An attempt will be made to explore the court interpretations of the standard policy definition of "uninsured automobile." However, when reviewing such, three basic consider-tions must be borne in mind. One is that many states have so-called uninsured motorist statutes which contain purpose and intent sections upon which the courts may have relied in allowing a liberal construction to achieve the purpose intended by the legislature. The second is that simple contract law, without statutory influence, requires that the words employed be given their plain and commonly understood meaning. Thirdly, however, any ambiguity in an insurance contract, it being a contract of adhesion, shall be construed against the company and will be given an interpretation most favorable to the insured.
Henry A. Hentemann, Uninsured Motorist Defined, 16 Clev.-Marshall L. Rev. 504 (1967)