at 574. This conflict is jurisprudentially significant and deserves some reasonable resolution. 7 Although Keys was raised hy the parties, although Keys governed the precise issue before it, and although this Court’s unanimous opinion in Keys had never been overruled, Kurylowicz, nonetheless, ignored its authority because “no Michigan appellate court has seen fit to cite [Keys] since it was released in 1959.” Kurylowicz, 67 Mich App at 572. 8 The flaw in the Court of A (“[Bjasic public policy considerations require that, once an innocent third party is injured in an accident in which coverage is in effect on the automobile, an insurer will be estopped from asserting rescission as a basis upon which it may limit its liability to the statutory minimum.”); Kurylowicz, 67 Mich App at 576 (<HOLDING>), quoting Barrera, 71 Cal 2d at 663. 12 See
holding that the insurers duty to undertake a reasonable investigation directly inures to the benefit of third persons injured by the insured holding that where all necessary parties  including the insurer the insured and the third party claimant  had stipulated to the material facts in the dispute a declaratory judgment action on the insurers duty to indemnify could proceed holding that an insurers duty to defend arises from the allegations in the complaint against the insured holding despite a reservation of rights that when the insurer provides a defense to its insured the insured has no right to interfere with the insurers control of the defense and a stipulated judgment between the insured and the injured claimant without the consent of the insurer is ineffective to impose liability upon the insurer holding that where an insured consistently deals directly with its insurers reinsurer  the reinsurer may become directly liable to the insured