[1966] 1 Lloyd's Rep. 343 (McNair J)
The most important point to come from Ginzberg v. Barrow Haemetite Steel Co. [1966] 1 Lloyd's Rep. 343 was McNair J's view that that it was common for the parties to a c.i.f. contract to intend that property in the goods shall pass only when payment is made. In the case the usual presumption was not rebutted by delivery having already been made to the buyers under delivery orders, bills of lading not having become available by the time the goods arrived at the port of discharge. McNair J's general proposition was referred to with approval by Roskill LJ in The Albazero.
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