If a person is injured in car accident while using a rental car and the driver is not on contract, could the rental agency be made to pay?

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If the car rental agency had knowingly rented an driver without entering into a contract, the rental agency would be liable for the injuries of the person who had used the rental car. However, this would be a rare case, because most car rental agencies would be very vigilant about getting all their drivers into proper contract. If the driver is not on contract but possesses car insurance coverage, the injured person could make a claim on the driver against such policy.