Kairos Shipping Ltd and another v Enka & Co LLC and others: [2014] EWCA Civ 217; [2014] WLR (D) 113
‘It is in principle possible to constitute a limitation fund under the International Convention on Limitation of Liability for Maritime Claims 1976, scheduled to the Merchant Shipping Act 1995, by means of a guarantee in the form of a letter of undertaking provided by a protection and indemnity club.’
WLR Daily, 6th March 2014
Source: www.iclr.co.uk