ABSTRACT
The Hague Rules provide a limit on the amount recoverable from the carrier of £100 per package, which limit could be avoided by the declaration, by the shipper, of the goods’ value on the face of the bill.120 Article X provides that ‘the monetary units mentioned in these Rules are taken to be gold value’. Uncertainty as to the effect of this provision on the £100 package limitation led to the adoption of the ‘gold clause’ which provided for an express limitation of £200 sterling per package. The wisdom of adopting such a clause was confirmed in The Rosa S121 where the Hague Rule limit was held to refer to £100 gold value at current prices, namely £6,630.50 at the date of the delivery of the cargo, 1 June 1984.
