Straight Bills, a Comparative Study

Abstract: This dissertation will be discussing the presentation requirement for straight bills in different jurisdictions, in an attempt to clarify interpretational differences and similarities. Starting with common law&semic United Kingdom's, Singapore's, Hong Kong's and the United States' legal interpretational views will be analysed and then compared with a civil law jurisdiction, represented by Swedish law. Furthermore, the different jurisdictions will also be compared with the newly drafted UNCITRAL Draft Convention. This dissertation will, among other things, come to the conclusion that common law jurisdictions interpret the presentation rule for straight bills differently. The United Kingdom's, arguably having a position in between the United States and Singapore/Hong Kong for the moment&semic view on this matter is far from resolved. Even if the House of Lords seem to favour a solution based on the path that Singapore and Hong Kong choose, many critics have in doctrine made it clear that case law is not clear enough and that the United States approach is better. Hence, the issue is so far not resolved.