Stein, Forbes & Co v County Tailoring (1916) Under a CIF (cost, insurance, freight – see 20.1) contract for the sale of sheepskins the price was stipulated to be payable against the documents (which entitled the buyer to the goods) upon arrival of the ship. However, when the documents were tendered the buyers refused to accept them. The sellers sued for price under s 49(1) of the Sale of Goods Act (which required that property must pass for an action in price) arguing that although the property had not passed, this was the fault of the buyer.