10 LUEDDEKE Carrier defences - Nautischer Verein zu Bremen ...

Nautischer Verein zu Bremen 10th SEMINAR 22.02.03 

Ladies and Gentlemen, 

Having listened to all my friends, I feel that there is some truth in the saying that “a 

conference can be best described as a happening where the confusion of one man 

is multiplied by the number of others present.” 

Carriage of Goods by Sea Acts lay out carriers’ and shippers’ defences and 

obligations for lost or damaged cargo. They apply to common carriage by sea and 

could also be adopted as the liability regime in service contracts. 

The acts have a list of defences available to carriers for lost or damaged cargo. 

They contain provisions regarding package limitation and the significance of 

statements in Bills of Lading, or statements setting out who is responsible and for 

what. 

We have seen the transition from the 19 th century liability system via the Harter Act 

of 1893 to the Hague Rules “catalogue of defences” and the “general liability clause” 

in the Hamburg Rules. 

Important is the so-called “q” clause, designed to ease the burden on the carrier by 

providing an excuse for negligence. 

The carrier can in order to establish non-responsibility, under the Hague Rules, try 

to rely on one of the seventeen exceptions. 

One of the cornerstones of the liability systems is the carrier’s possibility to avoid 

liability if the damage was caused by an error by the master or the crew in the 

navigation of the management of the vessel. 

This “error in navigation” exception created debates on definition and contradicts the 

otherwise unlimited concept of liability for acts and omissions by servants and 

agents. The definition of “error in navigation,” as compared to the duty to “man the 

vessel properly”, created a situation whereby the exception can be relied on without 

calling into question the vessel’s state of seaworthiness in relation to manning.

The ship-owner is liable as a carrier, provided there is no demise charter of the ship. 

I will refer further down to the JORDAN II, a case that recently decided that it was 

the charterer who was liable for cargo claims. 

Exception for fire damage 

The carrier can escape liability if he proves that the damage was caused by fire. 

The Hague Rules stipulate, however, that the fire damage exception is only valid if 

the carrier is not responsible for the fire. I will discuss this further down in the 

“EURASIAN DREAM”. 

The fire exception operates similar as one for acts and omissions by servants and 

agents. The rational for this privilege is because many fires on board of a ship are 

caused by the goods and the cause of the fire cannot easily be determined. 

One example is the obligation in respect of “peril of the sea”. The words used 

include the terms “peril of the sea” and “seaworthiness” and the obligation to prove 

that the vessel has satisfied the requirements requested for by the prevailing sea 

and weather conditions. 

It is suggested that it is required to prove that the vessel was seaworthy as a 

precondition if one wants to rely on a defence. 

Defences in case of damage 

Together with the two exceptions for acts and omissions by servants and agents 

(error in navigation and fire), the Hague Rules list other defences. These can be 

divided into four main categories: 

• irresistible and unpredictable forces 

• causes attributable to the cargo 

• attempts to save live; and 

• latent and hidden defects in the vessel. 

We now shall turn to some recent case law. 

Captain C. F. Lüddeke, Zürich - The Carrier’s Defences - 31/01/2003 2

There is a rather interesting case that will interest insurers and recovery agents alike 

concerning a Bill of lading and the agent's failure to present 1 . 

The Underwriters of the shippers sought to recover from agents in Georgia in 

respect of a settlement made by the Claimant with cargo underwriters. The dispute 

concerned two shipments of butter under the Claimant's bill of lading in March 1999. 

There was a long sale chain. The Defendant did not hand over the goods to the endconsignee 

against delivery of an original bill of lading, but handed them over to 

earlier consignees, although the goods did reach the intended recipients at the end 

of the contractual chain. The shipper was not paid by the receiver until June 1999. In 

the meantime, cargo underwriters made payments to the shippers under the 

insurance policy and the Claimant settled with underwriters in respect of this. The 

Claimant claimed for breach of the agency agreement in releasing the cargo without 

presentation of the original bill of lading, alternatively under an indemnity in the 

agreement. 

It was held that the Claimant's settlement with cargo underwriters was not 

reasonable in all the circumstances as their investigation of the claim was narrow 

and superficial. There was a lack of evidence, which made establishing the scope of 

the claim difficult. It was extremely unlikely that underwriters would have paid, let 

alone have paid as quickly as they did, had they been informed that the goods had 

reached the intended buyers, that there was no question of the bills of lading being 

used as security für payment of the goods and that the shippers had been paid. Had 

the claim been competently handled, the Claimant would have discovered that the 

shippers had been paid. Legal advice would have been obtained and the claim 

would have been competently tested. Once the relevant facts had been discovered, 

the claim against the Claimant would probably not have been pursued on any basis. 

