Application Of The Contemporary F.O.B. Contracts - Essay Example

Application Of The Contemporary F.O.B. Contracts Question: 1. The term “f.o.b.” connotes ‘free on board.’ The f.o.b. contract is always flexible in nature. It facilitates both the parties to change many of its incidents without modifying its nature as an f.o.b. contract. In Pyrene and Co .Ltd v Scindia Navigation Co.Ltd1, Delvin J observed that f.o.b. contract can be classified as follows: The classic or stern f.o.b. agreement An f.o.b. contract with supplementary covenants or obligations. The contemporary f.o.b. contract Delvin J has referred f.o.b. contract as a flexible instrument. “In case of f.o.b. contract with supplementary covenants or duties, the seller will be required to identify a carrier and has to enter into a contract of carriage with such carrier, has to load the products on the board and then dispatches the bill to the purchaser. In this type of f.o.b. contract, seller has assumed extra duties like identifying a ship, arranging for insurance for the products sold and hence this type of f.o.b. contract is being considered as a clone to the c.i.f. contract as it more closely looks like a “c.i.f. contract.” Contemporary “f.o.b. contract” Under this type of contract, the purchaser, himself will identify a ship either through his agent or directly. Hence, it is the buyer who identifies and appoints a carrier and seller will place the products sold on board of the carrier. Specialty of this type of contract is that the ‘bill of lading ‘will be forwarded to the buyer or his agent directly and will not go by through the seller’s hands. As the norm, today, this type of contract has replaced the traditional f.o.b. contract. (Bradgate & White 2007:250). The “free on board “(f.o.b.) contract has been defined as a ‘flexible instrument’ and this has been time and again resisted as not an acceptable definition. This albeit, the main driving force of an f.o.b. contract is the recognition by the seller to deliver the products at his own expenses, ‘free on board’ of the vessel for delivery to the buyer. Thus, f.o.b. contract has some special features. For instance, save that there is a contract, to that effect; a seller under an FOB contract is no way concerned to get a shipping berth for the products sold or to insure the product. In case , if he is requested or mandated to do the same , then cost of insurance and carriage will be normally passed to the account of the purchaser. Delvin J observed that An f.o.b. clause can be termed as a flexible instrument. In the classic type of f.o.b. contract, the buyer’s duty is to name the vessel, and the vendor’s duty is to place the products on the board of the vessel on account of the buyer and to get a bill of lading with a term that is usually is in existence in the trade. In such scenario, the vendor has become a party to the agreement of the voyage in any event till the time the seller obtains bill of lading in the purchaser’s name. Perhaps , the classic type is footed on the presumption that the vessel named will be accepting to load any products brought down to the vessel or perhaps those of which that has been notified. Under current scenario, when the space in the vessel is frequently booked upon in advance, the contract of carriage comes into subsistence at an advance point of time. Occasionally, the purchaser at the port of loading appoints his own forwarding agent to reserve space and to get the bill of lading. In such event, the vendor fulfills his obligation by placing the products on board of the vessel, then obtaining mate’s receipt and tendering to the agent of the vendor to facilitate him to obtain the bill of lading. The decision in the Pyrene case ascertains that a vendor can assume the responsibility of negotiating a contract of carriage instead of the buyer under an f.o.b. term. Thus, a court may find that parties, in fact, can close a contract under which a part of risks and costs is very different. Similarly, a f.o.b. or an Incoterm “D” term arrival contract might have concluded despite the other trade term like CIF might have been employed in the contract sale.( Burnett & Bath 2009 :62). In case of classic f.o.b. contract as described by Coin Delvin, the vendor makes a contract of carriage in lieu of a buyer where the vendor assumes additional obligations and where the situation demands him to enter into such a contract as is reasonable by giving prominence to the situation of the case and nature of the products sold. If the vendor fails to carry out those additional duties and if the products are damaged or lost during the voyage, the purchaser may either refuse or treat the delivery to the carrier to himself or claim pecuniary damages from the vendor. What is reasonable will be depending upon the each case. In such scenario, it will be very difficult to distinguish between the FOB contract in its ‘extended’ form and a CIF contract.” Question 2 A bank issues Letter of credit (LC) on behalf of a purchaser or applicant or importer to the vendor or beneficiary or exporter to make payment for goods or services provided that the vendor presents the documents that