This is the central question in the discussion of the friendly-hostile fire doctrine. Since fire is defined differently by the historian, the scientist, the layman, the economist, the lawyer and the insurance agent, it becomes necessary to consider these viewpoints separately and hopefully seek to clarify the existing differences. After completing this undertaking, it then becomes necessary to discuss the historical evolution of the doctrine with particular emphasis being placed upon a careful dissection of the early English case of Austin v. Drew which first introduced the principles embodied in the doctrine and the American case of Way v. Abbington Mutual Fire Ins. Co. which later coined the term, "friendly-hostile fire." The various divergent approaches taken by the courts concerning the doctrine will subsequently be viewed. Broadly generalized and inconsistent judicial policies in the area greatly impede the effective and uniform pursuit of logical remedies to the problem.
George P. Smith II, Friendly v. Hostile Fires, 70 DICKINSON L. REV. 50 (1965).