"8A. It was a further term of that agreement that the provisions
of the JVA were to remain in force and that the vessel would
be 50% owned by Van Shipping Co Limited for and on behalf of
the (Plaintiff) and 50% owned by the Defendant while the
vessel was flying the Japanese flag.
9. It was a further term of the Amendment Agreement that in or
about July 1987 when the original loan was repaid (Seven
Seas) or another company jointly owned by the Defendant and
Van Shipping Co Limited for and on behalf of the (Plaintiff)
would re-purchase the vessel from YSL at book value.
. . .
11. In breach of the provisions of the JVA and the Amendment
Agreement the Defendant has wrongfully refused to retransfer
the ownership of the 'Shin Kobe Maru' to (Seven Seas) or to
another joint venture company equally owned by Van Shipping
Co Limited for and on behalf of the (Plaintiff) and the
Defendant.
12. Further it was an implied term of the JVA and the
Amendment Agreement that the Defendant would retransfer the
ownership of the 'Shin Kobe Maru' to (Seven Seas) or to
another joint venture company equally owned by Van Shipping
Co Limited for and on behalf of the (Plaintiff) and the
Defendant.
13. In breach of the implied terms referred to above, the
Defendant has failed to retransfer the ownership of the
'Shin Kobe Maru' to (Seven Seas) as to another joint venture
company equally owned by Van Shipping Co Limited for and on
behalf of the (Plaintiff) and the Defendant.
PARTICULARS
(a) It was an implied term of the JVA, as amended by the
Amendment Agreement, that the Defendant would take all
reasonable steps to do all that is necessary to be done to
carry out the terms of the (sic) those agreements and to
retransfer the 'Shin Kobe Maru' to (Seven Seas) or to
another joint venture company equally owned by Van Shipping
Co Limited for and on behalf of the (Plaintiff) and the
Defendant.
(b) In breach of the JVA and the Amendment Agreement the
Defendant has wrongfully refused to retransfer the 'Shin
Kobe Maru' to (Seven Seas) or to another joint venture
company equally owned by Van Shipping Co Limited for and on
behalf of the (Plaintiff) and the Defendant.
14. The Applicant says that the claim made herein is a
proprietary maritime claim by reason of Section 4(2)(a)
and/or (b) of the Admiralty Act 1988 in respect of which
jurisdiction is conferred on this honourable Court by reason
or (sic) Section 10 and Section 16 of the said Act.
PARTICULARS
The proceedings are a claim relating to possession of ship
namely the 'Shin Kobe Maru' and/or title or ownership of a
ship or a share in the ship. Further and in the alternative
the proceedings are between co-owners of a ship relating to
the possession, ownership, operation and earnings of the
ship.
15. By reason of the Defendant's failure to retransfer the
ownership of the 'Shin Kobe Maru' in accordance with the
provisions of the Amendment Agreement, the (Plaintiff) has
suffered loss and damage.
PARTICULARS
1. Loss of bareboat hire at US$124,000.00
per month for 30 months (2/87 - 1/90)
with interest 8 1/2 p.a. to 7/93 US$5,592,604.00
2. Loss of profit on management US$25,000.00
per month for 72 months (7/87 - 7/93)
with interest 8 1/2 p.a. to July 93 US$2,354,087.00
3. Charter hire US$114,583.00 per month
(50% of charter hire of US$400,000.00
per month less monthly management fee
US$170,834.00 for 24 months (7/91 - 7/93)
with interest 8 1/2 p.a. to 7/93 US$3,007,235.00
4. The (Plaintiff)'s 50% share of the
vessel's sale proceeds US$2,500,000.00
US$13,453,926.00
Less
Excess loan at 7/87 US$6,911,623.00
Less SST/UTI (50% YSL) US$ 39,620.00
Empire US$ 31,867.00
New S/B pay US$ 910,385.00
US$5,929,751.00
Add
Interest to
17th year at 8.5% p.a.
7/87 to 7/93 = 6 years) US$3,841,479.00
Excess Loan and interest US$9,771,230.00
Total Loss US$3,682,696.00
=============="