ABSTRACT
Finally in this context, it should be noted that, in light of strictness of the rule in Holme v. Brunskill, the issuers and beneficiaries of many commercial guarantees, including shipbuilding refund guarantees, routinely agree to include wording specifically permitting amendment of the terms of guaranteed contract without the consent of the guarantor. Such language is, for example, included as paragraph 3 of standard form refund guarantee attached as Annex A(i) to the NEWBUILDCON Form.
