Lloyd's Maritime and Commercial Law Quarterly
WHEN IS A BENEFIT TO A BILL OF LADING HOLDER COLLATERAL?
Helen Morton*
Anthony Kennedy†
The Doric Valour
In The Doric Valour,1 the Court of Appeal had to determine whether the holder of a bill of lading, when making a claim against a shipowner for damage to cargo occurring during the voyage, must give credit for a payment received from the seller of the damaged goods.
That question arose from the following facts. The first claimant, Ameropa, purchased a cargo of soybeans and entered into a voyage charter dated 7 July 2020 from Louisiana to
* Barrister, Essex Court Chambers.
† Lecturer in Commercial Dispute Resolution at BPP Law School; barrister.
1. AMS Ameropa Marketing and Sales AG and Another v Ocean Unity Navigation Inc (The Doric Valour) [2024] EWCA Civ 1312; [2025] Lloyd's Rep Plus 28, [1].
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