President of India v Lips Maritime Corporation
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The House revisited the topic in President of India v Lips Maritime Corporation [1988] AC 395, where a claim for a currency exchange (The “Lips”) loss through late payment of demurrage failed on the straightforward basis that demurrage is liquidated damages, and the law knows no such thing as a claim for damages for failing to pay damages.
Claims to recover currency exchange losses as damages for breach of contract, whether the breach relied on is late payment of a debt or any other breach, are subject to the same rules as apply to claims for damages for breach of contract" (ie ordinary remoteness of damage and causation principles)