The previous issue of this Quarterly contained a note on the decision of Paul Stanley KC in CE Energy DMCC v Bashar 1 (hereafter “Bashar”), concerned with the availability of actions for the price under s.49(2) of the Sale of Goods Act 1979 (hereafter “SGA 1979”). That subsection provides that a seller can bring an action for the price if “the price is payable on a day certain irrespective of delivery and the buyer wrongfully neglects or refuses to pay such price”. This is in addition to s.49(1), which provides that a seller can bring an action for the price if “the property in the goods has passed to the buyer and he wrongfully neglects or refuses to pay for the goods according to the terms of the contract”. Bashar concerned the proper interpretation of “day certain” in s.49(2). Since Bashar, Andrew Baker J has handed down judgment in Trans Trade RK SA v State Food Corporation of Ukraine 2 (hereafter “Trans Trade”), which also concerned the proper interpretation of s.49(2), albeit focused on the terms “irrespective of delivery”.3 Andrew Baker J held that the phrase “irrespective of delivery” meant that the obligation to pay the price could not be conditional on delivery. This note serves as a brief addendum to the previous note on Bashar, looking at how the judgment in Trans Trade has developed the law in this area. It explains how the approach to the interpretation of the section in Trans Trade departs from and improves on that in Bashar.