J.H. Rayner and Company, Limited v. Hambro's Bank, Limited
Court of Appeal
1 KB 37 (1943)
Hambro's Bank Ltd. (Hambro) (defendant) issued a letter of credit for J.H. Rayner and Company (Rayner) (plaintiff), payable on presentment of shipping documents including an invoice for Coromandel groundnuts. Rayner instead presented an invoice describing machine-shelled groundnut kernels marked "C.R.S." in the margin, and Hambro refused payment because the invoice did not match the letter's terms; Rayner sued for breach of contract, arguing traders understood machine-shelled groundnut kernels and Coromandel groundnuts to be the same good, and the trial court agreed and entered judgment for Rayner, which Hambro appealed.
Whether an issuer of a letter of credit is required to make payment upon submission of documents that refer to goods by a different, but synonymous, name than the name of the goods in the letter of credit.