Meaning of dunnage

8.1 As used in this clause, dunnage means the wood, battens, mats and any other material necessary to ensure that the stow is tight and secure in the holds, that adequate ventilation passages exist, where the type of cargo so requires, and that the cargo is not damaged by condensation or by contact with the ship or with other cargo. Precisely what materials and appliances are included in the expression is a question of fact. In Wye Shipping Co. v. Cie. du Chemin de Fer ParisOrleans,1 the question arose whether the expression “dunnage”, in a clause similar to that at present under consideration, included shifting boards, and McCardie J. summarised his views as follows: