The law of causation in English law can be traced back to 1630. Bacon's maxim stated that cases should be judged on the immediate cause without looking to any prior circumstances. During the Victorian era from 1837 to 1901, the test of the chronologically last cause was formed and applied to insurance cases. This test was to assure certainty in the allocation of risk and liability in commercial cases by dissuading the parties from arguing which event was the cause of loss, focusing instead on identifying the last incident occurring before the loss.