Where a charterparty is negotiated through a broker1, a term is usually inserted providing for the payment to him of a commission2. The term may provide when the commission is to become due, as, for example, on the signing of the charterparty, or the loading of the cargo3, or the earning of the freight4. By the terms of the charterparty the liability to pay commission is often imposed on the shipowner, even if the broker is in fact employed by the charterer.
In the absence of any such term, the broker's right to receive his
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