The Claimant was entitled to nominal damages only. 

In the "Bunga Seroja" 

The Admiralty Division of the Supreme Court of New South Wales handed down an 

important decision in connection with the interpretation of the perils of the sea 

defence under the Hague Rules. 

1 P&O Nedlloyd Ltd (2) P&O Nedlloyd BV v M&M Militzer & Munich International Holding AG 


The Bunga Seroja, owned by Malaysian International Shipping Corporation (MISC), 

was carrying a cargo of aluminium coils in ten containers from Sydney to Keelung. 

While transiting the Bass Strait, she encountered severe storm conditions and 

suffered structural damage. On discharge, a number of coils were found to have 

been damaged due to shifting within the containers as a result of the heavy weather. 

A claim was brought by the cargo owners. The trial judge found that the carrier had 

discharged its responsibilities under Article 3 Rule 2 of the Hague Rules to "carefully 

to carry and care for the cargo". No question therefore arose as to whether the loss 

or damage had occurred as a result of the carrier not having exercised due diligence 

to make the ship seaworthy (Article 4, Rule 1). Nor had the loss or damage resulted 

from any negligence by the carrier, master or crew in the management of the vessel 

(Article 4 Rule 2a) or from perils of the sea (Article 4 Rule 2c). 

Rejecting the stricter US and Canadian approach, which take into account the 

element of foreseeability, the High Court continued to favour the Anglo-Australian 

approach in holding that MISC could still have relied on the perils of the sea 

defence, even though the weather encountered was foreseeable and had in fact 

been foreseen as the vessel had received forecasts of heavy weather that it would 

meet on the crossing. 

The Australian High Court continued to favour the more lenient approach to the use 

of the perils of the sea defence because otherwise it would transform the obligation 

to use due diligence to make the vessel seaworthy into an absolute obligation of 

seaworthiness which, the court felt, would deny the history of the development of 

this defence and its place in the context of the Hague Rules as a whole. 

Due diligence 

The Supreme Court of Western Australia handed down a ruling in a general average 

dispute which highlights the need for ship-owners to observe proper maintenance 

procedures and to properly document all maintenance work performed. 2 

The case arose from the failure of a nut which formed part of the engine on the 

2 Andre Toulemonde Wool Co Pty Ltd v Knutsen Offshore (Panama) SA 


cargo ship HANNE BAKKE. Eleven hours into a voyage from Fremantle to Hong 

Kong, the vessel's engine stopped and could not be restarted. One of the twelve 

cylinder shafts had been ripped apart, resulting in severe damage to the engine. The 

ship was towed back to Fremantle, where repairs were carried out. 

As a result of the incident, delivery of the vessel's cargo was delayed. The ship 

owner made a claim for general average contribution against the owners of the 

cargo. 

The case turned on whether the ship owner had exercised due diligence with 

respect to that crucial nut which formed part of the cylinder assembly of the ship's 

engine. The owner argued that there was a latent defect in the cylinder which it was 

impossible to discover. It maintained that the nut was not involved. The cargo 

interests, meanwhile, maintained that the engine failure was due to the failure to 

tighten the nut which formed part of the cylinder. They said there was a failure to 

conduct a proper general maintenance regime. The issue was important because 

the entitlement to general average contribution was dependent on the carrier's 

exercise of due diligence. 

After hearing expert evidence from marine engineers, and from those charged with 

carrying out maintenance on the vessel's machinery, the court concluded that, not 

only was the ship unseaworthy when it left Fremantle, but the unseaworthiness was 

due to a want of due diligence on the part of the ship-owner. Accordingly, the owner 

could not make a claim for general average contribution from the cargo interests. 

The JORDAN II 

The owner of the Jordan II was found not liable for a steel cargo damaged by poor 

handling and carriage. Deciding that the charter party had transferred full 

responsibility to the Charterer, a London judge also reaffirmed the Pyrene v Scindia 

principle that the "proper performance" obligations under the Hague-Visby Rules 

only apply to functions the carrier has agreed to carry out. 

Deciding that neither the voyage charterer of the Jordan II, nor the shipper and 

receiver of its cargo of steel coils can sue the owner for alleged damage in transit, 

deputy judge Nigel Teare QC rejected a claim that the interpretation of Article III rule 

2 of the Hague (later Hague-Visby) Rules, dating from the 1954 Pyrene v. Scindia 

case, was "wrong". 


What had the parties actually agreed in the charter and the bills of lading? And was 

this overridden by the Hague-Visby requirements as to the carrier’s obligations? 

The Jordan II was voyage chartered in December 1997, to carry 5,500 tonnes of 

galvanised steel coils from India to Spain. Under clause 3, of the charter freight was 

to be paid per metric ton FIOST [free in and out, stowed and trimmed] – 

lashed/secured/dunnaged. 

Clause 7 read: "Charterers to have full use of all vessel’s gear to assist in loading 

and discharging," but this was only to be "supplementary to the shore gear", shore 

winch men and crane men "to be used at all times". 

Clause 17 read: "Shipper/Charterers/Receiver to put the cargo on board, trim and 

discharge cargo free of expense to the vessel," trimming being described as 

"levelling off the top of the pile". The charter was subject to English law, and 

incorporated Hague-Visby. 

The shipper, Jindal Iron, the receiver, Hiansa, and TCI as charterer, complained that 

the cargo was damaged, and started proceedings against Islamic Solidarity. TCI 

sued under the charter, Jindal and Hiansa as bill of lading holders. Islamic Solidarity 

responded that, as ship owner, it was not liable for the cargo operations, either 

under the charter or under the contracts of carriage evidenced by the bills of lading. 

The claimants’ case was that even if clause 3 required the charterer to pay for 

loading, stowing, this did not transfer responsibility for ‘proper performance’. Islamic 

countered by arguing that clauses 3 and 17 transferred both obligations – to pay, 

and to ensure the operations were properly carried out. 

Mr Teare QC, the deputy judge said the owner had a responsibility for ‘proper 

performance’ under common law, and if this was to be transferred to the charterer, 

the charter party must use "clear words". Clause 3, would not, by itself, have been 

enough to transfer this responsibility. 

Clause 3 was a freight clause and, while it transferred liability for the expense of 

cargo operations, it did not "clearly" transfer the duty to perform them properly. 

However, it would have to be read with clause 17, which could be understood as 


including the FIOST requirements. Steel coils did not need ‘trimming’ but did require 

the services of lashing, securing and dunnage specified in clause 3. 

"Bearing that in mind," said the judge, "that the obligation to trim in clause 17 was 

intended by the parties to mean the obligation to lash, secure and dunnage." These 

responsibilities, he ruled, were transferred from the owner to TCI, the charterer, who 

therefore could not claim damages. 

Rejecting arguments that the reference to trimming was too "ambiguous" to transfer 

responsibility, and was "commercially repugnant to the bill of lading" because it 

removed the carrier’s normal responsibilities, he went on to hold that when cl 3 and 

17 were read into the bills of lading, they must be read together in the same way. 

The ‘trimming’ reference in cl 17 should "clearly be understood" in the same sense 

as in cl 3. The shipper and receiver could not claim under the bills of lading unless 

they could prove the damage was the ship owner’s fault. 

Mr Teare QC ruled that the clauses were not invalid under Article III, rules 2 and 8 of 

the Hague-Visby Rules, which says the carrier is responsible under the bills of 

lading for poor loading, stowage and discharge. He declined to reject the Pyrene 

versus Scindia view, subsequently confirmed by the House of Lords, that the 

carrier’s obligation to load, stow, carry and discharge the goods ‘properly and 

carefully’ only applied if he had agreed to carry out those functions. 

The “SAINT JACQUES II 3 

This case is believed to be the first in England where a party's ability to limit its 

liability under the 1976 Limitation Convention was held potentially open to 

successful challenge. It also illustrates just how difficult it will be in most cases to 

"break" that limitation. 

At about 4.30 am on 23rd April 2001, the fishing vessel, "Saint Jacques II", owned 

and skippered by Mr Margolle, collided with the "Gudermes", a motor tanker owned 

by Delta Maritime. Delta Maritime and the cargo owners immediately issued 

3 

Loic Ludovic Margolle and another v Delta Maritime Company Limited and others -English Admiralty 

Court: Gross j.: 28 November 2002 Nicholas Saunders, instructed by Constant & Constant, for 

Margolle Elizabeth Blackburn Q.C., instructed by Richards Butler, for Delta Maritime collision: limitation 

of liability: reckless navigation: whether owners had relevant knowledge that loss would probably result 


proceedings for damages in the region of US$700,000. In August 2001, Mr Margolle 

began these proceedings under the Merchant Shipping Act 1995 seeking a decree 

under the 1976 Limitation Convention limiting any liability he might have for 

damages. 

