The relationship between contextualism, The Achilleas, and the standard rules of remoteness has been further clarified by the Court of Appeal in John Grimes Partnership Ltd v Gubbins [2013] EWCA 37. Briefly stated, the standard rules of remoteness (from Hadley v Baxendale through to The Heron II) apply unless they have been displaced – for example, by express provision or, after The Achilleas, by the particular understanding in the relevant business sector.