Lloyd's Maritime and Commercial Law Quarterly
NOTICE OF READINESS UNDER VOYAGE CHARTERS
The Happy Day
1. Introduction
The judgment of Langley, J., in the English High Court in The Happy Day
1
may become an important decision concerning the effect of owners tendering an invalid notice of readiness under voyage charters.
The decision in The Happy Day
may be said to have taken the result from the earlier decision in The Mexico I
2
one step further. In The Mexico I
the vessel tendered an invalid notice, when arriving at the port, because of the relevant cargo being overstowed. In that case the vessel waited for berthing for about two weeks and then commenced discharging of the cargo on top. When that operation was completed, the vessel waited for another fortnight until it commenced discharging for the relevant charterers. No further notices were tendered apart from the originally invalid one and therefore time was held not to have commenced at all during the whole of the period prior to commencement of discharge. Time did, however, commence to run at the time of commencement of
LLOYD’S MARITIME AND COMMERCIAL LAW QUARTERLY
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