Demurrage in the strict sense of the word1 is payable only where there is an express term to that effect2. In the absence of any such term the shipowner is not entitled to claim demurrage as such3, nor is the charterer justified in detaining the ship beyond the expiry of the time allowed by the charterparty for loading or discharging, as the case may be4. If, therefore, he detains her for any further time, he is guilty of a breach of contract, and is liable to pay damages for her detention as soon as the lay days expire5. This
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