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"TBOOK APPROVED" AND ITS CONSEQUENCES

Lloyd's Maritime and Commercial Law Quarterly

“TBOOK APPROVED” AND ITS CONSEQUENCES

Robert Gay*

1. The Rowan

The judgment in The Rowan 1 considers2 the interpretation of an oil major approvals clause employing the phrase “tbook approved”, which is now frequently used in the chartering market. The judgment gives recognition to an aspect of the current system of approvals which (as far as the writer is aware) had not previously been dealt with by the courts.3 It will be submitted that such recognition is entirely right and proper. However, the interpretation which the court gave to the phrase “tbook approved” had the effect of converting an undertaking by the owners of Rowan about such approval letters into an undertaking about the condition of the vessel. It will be suggested that an alternative interpretation should be preferred.
* Solicitor, Hill Dickinson LLP; member of the Documentary Committee of Intertanko.
2. Ibid, [29–40]; see also [26] and [67].
3. Dolphin Tanker Srl v. Westport Petroleum Inc (The Savina Caylyn) [2010] EWHC 2617 (Comm); [2011] 1 Lloyd’s Rep 550 concerns a clause which defined “a vetting review/inspection” as “a nomination by the Charterer to an oil major and the oil major reviewing the vessel… ”, and therefore related to formal approvals rather than to the system of informal letters explained below.
LLOYD’S MARITIME AND COMMERCIAL LAW QUARTERLY

466

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