OBJECTIVES To point out the problems in the letter of credit To enunciate the advantages and disadvantages of letter of credit mechanism To detail upon the types of letter of credit which are used in various types of international trade transaction.

SIGNIFICANCE AND SCOPE OF THE STUDY

The scope of the topic significance of letter of credit in international commercial trade widens up to the examination and analysis of letter of credit.

REVIEW OF THE LITERATURE

The completion of this paper has required collection of relevant information through a number of books by renowned authors on international trade law and several websites. Since letter of credit is not a new concept, a plethora of information can be found easily.

RESEARCH METHODOLOGYThis project report is based on analytical and descriptive Research Methodology. Secondary and Electronic resources have been largely used to gather information and data about the topic.Books and other reference as guided by Faculty have been primarily helpful in giving this project a firm structure. Websites, dictionaries and articles have also been referred.HYPOTHESISInternational trade law is becoming prevalent nowadays. The letter of credit plays an important role in international trade from the inception of international trade and now its scope is increasing.

INTRODUCTIONLetter of credit is derived from the French word accreditation which means the power to perform or do something, which itself is derived from the latin term accreditivus which means trust. This applies to any defense relating to the underlying contract of sale. This situation is as long as the seller are committed to perform their duties to an extent that meet the requirements contained in the letter of credit.[footnoteRef:1] [1: BEWARE SELLERS!!!!!!!!! - Page 2 - The eBay Community, http://community.ebay.com/t5/Bidding-Buying/BEWARE-SELLERS/td-p/21973714/page/2 (accessed March 9, 2015).]

Most of the financial organization issues a document which is known as letter of credit which plays a primary role in trade finance, which provides an irrevocable payment undertaking.The letter of credit is also used for the payment of transaction which means that redeeming the letter of credit pays an exporter. It is the one of the important document which is used by many importers and exporters in international trade transaction

In such cases, the International Chamber of Commerce Uniform Customs and Practice for Documentary Credits applies (UCP 600 being the most recent form).[footnoteRef:2] They are likewise utilized as a part of land development and advancement methodology to guarantee that approved facility (roads, walkways, storm water lakes, and so on.) will be provided. The parties to a letter of credit are usually a beneficiary who is to receive the cash, the issuing bank of whom the beneficiary is a customer, and the instructing bank concerning whom the beneficiary is a customer. Pretty much, all letters of credit are irrevocable, i.e., can't be altered or wiped out without earlier assentation of the beneficiary, the issuing bank and the affirming bank, if any. In executing an transfer, letters of credit join capacities regular to giros and Traveler's cheques. Usually, the records or documents a beneficiary needs to present so as to get payment including commercial invoice, bill of lading, and a record demonstrating the shipment was guaranteed against damage or harm in transit. [2: Export Process, Flow & Documentation, http://rubaiyum.blogspot.com/ (accessed March 9, 2015).]

LETTERS OF CREDITUnder Article 2 UCP 600, a letter of credit is any arrangement, however named or described, whereby a bank (the issuing bank) acts at the request and on the instructions of a customer (the buyer/applicant) to make a payment to a third party (the seller/beneficiary) against stipulated document(s), provided that the terms and conditions of the credit are complied with. Once the buyer has concluded the contract with the seller in which a documentary credit clause has been incorporated, the buyer will request its bank (the issuing bank) to open a letter of credit in favour of the seller (the beneficiary). The buyer, as the applicant, will inform the issuing bank of the documentary requirements that it wishes to have inserted into the letter of credit. The issuing bank usually has its place of business in the buyer's country, whereas the seller operates from another country. Therefore the issuing bank may request a bank in the seller's country (which can be a branch office of the issuing bank) to take up the documents and make payment in its name (the advising or nominated bank -- Article 6a UCP 600).The nominated bank then forwards the documents to the issuing bank against reimbursement.[footnoteRef:3] [3: Electronic Library on International Commercial Law and the CISG, http://www.cisg.law.pace.edu/cisg/biblio/bijl.html (accessed March 21, 2015).]

