When an owner or time charterer is asked for “switch bills” he must tread carefully. A letter of indemnity is little consolation.  In Brown Jenkinson v Percy Dalton a letter of indemnity indemnifying owners for issuing clean bills when the cargo was not in apparent good order, was held unenforceable even though the Owners did not ‘intend to defraud’ and only the tort of deceit had been committed.