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The Bill of Lading contract and the transfer of property under Greek, English and United States law

Georgios I. Zekos (Attorney at Law, Komotini, Greece)

Managerial Law

ISSN: 0309-0558

Article publication date: 1 October 1998

Abstract

Discusses the Bill of Lading and its differences under UK, US and Greek law. Bases the paper on the fact that, under UK and US law, property in the goods sold passes from seller to buyer when the parties intend to pass it (regardless of whether or not delivery actually took place); whereas, under Greek law, ownership of goods passes from seller to buyer only if the intention to pass goods is supported by actual delivery. Asserts that this difference in national law causes problems in international trade. Explores the law in more depth, citing a number of cases and quoting legal precedents. Concludes that the intention of the parties concerned should be taken into consideration.

Keywords

Citation

Zekos, G.I. (1998), "The Bill of Lading contract and the transfer of property under Greek, English and United States law", Managerial Law, Vol. 40 No. 5, pp. 5-28. https://doi.org/10.1108/03090559810770088

Publisher

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MCB UP Ltd

Copyright © 1998, MCB UP Limited