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Tanga Pharmaceuticals Plastics Ltd & Ors v Emirates Shipping Line FZE [2025] EWHC 368 (Comm) (27 February 2025)

Source: Open mirrored case · Original bailii.org

Sanctions — Geo ✓

Executive Summary

  • The case concerns claims by Tanga Pharmaceuticals Plastics Ltd and others (Claimants) against Emirates Shipping Line FZE (Defendant) relating to cargo damage and salvage costs following a motor engine failure of the vessel *MV Alion* in September 2021.
  • Cargo shipped from India, UAE, and Saudi Arabia to Mombasa under Bills of Lading governed by English law.
  • Claims arose from salvage services rendered and general average declarations; claims were notified in November 2022 and issued in June 2023.
  • The Defendant sought summary judgment on the basis that claims were time-barred under the Bills of Lading terms.
  • The court considered contractual terms, applicable carriage conventions (Hague Rules, Hague Visby, Hamburg Rules, COGSA), and jurisdictional issues.

Sanctions Highlights

  • — No sanctions implications identified in the case.

Emerging Risks

  • Potential for increased litigation risk in multi-jurisdictional carriage contracts involving complex salvage and general average claims.
  • Time-bar provisions in Bills of Lading remain a critical risk factor for claimants, especially with extended delays in claim notification and issuance.
  • The interplay of multiple carriage conventions (Hague Rules, Hamburg Rules, COGSA) depending on shipment origin/destination complicates liability and limitation issues.
  • Reliance on English jurisdiction and law may limit claimants’ options but also provides clarity on procedural timelines.

Geopolitical Impact

  • The case involves shipments originating from India, UAE, and Saudi Arabia, with cargo destined for Kenya, highlighting key trade routes in the Arabian Sea region.
  • The involvement of English law and jurisdiction underscores the UK’s continued role as a legal hub for international shipping disputes.
  • The US legal framework (COGSA) is incorporated for shipments involving the US, reflecting transatlantic trade linkages.
  • The case reflects ongoing commercial interdependence between Middle Eastern, South Asian, African, and Western markets.

Economic Intelligence

  • The dispute underscores the economic significance of maritime logistics in the India-Gulf-Africa corridor.
  • Salvage and general average costs represent substantial financial exposures for cargo owners and carriers.
  • The timing of claims and settlements (mid-2022 to mid-2023) suggests protracted negotiations impacting cash flow and risk management.
  • The case highlights the importance of clear contractual terms to mitigate financial losses in maritime transport disruptions.

Strategic Recommendations

  • Parties engaged in international shipping should rigorously monitor and comply with time-bar and notice provisions in Bills of Lading to preserve claims.
  • Legal counsel should assess applicable carriage conventions early to determine governing liability regimes and limitation periods.
  • Stakeholders should consider jurisdictional clauses carefully, favoring stable legal environments like English courts for dispute resolution.
  • Cargo owners and carriers should enhance risk management protocols around salvage and general average events, including timely documentation and communication.
  • Monitoring geopolitical trade routes and legal frameworks can provide early warning of emerging risks in cross-border maritime commerce.

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**Source Notes:**

*Sanctions Intelligence Digest* — [https://empyreanprotocol.com/litigation/view/www.bailii.org/ew/cases/EWHC/Comm/2025/368.txt](https://empyreanprotocol.com/litigation/view/www.bailii.org/ew/cases/EWHC/Comm/2025/368.txt)

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