Taxfield Shipping Limited v Cargo Currently Laden on Board the MV New Market and Others (AC29/06) [2006] ZAWCHC 16; 2006 (5) SA 114 (13 April 2006)

Taxfield Shipping Limited v Cargo Currently Laden on Board the MV New Market and Others (AC29/06) [2006] ZAWCHC 16; 2006 (5) SA 114 (13 April 2006)

The applicant, as owner of the vessel, retains locus standi as no valid assignment of rights to Asiana Marine Inc was effected. The terms of the charterparty, including the lien clause, are incorporated into the bill of lading by general reference, despite the omission of the charterparty date. The applicant is...

Source-derived case information.

Citation
[2006] ZAWCHC 16
Parties
Applicant: Taxfield Shipping Limited; Respondent: Cargo Currently Laden on Board the MV New Market; Respondent: Parmex Limited; Respondent: Ibeto Cement Company Limited; Respondent: Access Bank Plc; Respondent: Asiana Marine Inc
Court
Western Cape High Court, Cape Town
Jurisdiction
South Africa
Case Number
AC29/06
Procedural Posture
Urgent Application / Application to Set Aside Arrest of Cargo
Outcome
Application granted; arrest of cargo set aside; costs awarded against second and third respondents.
Judges
B M Griesel
Legal Topics
Possessory Lien, Incorporation of Charterparty Terms, Arrest in Rem, Admiralty Jurisdiction, Impossibility of Performance
Admiralty and Maritime Possessory Lien Incorporation of Charterparty Terms Arrest in Rem Admiralty Jurisdiction Impossibility of Performance

Source-derived case record

Summary, issues, holding and outcome

More case intelligence is available

Unlock the full research layer for this judgment.

Downloadable case file Legal principles 4 Authorities cited 7 Party arguments 2 Amounts and remedies 1
Sign in to unlock

Parties

Taxfield Shipping Limited

Applicant

Cargo Currently Laden on Board the MV New Market

Respondent

Parmex Limited

Respondent

Ibeto Cement Company Limited

Respondent

Access Bank Plc

Respondent

Asiana Marine Inc

Respondent

Procedural Posture

Urgent Application / Application to Set Aside Arrest of Cargo

  1. 1 Whether the applicant has locus standi to bring the application.
  2. 2 Whether the applicant is entitled to exercise a possessory lien over the cargo.
  3. 3 Whether the arrest of the cargo should be set aside due to impossibility of performance.

Ratio Decidendi

The applicant, as owner of the vessel, retains locus standi as no valid assignment of rights to Asiana Marine Inc was effected. The terms of the charterparty, including the lien clause, are incorporated into the bill of lading by general reference, despite the omission of the charterparty date. The applicant is entitled to exercise a possessory lien over the cargo for amounts due under the charterparty and for damages. The impossibility of discharging the cargo in Cape Town further supports the setting aside of the arrest. The respondents' counter-application for discharge in Durban is only relevant if the arrest is upheld, which is not the case. Accordingly, the arrest of the cargo is...

Court Disposition

Application granted; arrest of cargo set aside; costs awarded against second and third respondents.

Orders

  • The arrest of the first respondent cargo is set aside.
  • The second and third respondents jointly and severally are ordered to pay the costs of the application.