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The Court noted that, as a matter of principle, the manipulation of charter clauses incorporated by general reference into bills of lading was possible when necessary. But, in this case, the Gulf of Aden and War Risk clauses made perfectly good sense in the context of the bills of lading simply as a record of the terms upon which the shipowner had agreed to transit the Gulf of Aden, referring, as they did, to the charterer, who was to pay the insurance premia. As such, there was no necessity to manipulate the clauses in this case.

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