The dispute centred on Article 4 of the Convention, which provides: 

"Conduct barring limitation”. 

“A person liable shall not be entitled to limit his liability if it is proved that the 

loss resulted from his personal act or omission, committed with the intent to 

cause such loss, or recklessly and with knowledge that such loss would 

probably result." 

There was no suggestion that the collision was caused intentionally, but Delta 

Maritime alleged it was caused by the personal act or omission of Mr Margolle 

committed recklessly and with knowledge that such loss would probably result. 

Mr Margolle’s lawyers applied for summary judgment, on the basis that Delta 

Maritime had no real prospect of successfully contesting the limitation claim and 

there was no other compelling reason why the claim should go to trial. The Admiralty 

Registrar dismissed the application. The Registrar reached his conclusion believing 

Mr Margolle was on the bridge at the time of the collision. New evidence, however, 

confirmed that he was, in fact, asleep below. Mr Margolle appealed. 

The collision took place as the Saint Jacques II, skippered by Mr Margolle, was 

sailing from Boulogne towards the Falls Bank fishing grounds. In his haste to get 

there before his competitors, Mr Margolle set a course across the South West Traffic 

Lane of the Dover Straits Traffic Separation Scheme, heading against the flow of 

traffic, in contravention of Rule 10 of the Convention on the International 

Regulations for Preventing Collisions at Sea 1972. This, as Mr Justice Gross put it, 

was the "nautical equivalent of a motorist proceeding the wrong way along a 

motorway". 

Although Mr Margolle had determined the course to be steered, he was down below 

when the collision took place, having left the vessel in charge of a 17-year old 

deckhand. Mr Margolle argued that the navigation of the vessel in the final minutes 

before the collision could not be the result of his personal act, because he was 

asleep at the time. 


This was not the first time the Saint Jacques II had breached the Collision 

Regulations. Delta Maritime had evidence of five other instances of rogue 

navigation. Mr Margolle, however, argued that because he had "got away with it" so 

many times in the past, one could not infer from that that he was reckless or had 

knowledge that damage would result, as required by Article 4. 

The burden of proof under the Limitation Convention rests with the party seeking to 

"break" the limit. That burden is a very heavy one. Where there is no allegation of 

intent, the party challenging the limitation must establish reckless conduct and 

knowledge that the loss would probably result. 

When a person acts recklessly, he acts in a manner which indicates a decision to 

run the risk or a mental attitude of indifference to its existence. 4 The knowledge 

required is actual, not constructive, in the sense of appreciation or awareness at the 

time of the conduct in question, that it will probably result in the type of damage 

caused. Nothing less will do. 5 

But the test under the 76 Limitation Convention is even higher than the test under 

Warsaw. It requires a personal act or omission of the party seeking to limit, rather 

than the act or omission of the carrier his servants or agents. In addition, under 

Warsaw, the relevant knowledge is that damage would probably result but, under 

the 76 Limitation Conventions, the relevant knowledge under Article 4 is that "such 

loss" would probably result. 

Lord Phillips said that "such loss requires foresight of the very loss that actually 

occurs, not merely of the type of loss that occurs". 6 In a collision between Ship A 

and Ship B, therefore, the owners of Ship A would only defeat the owner of Ship B's 

right to limit liability if they could prove that he intended that Ship B should collide 

with Ship A or acted recklessly with the knowledge that it was likely to do so. 

This was just such a case. If one looked only at the last minutes of navigation before 

the collision, Mr Margolle could not have had any personal involvement in the 

navigation during those minutes because he was asleep at the time. Had the case 

rested on this alone, Mr Margolle would have been able to limit his liability. 

4 Goldman v Thai Airways Limited [1983] 1 WLR 1186 

5 Nugent v Goss Aviation [2000] 2 Lloyd's Rep 222 

6 Schiffahrtsgesellschaft MS Merkur Sky MBH & Co v MS Leerort Schiffahrts Gmbh &Co KG [2001] 2 

Lloyd's Rep 291 


But the decisive factor was the evidence that this was not the first time the Saint 

Jacques II had been navigated across the traffic lane on Mr Margolle's instructions. 

This appalling navigational practice, combined with the obvious risk of collision, left it 

open to the court at trial to infer that Mr Margolle had the relevant actual knowledge 

that a collision would probably result, whether with the Gudermes or with some other 

vessel. 

