“Where the English court had jurisdiction pursuant to article 31.1 of the Convention on the Contract for the International Carriage of Goods by Road (as scheduled to the Carriage of Goods by Road Act 1965) in respect of a claim by the cargo owner against the primary carrier under the contract of carriage, article 36 of the Convention permitted the cargo owner to bring proceedings in England not only against the primary carrier, but also against successive carriers, whether or not the English court would have had jurisdiction over the successive carriers individually applying the provisions of article 31.1.”
WLR Daily, 30th October 2013
Source: www.iclr.co.uk