conform wholly to the stipulations and terms of the LC. As of now, all LC should be handled as per the International Chambers of Commerce norm that is referred as “Uniform Customs and Practice for Documentary Credits 2007 Revision UCP 600”. It is an upgraded version of UCP500 -1993, and they were introduced as early as in 1933 and this has been the sixth revision. “The main aim of the UCP 600 is to make a band of contractual regulations that may create homogeny in that exercise so that practitioners may not have to manage with a superfluity of frequently contradicting countrywide rules or regulations. The international acknowledgement of UCP by practitioners in various nations with an extensively judicial and economic system is an authentication to the regulations’ victory.” Twenty-five member nations consulting group have developed the UCP 600 which includes 400 members of the ICC national committees and ICC Commission on Banking Technique and Practice. It is to be noted that before a consensus text was reached, more than 5000 individual comments were considered. Some significant new provisions have been included in the UCP 600 on compliance, insurance and transport. (Branch: 53). UCP 600 sets out various kinds of bill of lading, which includes ocean / marine bill of lading, charter, inalienable sea-waybill, an air transport paper, rail, inland waterways transport paper, a multimodal transport document, postal receipt and courier receipt. For instance, in case of ocean or marine bill of lading, UCP 600 demand banks to acknowledge a document. However, it is named, which covers a port-to-port shipment. This could reduce the number of documentary rejections under UCP 600. (Klotz 2008:162). Article 16 of the UCP 600 is dealing with discrepancy document, notice and waiver. When a LC is not in conformity with instructions, an issuing bank may at its individual assessment approach the applicant for dispensation of the variances. Nonetheless, such waiver should be granted within five banking working days as per sub-article 14(b). If the issuing bank or a confirming bank resolves to decline to negotiate or honor, it ought to forward a one-time notice to the presenter to that cause. Thus, the information should be given by telecommunication method or by new swift ways not earlier than the completion of the five bank working day immediately succeeding the date of the production. This could reduce the number of documentary rejections under UCP 600. (Klotz 2008:127). Where a LC demand ‘indemnity against all perils',’ banks will accept an indemnity document that includes ‘all perils ‘clause or notation under UCP 600 whether or not having the title ‘all perils’. Further, even in case where insurance documents do mention that certain perils are not covered, banks will accept such LCs also under UCP 600. Further, where the LC is silent about the nature of insurance covered, the UCP will permit the banks to acknowledge the insurance documents which may have vague terms like ‘ customary risk’ or ‘usual risk’ as presented without any commitment for any perils not being covered and in such cases, the buyer acts at his risk. This could also reduce the number of documentary rejections under UCP 600. (Klotz 2008: 173). UCP 600 provides that if the final day for presentation of documents happens to be on holiday, then the presentation of documents may be made on the next working day of the bank. This could also reduce the number of documentary rejections under UCP 600 (Klotz2008:173). “Banks will acknowledge as originals under the UCP 600 ‘any document having a perceptible original signature, label, stamp, and mark of the issuer of the document, unless there is an indication in the paper itself that such documents are duplicate. Unless a paper signifies differently, a bank may have to acknowledge a paper as not duplicate if it seems to be typed, printed, stamped or perforated by the hand of the issuer of document or seems to be from the issuer’s office stationery.” Where many numbers of copies are to be submitted, one original and copies can be accepted by the bank. This could also reduce the number of documentary rejections under UCP 600. (Klotz: 2008:134). Under UCP 600,” the date of shipment or the date of loading” on board shall be construed as the “date of issue of bill of lading.” In all other remaining instances, loading on board of a named ship shall be corroborated by a noting or a notation “on the bill of lading “which exhibits the day on which the merchandises have been loaded on the vessel"” and in such cases, the day of shipment will be held to the day on which board notation has been made. This could also reduce the number of documentary rejections under UCP 600. (Klotz 2008: 134). Question 3 According to Scrutton J, “a c.i.f. contract is a sale of documents “pertaining to merchandise and is differing from the contract of sale of goods. Scrutton made his observation in clear terms in Arnold Karberg & Co v Blythe, and in Green Jourdine & Co2 that the commitment was on receipt of the contract price, the vendor has to forward documents like” bill of lading, which is a document of ownership.” Thus, in a