ABSTRACT

Although Article 17 was based on the firm and familiar footing of the CIM,1 the CIM was largely unknown in England and one senior English judge, coming to the CMR for the first time, expressed little enthusiasm: ‘‘So we set out on our journey through articles 17 and 18. It is a journey which we fear may be long and tedious. But the elaborate wording and the complexity of the articles do not provide a direct or a well-surfaced road to the destination.’’2