Universe Tankships Inc. of Monrovia v International Transport Workers' Federation [1982] 2 All ER 67 is an English contract law case relating to duress.
The International Transport Workers' Federation black listed a Universe Tankship Inc. ship in the context of a trade dispute.
ITWF admitted this was an agreement procured by duress, but it argued its actions were protected by immunity from tort in Trade Union and Labour Relations Act 1974 s 13.
Lord Diplock said duress is not about not knowing what you are contracting for, but 'his apparent consent was induced by pressure exercised on him by that other party which the law does not regard as legitimate, with the consequence that the consent is treated in law as revocable unless approbated either expressly or by implication after the illegitimate pressure has ceased to operate on his mind.'
Lord Scarman said that duress not only renders a contract voidable but is also a tort if it causes damage or loss (referring to Barton v Armstrong and Pao On v. Lau Yiu Long).