Berisford Metals Corpn. v. S/S Salvador and A/S Ivaram Rederi (The Salvador) - U.S. Ct. of Appeals for the Second Circuit (Friendly, Mansfield and Winter JJ.) - 16 December 1985

Package limitation - Whether carrier entitled to rely on COGSA provision, having issued false bill of lading

On 23 June 1983 B contracted to purchase from P, a company in Brazil, 50 metric tons of grade A tin ingots in bundles at a price of $13,140 per metric ton. The terms were f.o.b. vessel at Santos, Brazil for shipment to New York in January 1984, payment to be made net cash 45 days after ocean bill of lading date against presentation of a “full set of shipping documents”, which was understood by the parties as required a clean on board bill of lading.