All conditions stipulated in the letter of credit have to be documentary conditions. If a letter of credit contains conditions without stating the document(s) to be presented in compliance therewith, banks will deem such conditions as not stated and will disregard them (see Article 14h UCP 600). In other words, the buyer cannot require that the seller prove a fact that is not capable of being recorded in a document. All that he can require the seller to do is to submit documentation that records certain facts or conditions.The bank's promise to pay is conditional upon the seller presenting evidence that the goods have been shipped to the port of destination, along with the other documents required by the sales contract and thus stipulated in the letter of credit. With regard to the payment mechanism, the whole transaction is based purely on documentation that the bank checks for compliance against the letter of credit; the documents are deemed to represent the goods. The result is that neither party to the transaction controls both the goods and the money at the same time. These requirements are essentially designed to ensure that the seller submits documentation that records its compliance with its obligations under the underlying sales agreement,as well as to restrict the bank's involvement to the examination of the documents. The bank deals with documents, not with goods (see Article 5 UCP 600).Types of Letter of CreditLetters of credit in terms of opening bank commitments include[footnoteRef:4]: [4: The Role of Letter of Credit in International Trade, http://www.cprenet.com/uploads/archive/UJMSS_12-1291.pdf (accessed March 9, 2015).]

Revocable Letter Of Credit: This credit cant be given or changed by opening bank of credit and credit partners and the affirming bank. Affirmed letter of credit: It is letter of credit that an alternate bank notwithstanding opening bank credit responsibility to installment acknowledges and transfers, if documents needed to be given under the terms of credit. Affirming bank acknowledgement can be same as bank imparted or an alternate bank. Furthermore sorts of credit regarding transmission limit include: 1. Transferable Credit : It is irreversible letter of credit that beneficiary has the privilege to request the bank to approve keeping in mind the end goal to sensible payment or to transfer that aggregate or fractional credit will be accessible to the beneficiary or beneficiaries of auxiliary, dependent upon that be transferable is unmistakably expressed. 2. Consecutive letter of credit: Beneficiary of the letter of credit may be mediated dealer and have been deals concurrence with an alternate merchant to supply merchandise under to his/her dedication to unique credit purchaser. On account of credit transferable and demanded second dealer or merchants to pay by letter of acknowledge will meet for transfer credit of this requests however without transferable credit, the first merchant by depended and backed first credit can demand to opening credit for vender or sellers supplier of merchandise. 3. Rotating Credit: It suggests to credit that in it a condition utilization of measure of the credit will consequently be given again without correction.

Basis components of letter of creditCandidate: The person requesting the letter of credit, generally the shipper in a grain transfer. The Issuing Bank: The bank that issues the letter of credit and accepts the commitment to make installment to the beneficiary, usually the exporter. Beneficiary: The person in whose support the letter of credit is issued, usually the exporter in a grain transfer. Sum: The whole of cash, usually communicated as a greatest sum, of the credit characterized in a particular currency. Terms: The necessities, including records and documents that must be met for the accumulation of the credit. Expiry: The last date for the beneficiary to present against the credit.

DOCUMENTS THAT CAN BE PRESENTED FOR PAYMENTTo get payment, an exporter or shipper must present the documents needed by the letter of credit. Commonly, the payee shows a report demonstrating that merchandise was sent as opposed to representing the genuine products. The Original Bill of Lading is usually the documents acknowledged by banks as evidence that merchandise have been dispatched. In any case, the rundown and type of documents is interested in creative ability and transaction and may contain prerequisites to present records issued by an impartial outsider proving the nature of the products delivered, or their spot of birthplace or spot.Typical types of documents in such contracts might include: 1. Financial Documentsa. Bill of Transfer, Co-accepted Draft2. Commercial Documentsa. Invoice,Packing list3. Shipping Documentsa. Transport Document, Insurance Certificate, Commercial, Official or Legal Documents4. Official Documentsa. License, Embassy legalization, Origin Certificate, Inspection Certificate,Phytosanitary certificate5. Transport Documentsa. Bill of Lading(ocean or multi-modal or Charter party), Airway bill, Lorry/truck receipt, railway receipt, CMC Other than Mate Receipt, Forwarder Cargo Receipt, Deliver Challan...etc6. Insurance documentsa. Insurance policy, or Certificate but not a cover note.[footnoteRef:5] [5: Letter of credit - Wikipedia, the free encyclopedia, http://en.wikipedia.org/wiki/Letter_of_credit (accessed March 9, 2015).]

Standard Forms of DocumentationAt the point when making payment for item in the interest of its client, the issuing bank must confirm that all reports and drafts adjust correctly to the terms and conditions of the letter of credit. In spite of the fact that the credit can oblige a show of records, the most well-known documents that must go with the draft include:Commercial invoiceThe charging for the products and administrations. It incorporates a depiction of stock, value, FOB birthplace, and name and location of purchaser and dealer. The purchaser and vender data must compare precisely to the portrayal in the letter of credit. Unless the letter of credit particularly states generally, a generic description of the stock is typically worthy in the other going with reports.

Bill of LadingIt is a document which shows that a particular goods is received by the concerned carrier and it is issued by them. The documents mark control of merchandise. They likewise serve as a receipt for the stock dispatched and as confirmation of the bearer's commitment to transport the merchandise to their proper destination. Warranty of Title A warranty given by a merchant to a purchaser of merchandise that expresses that the title being passed on is great and that the transfer is legitimate. This is a strategy for confirming clear title to item transfer. It is for the most part issued to the buyer and issuing bank communicating consent to repay and hold both sides harmless. Letter of Indemnity It particularly repays the buyer against a certain expressed situation. Indemnification is generally used to guaranty that shipping documents will be provided in good order when available. LETTER OF CREDITLegal principles governing letters of creditOne of the essential characteristics of the documentary credit is that the payment commitment is unique and autonomous from the basic contract of offer or some other contract in the transfer. In this manner the bank's commitment is characterized by the terms of the credit alone, and the sale contract is irrelevant. The protections of the purchaser emerging out of the sale contract don't concern the bank and not affects its liability. Article 4(a) UCP states this principles clearly. Article 5 the UCP further expresses that banks only deals with documents; they are not concerned with the products (realities). Accordingly, if the documents tendered by the beneficiary, or his or her agents, give off an impression of being in place, then as a rule the bank is obliged to pay without further capabilities. Strategies behind adopting the abstraction principle are simply business, and reflects a party's desires: in the first place, if the obligation regarding the legitimacy of records was tossed onto banks, they would be troubled with examining the fundamental certainties of every transfer, and would hence be less slanted to issue narrative credits as the transaction would include incredible hazard and disadvantage. Second, documents needed under the credit could in specific circumstances be not quite the same as those needed under the sale transaction. This would place banks in an issue in choosing which terms to take after if needed to look behind the credit agreement. Third, it is a well-known fact that the most important basic function of the credit is to provide a seller with the certainty of payment for documentary duties which suggests that the banks should honor their obligation notwithstanding allegations of misfeasance by the buyer.. At last, courts have emphasized that purchasers dependably have a solution for an activity upon the agreement of offer, and that it would be a disaster for the business world if, for each breach of agreement between the merchant and purchaser, a bank were obliged to explore said break. The "principles of strict compliance" additionally aims to make the bank's obligation of effecting payment against easy documents, effective and brisk. Subsequently, if the documents tendered under the credit go amiss from the language of the credit the bank is qualified for withhold payment regardless of the fact that the deviation is absolutely terminological. The general lawful proverb de minimis non curat lex has no spot in the field of documentary credits. Letter of credit additionally refers to FIATA documents. More strictly, by and by cargo forwarders common present FIATA documents and the inquiry is does FIATA documents can use like a document for initiating letter of credit. In principle, the inquiry is not clear, as a result of the shortcoming in UCP 600.The Principle of IndependenceIn transactions involving a letter of credit, the bank is not party to the underlying contract. As such, letters of credit have an abstract character. This implies that the bank is not concerned with the specifics and the actual performance of the underlying contract. The conditions of the bank's duty to pay are to be found exclusively in the terms of the letter of credit and do not in any way depend on the performance of the seller's obligations under the contract of sale.Article 4(a) UCP 600 stipulates that:'Credit by its nature is a separate transaction from the sale or other contract on which it may be based. Banks are in no way concerned with or bound by such a contract, even if any reference whatsoever to it is included in the credit. ...'Accordingly, when deciding whether to make payment under the credit in favour of a beneficiary, the bank may only look at the terms of the credit itself. The bank may not raise any defenses that are available to the applicant in respect of the underlying agreement of sale.The seller will thus always receive payment from the bank if he submits documents that comply with the credit, regardless of any developments in the underlying sales agreement. The bank should not be forced into the position in which it has to resolve disputes between the seller and buyer, because this would lead to extensive delays in payment and would make theletter of credit unattractive as a commercial service.If the doctrine of independence is not scrupulously observed, the continuance of the letter of credit system as the primary means of payment in international trade would be in danger. The only exception to the principle of independence is fraud committed by the beneficiary when tendering the documents. As Dr Royhas stated: 'No system can be effective if it is blind to something which is manifestly unreasonable.' If the bank discovers fraud in the documents that were tendered by the beneficiary, it is entitled to refuse payment even though the documents appear to be in conformity with the terms of the letter of credit. This entails that the beneficiary, if he had been truthful in his representations, would have tendered documents that did not strictly comply with the terms of the letter of credit. The fraud, however, must be clear and evident to the bank, without the need for additional proof or having to investigate the actual circumstances surrounding the underlying contract. A mere suspicion of fraud is not sufficient to set aside the independence principle.Thus, even if a bank suspects fraud, it is obliged to pay under the letter of credit if the beneficiary has tendered documents that are in conformity with the letter of credit.

