Lloyd's Maritime and Commercial Law Quarterly
RETHINKING UNJUST ENRICHMENT, BAILMENT AND NECESSITY
Ken TC Lee* and Alvin W-L See**
The Kos
In The Winson,1 the House of Lords held that salvors who took steps to prevent deterioration of salved cargo after a salvage agreement had ended had “a correlative right to charge the owner of the goods with the expenses reasonably incurred in doing so”. The
* Pupil Barrister, Hong Kong.
** Lecturer in Law, Taylor’s University, Malaysia
The authors would like to thank Professor Lusina Ho of HKU and Mr David Martin-Clark for their helpful comments and encouragements. All views and errors remain our own.
1. China Pacific SA v. Food Corp of India (The Winson) [1982] AC 939, 961 (Lord Diplock). See also ibid, 963 (Lord Simon of Glaisdale).
CASE AND COMMENT
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