Where express liens are conferred on the shipowner by the terms of a charterparty, the holder of the bill of lading, if not the charterer1, is not subject to them, unless they are incorporated in the bill of lading2. Mere notice of the charterparty is not sufficient3. Moreover, any reference in the bill of lading to the charterparty is strictly construed4.
Unless, therefore, the language used in the bill of lading is wide enough to extend the shipowner's rights, the holder of the bill of lading is entitled to have his goods delivered to him on payment of the freight
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