Carlos Federspiel & Co., S.A. v. Charles Twigg & Co., Ltd.

Carlos Federspiel & Co., S.A. v. Charles Twigg & Co., Ltd.

QUEEN'S BENCH DIVISION (COMMERCIAL COURT)

[1957] 1 Lloyd's Rep 240

Property in a consignment of bicycles sold f.o.b. did not pass until shipment. They buyer had already paid, but was held not to have obtained any property in them, the seller having been wound up before the goods had been shipped. The seller had not finally appropriated the goods to the contract, within rule 5 of SGA 1979, s. 18, prior to their shipment.

The courts seem very reluctant to infer that property passes f.o.b. before shipment - see, e.g., Pyrene v. Scindia, where it was assumed that it had not done so even though the seller had surely performed the last act, so as to tie them unconditionally into the contract.

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