[3] The English courts devised some ways round the problem: in Brandt v Liverpool (1924) [4][5] the concept of implied contracts was developed, although the courts proved reluctant to use this concept.

[8][9][10] The report contained a draft bill which Parliament adopted in full without amendment.

The Carriage of Goods by Sea Act 1971 incorporates the Hague-Visby Rules into English Law.

These rules require (where the Article X invokes the Rules) that, on demand, the carrier must provide the shipper with a bill of lading that meets the requirements of Article III.

Although CoGSA 1992 cannot amend the Hague-Visby Rules, which are an International Convention, s.4 of the 1992 Act (above) upgrades the status of a bill of lading to be conclusive evidence of receipt for shipment.