77. Rederiaktiebolaget Argonaut v Hani [1917] KB 247

Undisclosed principal – parol evidence to prove identity not admitted

The facts

The charterparty was made between owners and H Company “as charterers”. A third party instituted arbitration proceedings as undisclosed principal of the agent signatory.


The court (Rowlatt J) found that the contract involved a delectus personae. Notices had to be given to the named charterer etc.

Accordingly, the terms of the agreement would be contradicted by the introduction of a third party. The parol evidence rule was called in aid to determine such evidence inadmissible.

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