Rosewood Trucking Ltd. v Balaam

Rosewood Trucking Ltd. v Balaam

The claimant's payment to P&O was made under a private contract and not in compliance with the provisions of the CMR; therefore, the claimant is not entitled to recover from the defendant under Article 37. The CMR regime is self-contained and does not allow recovery for contractual indemnities outside its express terms.

Parties
Claimant/appellant: Rosewood Trucking Ltd; Defendant/respondent: Brian Balaam
Jurisdiction
England and Wales
Judgment Date
04 November 2005
Procedural Posture
Civil Appeal / Appeal From High Court to Court of Appeal
Outcome
Appeal dismissed
Legal Topics
Carriage of Goods by Road, Successive Carriers, Indemnity and Contribution, Interpretation of International Conventions

Case Brief

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Parties

Rosewood Trucking Ltd

Claimant/appellant

Brian Balaam

Defendant/respondent

Procedural Posture

Civil Appeal / Appeal From High Court to Court of Appeal

  1. 1 Whether payment by a sub-contractor to a main contractor under a private contract constitutes 'compensation in compliance with the provisions of the Convention' under Article 37 of the CMR, entitling recovery from the carrier responsible for the loss.

Ratio Decidendi

The claimant's payment to P&O was made under a private contract and not in compliance with the provisions of the CMR; therefore, the claimant is not entitled to recover from the defendant under Article 37. The CMR regime is self-contained and does not allow recovery for contractual indemnities outside its express terms.

Court Disposition

Appeal dismissed

Orders

  • Appeal dismissed
  • Costs assessed in the sum of £5,750