Lloyd's Maritime Law Newsletter
Carbotrade SPA v Bureau Veritas (The “Star of Alexandria”) - US Court of Appeals (2nd Circuit)(Van Graafeiland, Walker and Leval Ct JJ) - 31 October 1996
Conflict of laws - Head charterers allegedly sustaining loss as a result of classification society’s negligent inspection -Whether United Kingdom law or Greek law to be applied
The vessel
Star of Alexandria
was owned by Caribene Investments Ltd (a corporation organized under the laws of Gibraltar) and registered in the United Kingdom
dependency of Gibraltar. She was managed by a company with offices in Greece. In February 1989 the shipowners chartered the
vessel to the plaintiffs (an Italian corporation carrying on business in Italy), who sub-chartered her to a New Jersey partnership.
On 17 April 1989 the vessel sank in international waters while
en route
to New Jersey from Greece.