Hanover Insurance Co. v. Hallford

Bell, Chief Judge.

To recover attorney’s fees or penalty for bad faith a demand for payment of the loss must be made more than 60 days prior to filing of the suit; Code Ann. § 56-1206. Hull v. Alabama Gold Life Ins. Co., 79 Ga. 93 (1a) (3 SE 903) and Continental Life Ins. Co. v. Wilson, 36 Ga. App. 540 (4, 5) (137 SE 403). The case of Cotton States Mutual Ins. Co. v. Clark, 114 Ga. App. 439 (8) (151 SE2d 780) held that no particular language is necessary to constitute a demand. In Clark the statement of the insured to an adjuster insisting upon payment of his loss and if not paid he would…