Facts
- The manager for a company chartered a ship on his own behalf, signing himself as the ‘charterer’
- The ship owners unlawfully terminated the charterparty
- The manager died before the trial
Issue
- Could the claimant company, for whom the deceased manager worked for, take the place of the claimant manager in the trial as undisclosed principals to the charterparty
Decision
- Yes
Reasoning
- Signing oneself as a ‘charterer’ is not incompatible with the doctrine of undisclosed agency