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Drughorn [1919]


  • 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


  • 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


  • Yes


  • Signing oneself as a ‘charterer’ is not incompatible with the doctrine of undisclosed agency
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