c.i.f. contract, the delivery or dispatch of bill of lading is of crucial in nature when merchandise is lost in a voyage but there had been delivery of shipping documents. Thus, the privilege to reject the merchandise can be differentiated from that of right to reject the documents. When the documents are delivered, the right to reject the documents arises. When the purchaser or bank which approves a LC for payment of the price takes up such a LC even when such a LC is with a defect and makes payment to it without any demur, then the right to reject the documents is lost. The documentary feature of the c.i.f. transaction paves to the exchange of documents for merchandise in so many aspects that it may also pave to the decision that the exchange or substitution is meant to be complete. The great English commercial judge, Lord Scrutton advocated that many of the intricacies emanating from c.i.f. contracts could be solved if the c.i.f. sale were interpreted as a sale of documents pertaining to the merchandise and not as a sale of goods. According to Scrutton, the purchaser, in a c.i.f. contract buys documents and not the merchandise. However, Lord Scrutton’s view on the above lines was objected by other English judges in the same case who enumerated the c.i.f. contract as an ‘agreement for the sale of merchandise to be performed by the delivery of documents. However , in Marbre Saccharine Co. v. Corn Products Co3, McCardie,J concurred with Scrutton that commitment of the seller is to deliver the documents rather than merchandise and rather than physical property represented thereby. It is to be noted that in Malmberg v Evans & Co4 , Scrutton retorted to reprimand Bankes and Warrington by emphasising that “I need not deliberate what maybe is a just question of words, whether that sale is of documents or merchandise. One of the salient features of a sale c.i.f. is that, for want of unique terms, the vendor claims payment against delivery or presentation or dispatch of shipping documents. Thus, according to Scrutton, the documents assume certainly the shipment of merchandise to which they connote. However, there is one concrete scenery in which the vendor may execute his c.i.f. contract by presenting the documents despite the fact that the merchandise has not been shipped. This is the case where the buyer acknowledges admitting a received-for-shipment bill of lading which expresses that merchandise are in the safekeeping of ship owner and are in anticipation of shipment on the board of a vessel which may or may not be named yet. This definitely corroborates the Scrutton statement that c.i.f. is a contract of delivery of documents but not delivery of merchandise. Further , it is well recognised that if , after shipment , the merchandise is lost during the voyage , the vendor may present shipping documents and insist or demand for payment even under scenario where he comprehends at the time of the transfer that merchandise has been lost in transit. This has been laid down in the Manbre Saccharine Co. v. Corn Products Co 5 and in Smith Co. v. Marano6. This type of contract makes sense since it is the purchaser who has acknowledged to admit the risk of loss of the merchandise as his interest is safeguarded by insurance. (Berman and Kaufman 1978: 237-243), Thus, according to McKendrik Evan, Scrutton was of the strong view that c.i.f. contract is a none other than a contract of sale of documents rather than a sale of merchandise.(McKendrik 2000:648) Thus , Scrutton observed in Arnold Karberg & Co , “I am of the strong view that the key to the many of the intricacies emanating in c.i.f. contracts is to bear in mind the principal differentiation that a c.i.f. sale is not a sale of merchandise but sale of documents pertaining to such merchandise. Thus , a purchaser in a c.i.f. contract purchase the documents and not the merchandise and it may be under the stipulations of insurance contract and affreightment, as he purchases no insurance for damage that has happened to the merchandise.” .(McKendrik 2000:388) Question 4 The given problem covers the following issues namely; What will be the date of shipment for the purpose of insurance cover? Whether part shipment or leeway shipment is allowed under UCP 600? Who has to bear the loss sustained due to the damages to the products before the date of shipment? Whether the buyer can repudiate the payment that price of the product sold has gone down under irrevocable terms of contract? I will advise Jade Dragon as follows: The UCP 600 allows banks to accept insurance documents, which include vague conditions such as ‘customary risks’ or ‘usual risks’ as presented, without liability for any perils not being covered. In such scenario, if the agreement is silent on the nature of insurance needed, banks will normally acknowledge the insurance documents as presented, without any responsibility for any perils not being covered. A dishonest vendor could under such a scenario sign up insurance subject to a large deductible at the purchaser’s peril. (Klotz 2008:173). In the given case, Alpha Traders engaged Safeshippers Co as carriers and entrusted the first consignment of the soya