There are various kinds of delivery orders applicable to sea carriage. A delivery order may be either an order by the owner of the goods to the carrier in possession to deliver them to the person named in the order or alternatively a document in which the carrier in possession of goods undertakes that he will deliver them to a named person or the holder1.
The first type of order, usually known as a 'merchant's delivery order', does not purport to contain any undertaking by the carrier, and will not be dealt with further here. By contrast, a ship's delivery order is a document issued
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