Elements of a letter of credit A payment undertaking given by a bank (issuing bank). On behalf of a buyer (applicant). To pay a seller (beneficiary) for a given amount of money. On presentation of specified documents representing the supply of goods. Within specified time limits. Documents must conform to terms and conditions set out in the letter of credit. Documents to be presented at a specified place.[footnoteRef:6] [6: Understanding and Using Letters of Credit, Part I - CRF online, http://www.crfonline.org/orc/cro/cro-9-1.html (accessed March 9, 2015).]

Characteristics of letter of credit Negotiability

Letters of credit are usually negotiable. The issuing bank is committed to pay the beneficiary, as well as any bank named by the beneficiary. Negotiable instruments are passed unreservedly starting with one party then onto the next pretty much in the same path as cash. To be negotiable, the letter of credit must incorporate a clear guarantee to pay, on interest or at a clear time. The nominated bank turns into a holder at the appointed time course. As a holder in the appropriate time course, the holder assumes the letter of acknowledgment for value, in good faith with common decency, without notice of any cases against it. A holder at the appropriate time course is dealt with positively under the UCC. The transfer is viewed as a straight transaction if the issuing bank's payment commitment stretches out just to the beneficiary of the credit. In the event that a letter of credit is a straight transaction it is referenced all over by "we captivate with you" or "accessible with ourselves". Under these conditions the guarantee does not go to a buyer of the draft as a holder at the appropriate time course.

RevocabilityLetters of credit may be either revocable or irrevocable. A revocable letter of credit may be revoked or changed for any reason, whenever by the issuing bank without warning. A revocable letter of credit can't be affirmed. On the off chance that a journalist bank is occupied with an transfer that includes a revocable letter of acknowledge, it serves as the prompting bank. [footnoteRef:7] [7: Letters Of Credit - Creditworthy, http://www.creditworthy.com/3jm/articles/cw041906.html (accessed March 9, 2015).]

When the reports have been presented and meet the terms and conditions in the letter of credit, and the draft is regarded, the letter of credit can't be renounced. The revocable letter of credit is not a usually utilized instrument. It is generally used to give rules to shipment. In the event that a letter of credit is revocable it would be referenced all over. The irrevocable letter of credit may not be revoked or revised without the understanding of the issuing bank, the affirming bank, and the beneficiary. An irrevocable letter of credit from the issuing bank protects the beneficiary that if the obliged records are displayed and the terms and conditions are consented to, payment will be made. On the off chance that a letter of credit is permanent it is referenced all over. Transfer and Assignment

The beneficiary has the privilege to transfer or allot the privilege to draw, under a credit just when the credit expresses that it is transferable or assignable. Credits administered by the Uniform Commercial Code (Domestic) perhaps transfers a boundless number of times. Under the Uniform Customs Practice for Documentary Credits (International) the credit may be transfer just once. Then again, regardless of the possibility that the credit details that it is nontransferable or non-assignable, the beneficiary may transfer their rights before execution of states of the credit.

Sight and Time Drafts All letters of credit require the beneficiary to present a draft and indicated records with a specific end goal to get payment. A draft is a composed request by which the party making it, requests an alternate party to pay cash to an outsider. A draft is additionally called a bill of TRADE.[footnoteRef:8] [8: Letters Of Credit - Creditworthy, http://www.creditworthy.com/3jm/articles/cw041906.html (accessed March 9, 2015).]