bean meal measuring 6,500 tonnes in the first week of November 2007. On 13th November, while the cargo was being loaded on board the vessel American Pride I, a fire broke out on the quay side destroying about 300 tonnes of the soya bean meal. It resulted in substantial delays in the loading process. The balance of the cargo was loaded and a bill of lading dated 14th November 2007 was issued for 6,200 tonnes of the soya bean meal with the remarks "some bags of the soya bean meal which was broken while containing the fire had to be sewn up". Clause 53 of the terms of the contract between Alpha Traders and Jade Dragoon stated that, "clean bills of lading shall be presented by the sellers as proof of shipment". Shipper issued for 6,200 tonnes of the soya bean meal with the remarks "some bags of the soya bean meal which was broken while containing the fire had to be sewn up". It didn't say if the cargo was damaged for any reason. Hence, this forms a ‘foul’ bill of lading and not a “clean bill of lading.” Majority of the LC will demand for a clean bill of lading to be presented. The paying banker can reject the LC on the ground it is a foul bill of lading as it has not mentioned about the damage to cargo by fire. (Klotz 2008:82). Hence, in this case, the banker may not effect payment to the seller Alpha Traders, unless the LC is amended or ratified as foul bill of lading. Under UCP 600, if under a LC, if particular quantities are needed per shipment, then a vendor can have a quantity tolerance of five percent from the invoice or up to ten percent if the contract contains an expression “about” unless the purchaser has negotiated otherwise. If the vendor makes a part delivery or to make a leeway on shipments, this should be specifically discussed, and consensus should be arrived at. If the buyer is reluctant to take delivery of any other quantity but the specific contracted quantity in one delivery, it should be discussed and included in the form of warranty. Else, the purchaser may receive only ninety-five percent or even 105% of the contracted quantity. (Klotz: 77). If there is a provision in the contract between Alpha Traders and Jade Dragoon, that part delivery or leeway delivery is allowed, then bankers will accept the LC without modification. If there is no mention about such part delivery or leeway delivery, then bankers will ask for amendment or ratification. Further under UCP 600, a vendor can have a quantity tolerance of five percent from the invoice or up to ten percent if the contract contains an expression “about” unless the purchaser has negotiated otherwise. In this case, I assume that there is five percent quantity tolerance mentioned in the contract between Alpha Traders and Jade Dragoon, and then the bank will honor the LC, otherwise they will not, unless there is an amendment or ratification towards this. Further, the bill of lading dated 14th November 2007 was issued for 6,200 tonnes of the soya bean meal with the remarks "some bags of the soya bean meal which was broken while containing the fire had to be sewn up". On 13th November, while the cargo was being loaded on board the vessel American Pride, I, a fire broke out on the quay side destroying about 300 tonnes of the soya bean meal. Clause 52 of the terms of the contract stated that, "the bill of lading shall be conclusive evidence of the date of shipment". Under UCP 600 Article 28 (e) ,banks will not acknowledge an insurance document which is having a date of issuance not shortly after the day of shipment, except it seems from the indemnity policy that insurance coverage is effectual at the earliest from a day not afterward than shipment.(Klotz 2008:173). Hence, Jade Dragoon may not cover the reimbursement from an insurance company for the 300 tonnes of soya beans as the fire occurred on 13th November, and bill of lading was dated 14th November 2007. Unless if Alpha traders have covered transit insurance from his warehouse till the sea rails, then recovery of loss of 300 tones of soya beans will not be possible. The buyers, Jade Dragoon, have now rejected the bill of lading dated 14th November 2007 on grounds that it was not "good tender" and instructed the banks accordingly. However, if there is an adequate recital in the contract for 5% lesser or higher materials with Alpha Traders, then Jade Dragon cannot repudiate the bill of lading dated 14th November 2007. The sub-buyers in Hong Kong have now rejected the bill of lading dated 28th November. The sub-buyers cannot repudiate the bill of lading dated 28th November if there is an adequate recital in the contract for the part shipment or leeway shipment. In an export or import contract, the basic recital will be as follows: WHEREAS the Vendor is engaged in the manufacture and sale of products or goods or services. AND WHEREAS the purchaser wishes to tender an irrevocable firm commitment to purchase (goods) in the quantities and at prices, times and conditions and terms espoused upon hereafter; Further, the commercial risk in the international contract is usually solved by the employment of an irrevocable, confirmed letter of credit to ensure the payment. Hence, Jade Dragon