Transgrain Shipping (Singapore) PTE Ltd v Yangtze Navigation (Hong Kong) Co Ltd & Anor [2016] EWHC 3132 (Comm) (07 December 2016)

Transgrain Shipping (Singapore) PTE Ltd v Yangtze Navigation (Hong Kong) Co Ltd & Anor [2016] EWHC 3132 (Comm) (07 December 2016)

The word 'act' in clause 8(d) of the ICA 1996 means any act, whether culpable or not, and does not require proof of fault; the ICA's scheme is for mechanical apportionment of liability without regard to fault.

Citation
[2016] EWHC 3132 (Comm)
Parties
Claimant/respondent in the Arbitration/charterers: TRANSGRAIN SHIPPING (SINGAPORE) PTE LTD; Defendant/claimant in the Arbitration/owners: YANGTZE NAVIGATION (HONG KONG) CO LTD
Jurisdiction
England and Wales
Judgment Date
07 December 2016
Procedural Posture
Appeal From Arbitration Award / Judgment After Hearing
Outcome
Appeal dismissed
Legal Topics
Charterparty, Cargo Claims, Inter Club Agreement, Contract Interpretation

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Parties

TRANSGRAIN SHIPPING (SINGAPORE) PTE LTD

Claimant/respondent in the Arbitration/charterers

YANGTZE NAVIGATION (HONG KONG) CO LTD

Defendant/claimant in the Arbitration/owners

Procedural Posture

Appeal From Arbitration Award / Judgment After Hearing

  1. 1 Whether 'act' in clause 8(d) of the Inter-Club Agreement 1996 requires culpability or includes any act regardless of fault

Ratio Decidendi

The word 'act' in clause 8(d) of the ICA 1996 means any act, whether culpable or not, and does not require proof of fault; the ICA's scheme is for mechanical apportionment of liability without regard to fault.

Court Disposition

Appeal dismissed

Orders

  • The tribunal's construction of 'act' in clause 8(d) of the ICA is upheld.
  • No order as to further relief.