The article provides the first comparative take on the issues surrounding the delivery of cargo without bill of lading in Polish legal literature. The author excludes Rotterdam Rules and domestic regulations of the subject as these call for further studies.

The author notes that bill of lading is recognized in legal systems all over the world as it remains the cornerstone of maritime trade, especially in the department of mass cargo transport. Divergences however do happen and they manifest themselves in several ways. The bill of lading may be substituted by avariety of waybills and shipping lists, as well as electronic negotiable instruments, the latter of which being already in use for years. None of these, however, seem to address the problem in every respect.

The author’s approach is rooted common law, the prevalent system in global maritime trade.