The fact that Mr Margolle had got away with this sort of behaviour in the past made 

no difference, since there is nothing to suggest that the risk or probability of a 

collision diminishes with repeated reckless navigation. If anything it increases. In 

any event, the test was the subjective knowledge of Mr Margolle, not an objective or 

logical analysis of risk. 

As a result, the judge was satisfied that Delta Maritime had a real prospect of 

demonstrating at trial that Article 4 of the Limitation Convention applied. Mr 

Margolle's application for summary judgment was dismissed. 

An interesting case is that of the MSC ROSA M 7 

Under Article 4 the burden of proof lies on cargo interests to show that limitation of 

liability should not apply on the ground that "the loss resulted from his personal act 

or omission, committed with the intent to cause such loss, or recklessly and with 

knowledge that such loss would probably result." Cargo interests claimed that on the 

facts there were various defects in the fuel and ballast systems which endangered 

the vessel, and that the Captain knew about some of these defects, and that he 

ought to have known about other defects if the ship's reporting procedures were not 

deficient. The failure of the Captain to take the appropriate actions with regard to the 

defects was argued to constitute a reckless disregard for the safety of the ship, 

which the Captain should have known would lead to a serious incident. 

The purpose of the 1976 Convention is to give a higher limit in return for an almost 

indisputable right to limit Owners liability. There were no examples in English 

maritime law of a successful defence to limitation based on Article 4. If there was no 

7 MSC Mediterranean Shipping Co SA -v- Delumar & Ors, The 'MSC Rosa M' 13.07.2000 Limitation 

Action - Article 4 of Convention on Limitation for Maritime Claims 1976 - should Owners be precluded 

from obtaining decree of limitation - Held: the onerous burden of Article 4 had not been met - decree of 

limitation applied. Q. B. Division, David Steel J. 

Captain C. F. Lüddeke, Zürich - The Carrier’s Defences - 31/01/2003 10

intent, then cargo interest has to show both: 

(1) reckless conduct 

and; 

(2) knowledge 

that the type of loss in question would result. On the facts, cargo interests’ case 

disclosed no reasonable ground to challenge limitation. 

The chances of breaking limitation are very slim. It is not enough that the Master is 

or should have been aware of the defects. It is the conduct and knowledge of the 

person seeking to limit which is important. 

The dangers of wrong, superfluous instructions or off-the-shelf ISM systems copied 

from reports by eager claims managers who probably do not understand what they 

read, are best demonstrated in the following case. 

Since ISM, speculations are made as to what impact the implementation of the code 

would have on judicial determination relating to issues of seaworthiness. The recent 

High Court judgment of the “EURASIAN DREAM” that turned into the EURASIAN 

NIGHTMARE provided some insight into this matter. 

In July 1998, the car carrier EURASIAN DREAM became a constructive total loss 

and the entire cargo was destroyed after the crew was unable to contain a fire which 

originated in a vehicle aboard the vessel. At the time of the loss, there was no 

mandatory requirement for the vessel to be ISM certificated. 

The court found that the managers had an ISM system in place providing the vessel 

with the same safety manuals as other vessels in their fleet. 

The issue before the court was that of liability for the cargo. The carrier had provided 

that the Bill of Lading contracts incorporated both the Hague and the Hague-Visby 

Rules. Article III of both the rules, require the carrier to exercise due diligence before 

and at the commencement of the voyage to provide a seaworthy vessel. The vessel 

must be properly manned, equipped and supplied with cargo compartments, fit and 

safe for the reception, carriage and preservation of cargo. The court found that 

unseaworthiness was causative of the cargo loss for which the owners of the 

Eurasian Dream were liable. The vessel was unseaworthy by reason of the 

condition of the vessel's equipment and the lack of competency and efficiency of the 


master, crew and the inadequacy of the documentation supplied to the vessel. The 

court acknowledged that the vessel's equipment complied with Solas regulations. It 

is clear, however, that mere compliance with Solas regulations may be insufficient 

for the purposes of establishing seaworthiness. This suggests that it is incumbent on 

the manager and owner to perform a risk assessment to determine safety 

equipment requirements, having regard to the vessel’s type, nature of the cargo and 

trade, rather than merely relying on compliance with Solas regulations. 

The master of the Eurasian Dream would have required two to three weeks to read 

all manuals. The managers were found at fault for not providing a briefing letter 

targeted at the vessel type and the master's experience. Such a letter should have 

summarised the guidance to be given to a master in relation to emergency 

procedures and have would directed him to the relevant parts of the manuals. The 

court said that there was too much documentation; much of it was irrelevant and 

obsolete often referring to other vessel types and concluded, for efficiency and 

competence of response, only one code or set of procedures should have been 

prescribed for the master. 

