Brandt v Liverpool Contract

The Brandt v Liverpool implied contract is the common-law device that gives an indorsee of a bill of lading, who is not a party to the original carriage contract, a direct contractual claim against the carrier. It is implied from the holder presenting the bill and the carrier delivering the goods against it, on the bill’s terms. In England the doctrine lost most of its work once the Carriage of Goods by Sea Act 1992 transferred suit rights to the lawful holder by statute, but it survives where COGSA 1992 does not reach.