In the recent English Court of Appeal decision, The Eternal Bliss [2021] EWCA Civ 1712, an important point of law on demurrage was ‘settled’. In overruling the High Court, the Court of Appeal held in no uncertain terms that demurrage ‘liquidates the whole of the damages arising from a charterer’s breach of the charter in failing to complete cargo operations within the laytime and not merely some of them. Accordingly, if a shipowner seeks to recover damages in addition to demurrage arising from delay, it must prove a breach of a separate obligation’. read more