PARTENREEDEREI M/S “HEIDBERG” AND VEGA REEDEREI FRIEDRICH DAUBER v. GROSVENOR GRAIN AND FEED CO. LTD., UNION NATIONALE DES COOPERATIVES AGRICOLES DE CEREALES AND ASSURANCES MUTUELLES AGRICOLES (THE “HEIDBERG”)

[1994] 2 Lloyd's Rep. 287

QUEEN’S BENCH DIVISION(COMMERCIAL COURT)

Before His Honour Judge Diamond, Q.C.

Bill of lading - Incorporation - Arbitration clause - Vessel chartered for carriage of grain - Vessel collided with jetty and fire broke out on board - Cargo damaged - Claim by cargo interests - Whether amended Centrocon arbitration clause incorporated into bill of lading. Conflict of laws - Proper law - Bill of lading - Incorporation of arbitration clause - Dispute between owners and cargo interests - Owners brought action in France - French Court decided arbitration clause not incorporated - Whether Court bound by Brussels Convention to recognize French decision - Whether question of incorporation to be determined by English or French law.