SLT Imports Inc v. SAR Transport Systems Pvt Ltd

── SLT Imports Inc v. SAR Transport Systems Pvt Ltd ── Court: Court of Appeals for the Third Circuit Date: May 28, 2026 Category: General U.S. COURT OF APPEALS FOR THE THIRD CIRCUIT No. 25-1549 SLT IMPORTS, INC., a New Jersey Corporation, Appellant v. SAR TRANSPORT SYSTEMS PVT LTD; DOES, 1 through 15. _____________________________ Appeal from the U.S. District Court, D.N.J. Judge Evelyn Padin, No. 2:23-cv-18484 Before: PORTER, MONTGOMERY-REEVES, and BOVE, Circuit Judges Submitted Apr. 7, 2026; Decided May 28, 2026 _____________________________ OPINION OF THE COURT PORTER, Circuit Judge. In this maritime shipping dispute, we are asked whether the Carriage of Goods by Sea Act’s (“COGSA”) one-year limitation period bars appellant’s fraud-in-the-execution claim. The District Court held that it does and granted judgment on the pleadings. We will affirm. I Appellant SLT Imports, a New Jersey-based importer, agreed to provide financing for non-party Krishna Food Corp. to import goods from non-party Bikaji Foods International, based in India. Defendant-Appellee SAR Transport Systems, based in India, was selected as the carrier of the cargo. Under this arrangement, Krishna would pay SAR for each delivery by drawing on SLT’s bank facility. “All purchases by Kirshna [sic] were to be made by and through SLT with SLT’s full real- time knowledge and consent.” Appendix (“App.”) at 54. These contractual obligations were memorialized in a Bill of Lading (“BOL”) for each shipment, on each of which Bikaji was listed as consignor, SLT as consignee, and SAR as carrier. The terms of the BOLs stipulated that, upon delivery, SAR would only release the goods to Krishna upon presentation of an endorsed BOL. The complaint states that SAR would issue the BOL. But the complaint is unclear as to which entity was responsible for endorsing the BOL. It alleges that SAR would turn the goods over to Krishna only “upon presentation and surrender of the original duly endorsed bills of lading.” App. at 55. Thus, SAR was not responsible for endorsing the BOL; rather, SAR would issue the BOL and then wait until it was endorsed before releasing the cargo. The complaint then alleges that an endorsed BOL would “only be available or provided to Krishna if it tendered payment on the facility to SLT’s bank.” App. at 54. Thus, it is implied that Krishna too was not responsible for endorsing the BOL; rather, it received an endorsed BOL from some other party. That leaves SLT. The complaint alleges that the endorsed-BOL requirement “protected SLT from any failure to pay on the part of Krishna” and “assured [SLT] that Krishna would pay for the goods sold to Krishna.” App. at 55. So, all told, the complaint suggests that once Krishna paid for the goods via SLT’s bank facility, SLT would endorse the BOL and provide it to Krishna. Krishna, in turn, would presumably submit the endorsed BOL to SAR in exchange for the transfer of the goods. In November 2021, SLT noticed it had not received interest payments from Krishna on its bank facility for six months. After conducting an audit, SLT discovered that SAR 2 had allegedly made 30 deliveries to Krishna without receiving an endorsed BOL for any of them, as was required.1 Instead, Krishna provided SAR with letters of indemnity noting on each that the BOL “has not arrived.” App. at 80–81. SLT sued SAR for fraud in the execution and breach of contract. SLT alleges that SAR breached its contracts by “releas[ing] the SLT Cargo . . . to Krishna without presentation and surrender of the original duly endorsed bills of lading.” App. at 70–71. And SLT claims “SAR defrauded SLT when it issued Bills of Lading with terms that SAR knew to be false”— i.e., that SLT would endorse the BOL prior to release of the cargo. Appellant’s Br. at 9