“…bill issued had been a straight consigned bill in line with the draft bill of lading, as JI Macwilliam Co Inc v Mediterranean Shipping Co S.A.(“The Rafaela S”) [2005] UKHL 11; [2005] 2 AC 423 established that straight consigned bills are within Article 1(b). However, no bill of lading had been issued, only the sea waybills which wer…”