cannot reject or repudiate the purchase contract entered with Alpha Traders on the ground that the price of the soya bean meal has started to go down dramatically in Hong Kong and Taiwan. Question 5: The nature of c.i.f. contract under which the shipping documents symbolise the merchandise which indicates that there can be instances in which particulars of shipment are not decided in the contract of sale, that is the details like where the seller sources or obtains the merchandise which is already in ‘goods afloat” or “ goods in transit.” In such scenario, a vendor under a CIF contract has the choice either to facilitate shipment of the merchandise in a vessel selected by the buyer or to purchase the merchandise afloat. As far as the purchaser is concerned, the seller is accountable for any insurance or freight as well as delivery of the merchandise at the port of destination. (Burnett & Bath 2009:71). The bill of lading in a c.i.f. contract performs three functions. BL is the authentication for receipt of merchandise, as an evidence for the existence of the contract of carriage and also has the characteristics of document of title to the goods. Thus, the bill of lading along with insurance cover must offer nonstop coverage in the logic that the party to whom a negotiable bill of lading is conveyed while the merchandise is afloat must be ensured that if there is a loss or damage to the merchandise during the main voyage that party will have a privilege of recourse against the insurer or carrier. (Burnett & Bath 2009:97) In Saunders Bros v. Maclean & Co7 , it was held that the bill of lading is the vital document to claim the merchandise themselves. In E Clemens Horst Co v Biddell Bros8, it was held that while the merchandise is afloat, the delivery of the BL will be construed as delivery of the merchandise itself. In this way, the privilege to possession is being passed from one legal owner to another, where the subsequent purchaser or bank, while the merchandise are still in the possession of the carrier or afloat. (Burnett & Bath 2009:105). As per Incoterm 2000, CIF A4, under a c.i.f. contract, a vendor has to deliver the merchandise on board of the vessel at the port of shipment mentioned in the contract. In case, there is an unexpected export embargo, then the seller has to make alternate arrangements for the delivery of the merchandise. As a result, the vendor may be under pressure to buy afloat. The general rule under English law is that the vendors will normally not be discharged in such scenario, by the common law doctrine of frustration as a c.i.f. seller is , in principle ,is anticipated to perform either by delivering the merchandise of the contractual description or by purchasing such merchandise already afloat and appropriating them to the contract. In Tradax Export Corp. v.S.T.M Grain Ltd9 , it was held that general rule that a c.i.f. vendor who was thwarted from shipping merchandise must purchase afloat did not arise where the exercise of such a rule would jack up the prices acutely to the unheard of levels.( Brunner 2009:333). As held in Hindley and Co Ltd v East Indian Producer Co Ltd10 , t is possible for the vendor to contract on c.i.f. terms for merchandise that are already afloat. This may happen in a number of styles namely. The vendor might have shipped the merchandise prior to the sale on the hope to identify buyers while merchandise on the high seas. In another parlance, ship is regarded as a floating storehouse or warehouse. This is usually found in grain and oil trade. Vendors prefer this modality as they may be benefited from the price fluctuations. As held in Hindley and Co Ltd v East Indian Producer Co Ltd11, the vendor might have purchased the merchandise from a third party. In “Comptoir d’ Achat et de Vente Boerenbond Belge SA v Luis Ridder Limitada (The Julia)”, Lord Porter opined that the main intention and objective of a c.i.f. contract is to facilitate buyers and sellers to deal with merchandise or parcels afloat and to transfer them without any riders from hand to hand by giving constructive possession of the cargoes which are being dealt with. (Carr and Stone2005:9). “In Pl van der Zijden Wildhandel NV v Tucker and Cross Ltd”12 , a vendor may allocate to the contract cargoes from a bulk that he has earlier shipped, or he may purchase merchandise that are already under afloat from a third party and allocate them to the contract. Allocation of merchandise generally found in oil and coffee trade, which is subject to wide fluctuations in price. . (Carr and Stone2005:14). Question 6 Bill of Lading Act 1855 has been replaced with new provision namely “Carriage of Goods by Sea Act 1992” with respect to bills of lading and other shipping papers, which came into force from 16 September 1992. Some of the special features of the 1992 Act are enumerated hereunder; The 1992 Act transfers and vests to the holder of the shipping documents with “all privileges of a lawsuit under the contract of carriage as laid down in the East West Corp13. In Leduc & Co. v. Ward, in a voyage, the carrier deviated to Glasgow and sunk with merchandise. The shipping company tried to rely