Eitzen Bulk A/S v TTMI Sarl

Eitzen Bulk A/S v TTMI Sarl

The words 'price actually paid' in clause 15 of the SHELLTIME 4 form mean the price paid when the bunkers were stemmed, as supported by paid invoices to the bunker suppliers, assessed on a first-in-first-out basis. The clause does not provide for reimbursement of the price paid by the party seeking payment, nor does estoppel arise on the facts.

Parties
Claimant: Eitzen Bulk A/S; Defendant: TTMI SARL
Jurisdiction
England and Wales
Judgment Date
14 February 2012
Procedural Posture
Commercial Arbitration Appeal / Judgment on Appeal Under S.69 Arbitration Act 1996
Outcome
Appeal dismissed; Award upheld
Legal Topics
Charterparty Interpretation, Bunker Price Calculation, Estoppel, Contract Construction

Case Brief

Summary, issues, holding and outcome

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Parties

Eitzen Bulk A/S

Claimant

TTMI SARL

Defendant

Procedural Posture

Commercial Arbitration Appeal / Judgment on Appeal Under S.69 Arbitration Act 1996

  1. 1 Proper construction of 'price actually paid' in clause 15 of SHELLTIME 4 form
  2. 2 Whether clause 15 provides for reimbursement or price paid when bunkers were stemmed
  3. 3 Whether estoppel applies to prevent TTMI from disputing Eitzen's construction

Ratio Decidendi

The words 'price actually paid' in clause 15 of the SHELLTIME 4 form mean the price paid when the bunkers were stemmed, as supported by paid invoices to the bunker suppliers, assessed on a first-in-first-out basis. The clause does not provide for reimbursement of the price paid by the party seeking payment, nor does estoppel arise on the facts.

Court Disposition

Appeal dismissed; Award upheld

Orders

  • Appeal by Eitzen dismissed
  • Award of the Tribunal upheld