It is common for a charterparty to permit the owner or master of a vessel to release the cargo without production of the bill of lading on condition that the charterer supplies a letter promising to indemnify the owner against any liability arising from this action. Before providing such a letter to the owner of the vessel, the charterer will, in practice, obtain a letter of indemnity from the receiver of the cargo. The owner of the vessel and the charterer are parties to the charterer’s letter of indemnity, but the parties to the receiver’s letter of indemnity are the charterer and the receiver, so the issue raised by The

---

8