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Deviation


Shipowner’s Liability as a Common Carrier
Last updated: 06-Oct-2014

Internationale Guano En Superphosphaat-Werken v Robert MacAndrew & Co. [1909] 2 KB 360 per Pickford J at p 366:

That still leaves a serious question to be decided, and that is this: whether as common carriers they are responsible for the damage in this case, it being alleged that it was occasioned by the inherent vice and the nature of the goods themselves. Now, common carriers, as I take it, are not liable for damage due to the nature of the thing carried so long as they perform their voyage with reasonable despatch under all the circumstances which they have to encounter. I think that until the deviation in this case the defendants did perform voyage with reasonable despatch.


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