Club cover requires delivery of cargo under a non-negotiable bill of lading or waybill to be made to the person named in that document and no other. If not a claim for wrongful delivery could be made. It was commonly believed that in the case of a non-negotiable B/L it was not necessary for the original B/L to be produced if the named consignee could properly identify themselves. That is no longer the legal position in English jurisdictions (and has not been the case in several other jurisdictions either namely Dutch, and French jurisdictions). From time to time we are asked how to ensure that delivery under a non-negotiable B/L can go ahead: if the named person cannot produce the bill (or if no bill has in fact been issued) or if a different person presents the bill. Some recent decisions in England and Singapore show how it can go wrong (and so how expensive it can be) if care is not taken. Another important result of two of these cases, as far as non-negotiable bills are concerned, is the loss of owners’ ability to limit liability to the lower amount in the Hague Rules even where the Hague Visby Rules apply compulsorily. This will affect all those using straight bills as part of their trade and is discussed further below. The terms "straight B/Ls" and "non-negotiable B/Ls" are here used interchangeably. The term "non-negotiable" often causes confusion because it is actually used to describe the bill as being non-transferable. When is a bill of lading a straight bill? In  The Happy Ranger  [2002] 2 Lloyd’s Rep 357, the Court of Appeal decided that the bills of lading in question were not straight bills – or rather they would have been straight bills had they been issued. No bill had in fact been issued, but it was sufficient that its issue was contemplated because the carrier’s regular form of bill was incorporated into the charterparty. A straight bill of lading has actually no English law definition but the Court approved of the US term: a straight bil