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Universe Tankships of Monrovia v International Transport Workers Federation [1983]


  • The International Transport Workers Federation blacked the claimant’s ship and prevented them from leaving dock unless they signed new contracts for their employees


  • Had the new contracts been signed under duress


  • Yes, claim allowed, contracts were void


  • There are 2 elements to duress: pressure amounting to compulsion of will and illegitimacy of that pressure
  • No other practical choice constituted duress, even though signed contracts of own accord, therefore ‘consented’
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