Subject to the provisions conferring protection on the carrier1 in certain circumstances2, he must3 properly and carefully load, handle, stow4, carry, keep, care for and discharge the goods5 carried6. 'Properly', in this connection, is not simply synonymous with 'carefully', but means in accordance with a sound system7. The obligation to load the cargo properly and carefully applies to deck cargo unless it is being carried outside the terms of the Carriage of Goods by Sea Act 1971 altogether8. The obligation to care for the goods in the course of the voyage, expressed in the words 'handle, stow, carry, keep,
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