Those masters who have been expected to familiarise themselves with a new safety 

management system on joining a vessel will take comfort that the court found the 

Eurasian Dream's documentation too voluminous to be digestible and that a 

manager does not discharge his responsibility by simply instructing the master to 

read the manuals and instructions onboard. The ISM Code is an integral part of the 

standards and practices of the industry. It appears likely that in any future dispute 

over seaworthiness, managers and owners should be prepared that implementation 

and effectiveness of their ISM systems will be closely scrutinized. One should also 

take note that mere compliance with Solas regulations regarding equipment onboard 

is not sufficient for the purposes of establishing seaworthiness. Finally, the case of 

the Eurasian Dream should serve as a warning to those managers that have 

purchased an, 'off the shelf' ISM system. The courts will examine the adequacy, 

relevance, size and 'user friendliness' of the manuals as well as the method by 

which key personnel are familiarised with the system. 

Ladies and gentlemen you will be pleased to hear that I have come to the end of my 

discussion I do presume that confusion reigns supreme. It is rather important for 

persons handling cargo claims to know the difference between Hague-Visby and 

what some conceived to be the name “Haig Whiskey”. One of my successors in 

MSC is of that specie. 


Please do always remember, that 

Defences in court actions look bigger when entering the court 

but much less so when leaving. 


Captain Christof F. Lüddeke, FNI 

Captain Christof F. Lüddeke, FNI has been 

director of MSC Mediterranean Shipping Co. 

SA, a shipping company in Geneva 

Switzerland, for 30 years and was in charge 

of the insurance, claims and legal 

department. He has been at sea for 20 years, 

commencing his seafaring career as cadet on 

the square-rigger "PASSAT". He is Master 

Mariner and Lt. Cdr. of the German Naval 

Reserve. Fellow of the Nautical Institute. 

Brother of the Schiffer-Gesellschaft zu Lübeck, Germany. Member of the Society of 

Master Mariners of South Africa and the Hon. Company of Master Mariners, 

London. Member of the International Federation of Shipmasters. Member of the 

Friends of the square-riggers Pamir & Passat. Member of the Technical Advisory 

Group of the Germanischer Lloyd classification, Hamburg. He was director on the 

Board of the North of England P&I Association Ltd. He is director on the board of 

Shoreline, an international maritime pollution COFR organisation. Member of the 

Swiss Maritime Law Association. Acting as arbitrator as full member of the German 

and the Mediterranean Maritime Arbitrators Association, of the Chambre Arbitrale 

Maritime de Monaco. He opened a trustfund with the Nautical Institute in London. 

This fund has been built up with the royalties received for the various publications 

and hands out an annual prize for the best student of the year in the Institute's 

"Command" scheme. 

Lüddeke is Member of the Deutsche Gesellschaft für Transportrecht e.V. He was 

closely involved with the development of Slot Charter Parties and "Standard Service 

Contracts" as member of BIMCO working Groups and is Swiss member of the IMLA 

working group on International Transport Law. 

He is author of a textbook on the 

Hamburg Rules and the "Guide to 

Marine Claims", both published by 

Lloyd's of London Press Ltd., co-author 

of books on "The Management of 

Safety in Shipping" and "Command" 

published by the Nautical Institute. He 

published articles about maritime law 

and insurance with Kluwer Law, Cargo 

Claim Analysis, Charterparty International, P&I International and others. He was 

frequently appointed maritime expert by the Lausanne Commercial Court. Speaker 

at seminars, published various articles in maritime newspapers. 

Since his departure from MSC Mediterranean Shipping Co. SA Geneva, he works 

as Maritime Consultant in Zurich and as Correspondent for the P&I Clubs: 

Transmarine, London, Michael Else and Co. Ltd., London, North of England P&I 

Assoc. Ltd., Newcastle upon Tyne, The Standard Steamship Owners' Protection 

and Indemnity Association, Bermuda & London, The Charterers P&I Club, London 

Swiss agent for: MacDonald Hebditch & Co. Ltd. General Average Adjusters, 

England, C.E. Goltermann Succrs. Schiffahrts- und Handelsgesellschaft mbH, 

Hamburg, Mountbatten Finance Ltd. London. 

General Representative of the North of England Insurance Co. accredited by the 

Bundesamt für Privatversicherungen.

10 LUEDDEKE Carrier defences - Nautischer Verein zu Bremen ...

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