Hague/Hague-Visby Rules - Bills of Lading, "Straight" Bills and Limitation (the "Happy Ranger")

July 2002

In a recent decision the English Court of Appeal considered the application of the Hague/Hague-Visby Rules and the following issues:

• the requirement for the issue of a bill of lading (or other similar document of title);

• the impact of a "straight" bill of lading; and

• the carrier's right to limit liability even where he has failed to exercise due diligence - the meaning of "in any event" in Article IV Rule 5(a) . 

Parsons Corporation & Others v CV Scheepvaartonderneming - the "Happy Ranger"

Click here to view report of the "Happy Ranger" decision in DMC's CaseNotes*

* DMC CaseNotes are edited by David Martin-Clark. 

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This decision was subsequently relied upon by the English Commercial Court in the "Kapitan Petko Voivoda".