There are two sorts of drafts: sight and time. A sight draft is payable when it is presented for payment. The bank is permitted a sensible time to audit the reports before making payment. A period draft is not payable until the breach of a specific time period expressed on the draft. The bank is obliged to acknowledge the draft when the reports conform to credit terms. The issuing bank has a sensible time to analyze those documents. The issuing bank is committed to acknowledge drafts and pay them at development. Standby letter of credit

The standby letter of credit serves a different function than the business letter of credit. The business letter of credit is the essential payment instrument for an transfer. The standby letter of acknowledge serves as an optional payment system. A bank will issue a standby letter of credit for a client to give affirmations of his capacity to perform under the terms of an agreement between the beneficiaries. The parties involved with the transaction don't expect that the letter of credit will ever be drawn upon. The standby letter of credit guarantees the beneficiary of the execution of the client's commitment. The beneficiary has the capacity draw under the credit by exhibiting a draft, duplicates of receipts, with confirmation that the client has not performed its commitment. The bank is committed to make payment if the reports comply with the terms of the letter of credit. Standby letters of credit are issued by banks to remain behind fiscal commitments, to safeguard the discount of development payment, to help execution and offer commitments, and to protect the finish of a business contract. The credit has a expiry date. The standby letter of credit is frequently used to ensure execution or to fortify the credit value of a client. In the above case, the letter of credit is issued by the bank and held by the supplier. The client is given open record terms. On the off chance that payments are made as per the suppliers' terms, the letter of credit would not be drawn on. The merchant seeks after the client for payment directly. On the off chance that the client is not able to pay, the vender exhibits a draft and duplicates of receipts to the bank for payment. Limitation of Letter of CreditThe utilization of letter of credit is the most widely recognized methodology for imports from different nations in the cutting edge world and banks opening of letter of credit. Clearly, the absence of backup for the keeping money has made genuine restrictions for industrialists and those included in the import and fare of merchandise. 1. Absence of supporting banks in opening letter of credit from the builders who have little credit and absence of acknowledge organisation by the banks. 2. Related deferrals to letter of credit stretched out because of political conditions, changes in laws and regulations, administration TRADE. . . 3. In a few bargains that payments to outside organizations is carried out through opening a letter of credit, once in a while prolongation of opening procedure prompted postpones in payment, defers in getting credits and eventually making crevices in monetary administration of venture and issues in money related arranging builder. 4. Complex administration of the boss to open letter of credit and therefore force expenses coming about because of the deferral in the opening of foreman causes that in a few activities, gear acquired and prepared to delivered however not yet issued letters of credit and is in the labyrinth of organization.

THE ROLE AND SIGNIFICANCE OF LETTER OF CREDIT IN INTERNATIONAL TRADEOffers of products and administrations to outside purchasers have more contradictory dangers that develop for exchanging the local business sector. Irreconcilable situations and newness and guarantee purchaser and dealer together is brought on that making system called letter of credit that consider premiums of both purchaser and merchant and halfway adjust the dangers of contracting parties, so that give documentation conveying merchandise to a third organization (bank) was viewed as characteristic of conveyance of products and as per it the payment done through bank .Letter of credit payment component is, for example, blood stream in assortment of global transfers. Letter of Credit, because of the need to have essential significance in global transfers is free of the mother or the first transfer of procurement and deal and hence particular issues independently from it.[footnoteRef:9] [9: The Role of Letter of Credit in International Trade, http://www.cprenet.com/uploads/archive/UJMSS_12-1291.pdf (accessed March 9, 2015).]

These days banks assume a vital part in encouraging residential and global business TRADEs and transfers. Particularly in arena of global transfer can guaranteed that no transfer or universal contract don't be without the contribution and help of banks in light of the fact that innovation and utilization different instruments of bank, for example, letter of credit and bank assurances tackled a large portion of the issues created by separation and direct contact between worldwide merchants, while keep up two noteworthy qualities of organizations means the velocity and precision.Significance of letter of creditThere are a number of uses of a letter of credit. These can be used as a mode of payment in the transactions. There are a number of exporters who receive payment through these modes. The letter of credit is becoming a crucial part of the land development processes where it ensures growth of the public facilities.[footnoteRef:10] On the other hand, the letter of credit is becoming very important for the international trade and commerce. It provides an easy transaction system for the businesses where customer and the supplier belong to different nations. [10: http://finance.mapsofworld.com/credit/letter.html (accessed on March 12, 2015)]

