The aim of this study is to examine the importance of the decision in Engelhart CTP (US) LLC v Lloyd’s Syndicate 1221 with regard to the insurance of economic losses and non-existent goods in the context of all-risks cover. It also strives to analyse to what extent the principles of construction described in this decision are applicable to the interpretation of all risks cover in marine insurance disputes subject to Polish law. Assureds and beneficiaries of cargo policies are defrauded into taking up false documents for non-existent goods yet Polish law fails to address the questions which arise in such situations. It is thus important not only to investigate and evaluate the answers provided by English law but also to explore if and how Polish law may employ them. It follows from this study that Engelhart may be used in construction of all-risks policies subject to Polish law in most scenarios.