Bills of Lading Additional Information

While the Hague/Visby Rules contain no requirement for additional information to be incorporated into bills of lading, the parties themselves or their agents may include statements of fact which are capable of raising an estoppel in favour of future transferees for value of the bill. One such relevant fact is the date on which the bill was issued. Thus it was held in The Saudi Crown that where a master or other agent has been authorised to sign bills of lading on behalf of shipowners, this carries with it the authority to insert in the bill the date and place at which the bill was issued. The contract of sale in this case required the goods to be shipped under bills dated between 20 June and 15 July. Although loading was not in fact completed until 26 July, bills dated 15 July were issued on the faith of which the buyer authorised payment for the goods. When the goods arrived later than expected and the buyer had to acquire replacements in order to meet his existing commitments, he was held entitled to recover damages for misrepresentation from the shipowner. The shipowner’s argument, based on Grant v Norway that the agent had no authority to enter an incorrect date on the bill, was firmly rejected. ‘It cannot be said that the nature and limitations of the agent’s authority are known to exclude authority to insert the dates on the grounds that the ascertainment of the correct date is obviously quite outside the scope of the functions or capacities of those agents.’ In appropriate circumstances a similar estoppel might apply to statements in the bill as to the date on which the cargo was shipped.