A 'received for shipment' bill of lading is one which states that the goods have been received by the carrier for shipment on board but does not state that the goods have actually been shipped on board1. It is a matter of some doubt whether such a bill of lading2 can validly be tendered by a cif seller. It is clear that such tender is valid if sanctioned by the agreement of the parties or by usage of the particular trade3. It is equally clear that, where the contract expressly prohibits the tender of such a document, the seller is
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