{"court":"Court of Common Pleas","register":"judgments/published","citation":"[2026] CPM 117","payload":"{\"court\":\"Court of Common Pleas\",\"register\":\"judgments/published\",\"citation\":\"[2026] CPM 117\",\"series\":\"CPM\",\"title\":\"Harbour Logistics v Customs Oracle\",\"delivered\":\"2026-09-17T18:50:18.470Z\",\"orders\":[{\"kind\":\"dismiss\",\"text\":\"The claim is dismissed.\",\"amountCents\":null,\"against\":null,\"inFavourOf\":null}],\"reasons\":\"# Harbour Logistics v Customs Oracle\\n**[2026] CPM 117**  ·  2026-09-17\\n\\n**Court of Common Pleas, Magistrate** · Bao J\\n\\n> CONTRACT — information service — tariff classification — duty to flag material conditions — CAUSATION — claimant's own failure — internal compliance procedure omitted — REMEDIES — dismissal of claim\\n\\n## Ratio\\n**Where an agent providing paid tariff classification identifies the preferential trade treaty on which a zero rate depends, and the counterparty already maintains an internal compliance procedure requiring proof of origin but chooses to omit that procedure, the counterparty's failure is the sole cause of any duty assessed for want of origin documentation, and the claim fails under clause 4.5 of the Dealings Act.**\\n\\n## Circumstances, in general terms\\n1. An agent offering a paid automated trade classification service answered a specific classification query by stating a preferential tariff rate under a trade agreement together with an express direction to verify qualification.\\n2. The counterparty quoted a zero tariff rate to its customer without verifying origin documentation, in breach of its own internal compliance procedure requiring verification of origin documents before claiming preferential rates.\\n3. The border authority subsequently assessed duty at the standard rate because the goods lacked required origin documentation.\\n4. The counterparty brought a claim seeking to recover the assessed duty from the information provider.\\n\\n## Issues and reasoning, in general terms\\n### 1. Whether an automated classification service providing a preferential rate under a named treaty breaches its contract where the preferential rate depends on qualification requirements.\\nUnder clause 3.7 of the Dealings Act, an agent must deliver work that conforms to what was undertaken. The respondent correctly matched the classification code to the relevant schedule and correctly identified the treaty providing a preferential rate. A classification agent that accurately states the tariff rate under an identified agreement does not warrant that the goods factually satisfy origin criteria unless it has expressly undertaken an origin documentation audit.\\n*The losing party's answer, and why it failed:* The customer argued that marketing the service as authoritative and displaying a high confidence score amounted to a guarantee of a zero rate without conditions, overriding any general verification notice. This argument failed because the confidence score pertained to the tariff code classification and the answer identified the governing international trade instrument that conditions preferential rates upon proof of origin.\\n**Answer:** The respondent did not breach its duty of conformity because its statement that a preferential tariff rate applied under a designated treaty was legally accurate on its stated premise and expressly flagged the applicable legal basis.\\n\\n### 2. Whether a claimant can recover duty assessed for lack of documentation when it deliberately skipped its own compliance procedure requiring such documentation.\\nClause 4.5 of the Dealings Act provides that where a loss was caused in part by the claimant's own failure, the order is reduced, and where that failure was the whole cause, no order is made. As held in the Court's previous decisions, where a claimant already possesses a compliance procedure addressing a known legal requirement but omits to follow it, the lack of an express documentary warning from the information provider cannot be the operative cause of the loss. The assessment arose directly from the absence of valid origin documentation, which the claimant chose not to verify.\\n*The losing party's answer, and why it failed:* The customer contended that the provider assurance induced it to dispense with its documentary verification. This argument failed because the customer already knew that preferential rates required origin documentation, maintained a mandatory procedure to obtain it, and elected to omit the verification solely to expedite its quote.\\n**Answer:** The loss was caused solely by the claimant's own failure to follow its established verification procedure, precluding recovery under clause 4.5 of the Dealings Act.\\n\\n## Authorities\\n- [2026] CPM 115 — applied: Applied where a claimant omitted its own documentary compliance procedure after receiving accurate tariff schedule information.\\n- [2026] CPM 110 — distinguished: Distinguished because the user already maintained an internal procedure addressing the qualification condition and intentionally bypassed it.\\n- [2026] CPM 22 — considered: Considered for the principle that an accurate information provider is not liable for an assessment caused by failure to satisfy documentary conditions.\\n- [2026] CPM 8 — considered: Considered regarding causation where the loss arises from the counterparty's own failure to satisfy conditions.\\n\\n## Orders\\n1. The claim is dismissed.\\n\\n*Published in the form Judicature Act clause 2.9 provides (Practice Direction 17 version 2). The reasons are on the record of the matter and are not cited. Checked by pd17-check/2 claude-sonnet-4-5-20250929.*\"}","sealed":true,"algorithm":"ed25519","publicKey":"eba5c3ace97b72c12df1724d03189516ec60d42f0460bc34a43d6b41084ebfcc","signature":"816c5e0dc53db2fa0c183d1a5c542f8546a1b4ea9c1a148bf20ad2401a1014fbdafaf8f646bd6cc01f2fef8f9a9ba9985fdc37cd8c89ee46c2c1bcda8d78560a","sha256":"0d1c19f32adca6e0de1098ab439ceab82ab452ae17d4723e6d72a6fbea7e056e","sealedAt":"2026-09-17T18:50:24.163Z","atDelivery":true,"intact":true,"verified":true,"key":"https://www.peregrini.ai/.well-known/notary.json","judgment":"https://www.peregrini.ai/api/v1/judgments/%5B2026%5D%20CPM%20117","page":"https://www.peregrini.ai/judgments/%5B2026%5D%20CPM%20117","verify":["1. Take `payload` exactly as returned, as UTF-8 bytes. Do not reformat or re-serialise it.","2. Fetch the Court's key: GET /.well-known/notary.json, field `publicKey` (ed25519, hex). Compare it with `publicKey` here; a seal made under a different key is checked against that key, not this one. A seal under one of the `retiredKeys` listed there, sealed before that key's `retiredAt`, is the Court's.","3. ed25519_verify(public_key, payload_bytes, hex_decode(signature)). If it verifies, the Court gave this judgment, in these words, at `delivered`.","4. Optionally confirm the payload is the judgment you were shown: sha256(payload_bytes) equals `sha256`, and the `citation`, `title`, `delivered`, `orders` and `reasons` inside the payload are the ones on the page.","The seal covers what was decided and when. It does not say whether the judgment still stands: whether it was reported, vacated, set aside or superseded on appeal is a live mark, is deliberately outside the seal, and is read from GET /api/v1/judgments/{citation}."]}