Lloyd's Maritime and Commercial Law Quarterly

Edited by Professor Francis D Rose

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ARREST AND THE DUTY OF DISCLOSURE

The Varna

In The Varna,1 the Court of Appeal held, in somewhat unsatisfactory circumstances,2 that a person swearing an affidavit to lead warrant of arrest is no longer required to make full and frank disclosure of matters relevant to the arrest. The reason for this decision, which is contrary to the unanimous imposition of such a

1. [1993] 2 Lloyd’s Rep. 253.

2. Ibid., 254, per Scott, L.J.

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