C Czarnikow Ltd v Koufos or The Heron II [1969] 1 AC 350 is an English contract law case, concerning remoteness of damage.
The House of Lords held that the "remoteness" test, as a limit to liability, is, in contract, more restrictive than it is in tort.
Koufos chartered a ship (the Heron II) from Czarnikow to bring 3,000 tons of sugar to Basra.
Lord Reid disapproved of Asquith LJ’s judgment in Victoria Laundry v Newman in that the term "foreseeability" was employed.
He emphasised that he would use the words ‘not unlikely’ as denoting a degree of probability considerably less than an even chance but nevertheless not very unusual and easily foreseeable.