Comptoir d'Achat et de Vente du Boerenbond Belge S/A v. Luis de Ridder Limitada (The Julia)

Boerenbond (plaintiff) paid Ridder (defendant) for rye to be shipped to Antwerp under a C.I.F. contract and received a delivery order, but taking actual possession required a multi-step procedure ending with the ship captain's release document going to Ridder's agent, Van Bree, who alone could authorize final delivery; the ship never reached Antwerp due to wartime conditions and instead sold the rye elsewhere at a reduced price. Boerenbond demanded a full refund, arguing complete failure of performance since title never passed, while Ridder argued the delivery order itself constituted performance; an arbitration umpire and lower courts ruled for Ridder, and Boerenbond appealed.