on an excepted risk clause, exonerating it from legal responsibility for risks of the sea but would have been not able to do so as she strayed from the route explained in the carriage contract. Carrier contended that the seller aware well before the carriage contract was signed that it was planned to sail to Glasgow, and in effect, that deviation was authorised by the contract. It was held by House of Appeal that the endorsee was not bound by pre-contract agreement who relied on bill of lading terms. Conditions in BL did not authorise any deviation and by straying the shipping company lost the advantage of the excepted risk clause. It is to be observed that the above decision was based on the wording of 1855 Act and the decision would be different if 1992 Act is applicable as the 1992 Act wording is different from that of 1855 Act. (Dockray & Thomas: 118). Liability Transmission under the 1992 Act The 1992 Act states that financial obligation under shipping documents passes to the holder of the document only when the holder demands or takes delivery or advances a claim under the contract. Although, it was intended to mirror the wider aspect of previous law, this part of the Act was new. House of Lords considered the new provisions for the first time in the Borealis AB v Stargas Ltd, The Berge Sisar14. (Dockray & Thomas: 120). In this case, Borealis purchased liquid propane from Stargas and arranged the Berge Sisar, the carrier, to transport the propane from Saudi Arabia to Sweden. On arrival at Sweden, it was found contaminated and the merchandise was delivered to Dow. Under the terms of 1992 Act, Bergesen, the ship owners claimed damages for cost of cleaning the ship from the Stargas and from Borealis. It was held that Borealis was liable when they received the endorsed bills of lading from Stargas. It was submitted by the Ship owners Bergeson, since Borealis was already liable, and they are also liable subsequently also under section 3 (1) of the Act despite that they had endorsed the bills to Dow. (Dockray & Thomas: 120). Thus, the 1992 Act contains a separate provision for the liabilities and the rights of a bill of lading holder. As per section 2(1) of the 1992 Act, right to enforce the contract arises to the lawful owner of the “bill of lading” and the transfer of this right eliminates the privilege of earlier holders to do so. Thus, holder of a BL can sue and can recoup damages in support of another with an interest in merchandise as laid down in section 2(4). (Dockray & Thomas: 120). “Carriage of Goods by Sea Act 1992” ignores the charter parties and offers more emphasis on documents like a sea waybill or a bill of lading that evidence the contract of carriage. The 1992 Act has advantages like predictability and stability and does not permit conflicting interpretation. The 1992 Act making the English law into the same line with international laws and laws of foreign jurisdictions and making the way for its growth into the twenty-first century. Normally, under f.o.b. or c.i.f. contract, the purchaser assumes the peril of loss no sooner the merchandise was loaded on to the vessel’s deck, even if the contract is entered after the shipment. Nonetheless, the purchaser under modern flexible f.o.b. contract or c.i.f. contract is not a party to a “contract of carriage” and under the general law, has no contractual privilege against the vessel or ship if the merchandise damaged or lost. It is to be noted that 1855 Act attempted to find a solution to the issue by awarding the right to the buyer to sue on the contract. However, limited interpretation and restrictive drafting destabilised its efficiency. The decisions in the cases like in Aramis15 and in the Aliakmon16 corroborated that it was ill-conceived to contemporary trading practices like employment of documents other than” bill of lading “and in the case of bulk carriage. However, the 1992 Act has taken care of all the disadvantages and deficiencies that were present in the earlier law namely “Bill of Lading Act 1855.” “The Carriage of Goods by Sea Act 1992” has safeguarded the rights of the suit in relation to the carriage of goods by sea. List of References Berman and Kaufman. (1978). The Law of International Commercial Transactions. New York: Lex Mercatoria. Bradgate, Robert & White, Fidelma. (2007). Commercial Law. Oxford: Oxford University Press. Branch, Alan E. (2008). Global Supply Chain Management and International Logistics. New York: Taylors and Francis. Brunner, Christoph. (2009). Force Majeure and Hardship Under General Contract Principles. London: Kluwer Law International. Burnett Robin & Bath Vivienne. (2009). Law of International Business in Australia. Sydney: Federation Press. Carr Indira & Stone Peter. (2005) International Trade Law. London: Routledge Taylor and Francis Group. Dockray Martin & Thomas, Katherine Reece. (). Cases & Materials on the Carriage of Goods by Sea. London: Routledge Taylor and Francis Group. Klotz, James M. (2008). International Sales Agreements. An Annotated Drafting and Negotiating Guide. New York: Kluwer Law International. McKendrick Evan. (2000). Sale of Goods. London: Informa Finance. Read More