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J.H. Rayner and Company, Limited v. Hambro’s Bank, Limited
England and Wales High Court of Justice, King's Bench Division
1 KB 37 (1943)
Hambro’s Bank Ltd. (Hambro) (defendant) issued a letter of credit in favor of J.H. Rayner and Company (Rayner) (plaintiff). The letter provided that payment would be made upon presentment of shipping documents to Hambro, including an invoice for Coromandel groundnuts. Rayner presented the required documents to Hambro, including an invoice for machine-shelled groundnut kernels. In the margin of the invoice was the marking “C.R.S.” Hambro refused to make payment on the letter, because the invoice presented did not match the letter of credit. Rayner brought suit for breach of contract, arguing that C.R.S. meant Coromandel and that it was understood by traders that machine-shelled groundnut kernels were the same good as Coromandel groundnuts. The trial court entered judgment for Rayner, and Hambro appealed.
Rule of Law
Holding and Reasoning (Mackinnon, J.)
Concurrence (Goddard, J.)
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