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“European Enterprise” Browner International Ltd. –v- Monarch Shipping Co. Ltd.

7th Apr 1989

[1989] 2 Lloyd’s Rep. 185

Charles Priday – Carriage by sea – Limitation of liability – Damage to goods – Goods carried subject to consignment note and partial incorporation of Hague-Visby Rules – Limitation provisions in consignment note less generous than Hague-Visby Rules – Whether provisions invalidated – Whether “carrier” in art. IV, r. 5(e) referred only to carrier or included carrier acting through his agents or servants – Hague-Visby Rules, art. IV, r. 5, – Carriage of Goods by Sea Act, 1971 s. 1(6)(b).

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