The duty of good faith and fair dealing (also known as “bad faith”) is an implied covenant that neither party to a contract will do anything which will injure the right of the other to receive the benefits of the agreement. As applied to liability insurance, it is a liability insurer’s duty not to withhold unreasonably payments due under a policy. Bad faith exposes a liability insurer to pay non-contractual damages to the insured. See, Article: Duty of Good Faith and Fair Dealing.