8.1 This book has examined cargo claims from the perspective of the contract of carriage, usually contained within a bill of lading. Cargo claims may also arise under the terms of a charterparty. This may be because cargo interests choose to bring a claim under a voyage charter, with liability then flowing up the charter chain to the head owner. Alternatively, a shipowner incurring a claim under a bill of lading might seek to pass the liability down the charter chain.