They can be summarized:(a)Distance.(b)Different legal system.(c)Currency system.(d)Trade rules are different.Other important significances are :-1. The Letters of Credit give importers the most extensively used and conventional international trade payment means and finance instrument. By making Letter of Credit terms to permit Deferred Payment or Trade Acceptance, a Letter of Credit facilitates financing to the importer. It promises payment, provided the seller complies with the terms and conditions inside the Letter of Credit. The Irrevocable letter of credit cant be canceled or varied without the approval of all parties.2. Letters of Credit provide importers the most broadly used and accepted worldwide trade payment mechanism and business instrument. By structuring Letter of Credit terms to permit Deferred Payment or Trade Acceptance an letter of credit can be operated to offer funding to the importer. Most prominently global trading has a whole lot of money involved and if done appropriately could build up a turnover capable of running a nation states budget; hence it is significant that it is managed with care.Significance for buyer and sellerLetter of credit advantages for the seller The seller has the obligation of buyer's banks to pay for the shipped goods; Reducing the production risk, if the buyer cancels or changes his order The opportunity to get financing in the period between the shipment of the goods and receipt of payment (especially, in case of deferred payment). The seller is able to calculate the payment date for the goods. The buyer will not be able to refuse to pay due to a complaint about the goods

Letter of credit advantages for the buyer The bank will pay the seller for the goods, on condition that the latter presents to the bank the determined documents in line with the terms of the letter of credit; The buyer can control the time period for shipping of the goods; By a letter of credit, the buyer demonstrates his solvency; In the case of issuing a letter of credit providing for delayed payment, the seller grants a credit to the buyer. Providing a letter of credit allows the buyer to avoid or reduce pre-payment.OPERATIVE INSTRUMENT FOR LETTER OF CREDITA letter of credit may be issued by:1. AIRMAIL:When issued by airmail, the standard format of the bank is filled in with the relevant details, signed by the authorized signatories of the bank and mailed to the advising bank.

2. TELECOMMUNICATION: Where the letter of credit is to be issued by telecommunication, full details of the credit are cabled/ telexed to the advising bank. Opening of a letter of credit by telecommunication is of course costly. It is resorted to only when the applicant requires it and on his account.[footnoteRef:11] [11: Kaushik Mhatre, International Trade ,(Eastern Book Company) Third edition, Pg 108]

CONCLUSIONIn global transfer that included dangers, for example, absence of commonality the transferd individual, absence of coin, and separation, payment strategy needed to back its specialists to transfer. Letter of acknowledge is perceived as fitting payment strategy and acquiring credit for purchasers and merchants in global transfers. Letter of Credit is duty opening bank credit to pay the cases of the beneficiarys as per the terms stipulated in credit that incorporate diverse sorts and each of them gives distinctive profits and different to beneficiarys. Development and utilization different apparatuses of bank, for example, letter of credit and bank assurances tackled huge numbers of the issues brought on by separation and direct contact between worldwide merchants lastly the pace and exactness.It is stressed here once again that one of the main principles of the CISG is the preservation of the contract. In letter of credit transactions as well, the avoidance of the contract is a remedy of last resort. Only after all else has failed should a buyer be entitled to avoid the contract. This decision should not be taken lightly. Both parties have, first and foremost, an obligation to uphold their end of the bargain and not to hinder the performance by the other party.

BIBLIOGRAPHY Indira carr, International Trade Law and the WTO the federation press (Australia).

Aggarwal, Aradhna., The anti-dumping agreement and developing countries, Oxford University Press, (New Delhi : | New York )

REFERENCE FOR ARTICLES1. Bergami Robert, (2007), Will the UCP 600Provide Solutions toLetter ofCredit Transactions?International Review of Business ResearchPapers, Vol.3 No.2, June 2007, Pp. 41 - 532.Dolan John, (2007),2. The law of letters of credit The Wayne State University Law School Legal Studies Research, Vol 1, April 2007, p149.3. Klien Carter,(2005), Using Letters of Credit to Secure Lease Obligations,Law journal Newsletter, Vol 18, No 4, September 2005, p.585

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