Legal Considerations of the Sale of Diverse Goods

provides for sale of different kinds of goods

Introduction

The Sale of Goods Act 1979 (SGA 1979) provides for sale of different kinds of goods, which may be specific or unascertained goods. The SGA 1979, s. 61(1) describes specific goods as those which are identified at the time of the contract. The Act does not provide a definition of unascertained goods, save that these are those goods that are not specific. It is important to define the nature of the goods involved in a particular contract because the passing of the property from the seller to the buyer will depend on the definition of goods. This has implications for the rights and liabilities of the parties under the sale of goods contract.

In this scenario, the issues are:

The passing of property in the inflatable Christmas tree

The first issue in the scenario is whether the property in the inflatable Christmas tree has passed to Casa Nautica. In other words, can Casa Nautica claim that they have not received the inflatable Christmas tree from Inflatable Objects Limited.

The relevant legislation in this case is the Sale of Goods Act 1979 (SGA 1979). S.17(1) of the SGA 1979 provides that in cases of sale of specific and ascertained goods, property in the goods passes to the buyer only at such time when the parties to the contract have intended such property to pass to the buyer. This is to be construed as per the terms of the contract, circumstances of the case, and the conduct of the parties.

Where the parties have not specified when the property is to pass to the buyer, then SGA 1979, s.18 comes into play.[2] If the sale of goods contract is unconditional and the goods are in a deliverable state, the property shall pass to the buyer immediately.[3] The property in the goods does not pass to the buyer, until all that the seller is bound to do to the goods to put them in deliverable state, is done by the seller. This rule is provided in s.18, Rule 2 of the SGA 1979. The provision specifically states that where there is a contract for the sale of specific goods and the seller is bound to do something to the goods for the purpose of putting them into a deliverable state, the property passes to the buyer only when the thing is done and the buyer receives the notice of the same.[4] This was also the case in Underwood Limited v Burgh Castle Brick and Cement Syndicate.[5] In this case, a horizontal condensing engine was agreed to be sold at a price free on rail in London. The engine was bolted to and embedded in a flooring of concrete and it had to be detached and dismantled from the concrete before delivery to the buyer. The engine was damaged by the sellers as they were in the process of detaching and later loading it on a truck. The court held that the property in the engine had not passed to the defendants.[6] In Rugg v Minett,[7] the court held that property had not passed to the buyers as the sellers were supposed to top up the casks of the turpentine before delivering, and while doing so, the casks caught fire and the goods were destroyed.

In the present situation, Inflatable Objects Ltd. were required to inflate and secure the inflatable Christmas tree on the roof of the Superstore owned by Casa Nautica. While performing this task, the tree was punctured and it exploded. Thus, the tree was destroyed by the employees of Inflatable Objects Ltd. The property in the tree had not as yet passed to Casa Nautica, as per the provisions of the SGA 1979, specifically ss. 17 and 18.[8] By applying the provision contained in s.18, Rule 2,[9] it is seen that the property in the inflatable tree would have passed to Casa Nautica only when Inflatable Objects had done everything required to be done before making the delivery, in this case, inflating and securing the tree. To conclude, the property in the tree had not passed to Casa Nautica at the time of the explosion.

The passing of the risk in the inflatable tree

The second issue that arises in this case is whether the risk has passed to Casa Nautica for the inflatable tree. This question arises because the inflatable tree has been destroyed, before it was delivered to Casa Nautica as per the terms of the contract. Therefore, property has not as yet passed to Casa Nautica.[10] Conversely, if the risk would have passed to Casa Nautica, then it could not have claimed a refund of any amount paid by them to Inflatable Objects Ltd. Moreover, they will be required to pay any remaining amount that is payable from them to Inflatable Objects Ltd.

The rule that is applicable to this issue is contained in s. 20(1) of the SGA 1979, which provides that the goods remain at the seller's risk until the property in them is transferred to the buyer. In other words, the transfer of the property in the goods to the buyer will also transfer the risk to the buyer.

In Pignataro v Gilroy,[11] the court held that where the property has passed to the buyers, the risk will also pass, irrespective of whether or not actual delivery is taken by the buyer. In Sterns, Limited v Vickers Limited,[12] the court held that where the buyer has committed some action specifying his acceptance of the delivery of the property in the goods, the risk in the same also passes to the buyer. Clearly, the risk passes to the buyer only when the property is transferred to the buyer. The only exception to this is if the parties specifically agree to pass the risk to the buyer before the property is transferred to the buyer.[13] Therefore, the parties can provide retention of title clauses, whereby the seller can retain the title in the property, while passing the risk to the buyer.[14] This however, has not been done by the parties in the present case.

Applying the above analysis to the present situation, the property in the inflatable tree had not as yet passed to Casa Nautica, because before the passage of the property, Inflatable Objects Ltd. were required to inflate and secure the tree on to the roof of the superstore. The tree exploded due to a puncture before this act could be completed by the employees of Inflatable Objects Ltd. Therefore, it is concluded that the risk in the goods not having yet passed to Casa Nautica, they are entitled to claim a refund of the amount paid for the purchase of the tree or a replacement of the same.

The liability for the damages to be paid for loss of profits due to the damage caused by the explosion of the inflatable tree

The third issue in the situation is regarding liability for the damage caused to the store by the explosion of the inflatable tree. Casa Nautica had to be shut for urgent repairs due to the damage caused to its roof by the explosion of the tree. The period during which the store was closed is one of the busiest weekend of the year. Therefore, the question arises whether Casa Nautica can claim damages from Inflatable Objects Ltd for the loss of profits suffered by it due to the damage to the store.

The rule of consequential damages is used to claim damages for lost profits due to the act or omission of the defendant. In Western Web Offset Printers Ltd v Independent Media Ltd,[15] it was held by the Court of Appeal that not only was a person entitled to net profits lost due to the breach of contract, a person is also liable to bring an action for any other profits lost as well as the overheads.

Applying this principle to the present case, it is submitted that Casa Nautica lost profits due to the breach of contract and negligence of Inflatable Objects Ltd. and therefore, it must be compensated for the loss of profits.

In this scenario, the issues are:

Breach of condition and its impact on the contract

The first issue in this situation is whether there is a breach of contract by Casa Nautica in supplying the wrong Christmas trees to Geneve. A breach of contract would occur when there is a breach of condition by Casa Nautica.

It is also pertinent to draw a distinction between terms of the contract and mere representations. Promises made by the parties are terms and statements that are made by the party without the intention of being bound is a representation. [17] The importance of such statement to the contracting parties can help determine the importance of the statement.[18] If the statement led to the influencing of the party to enter into the contract, it will be a term.

The effect of a breach of condition is that the contract itself is treated as repudiated by the buyer.[20] Thereupon, the buyer can reject the goods and demand compensation from the seller.[21] If the term breached is a warranty, the buyer cannot repudiate the contract and nor can he reject the goods. However, for breach of warranty, damages can be asked for by the buyer.

The SGA 1979 provides certain conditions that are inherent in a contract for sale of goods. The SGA 1979, s.13 provides that the goods shall correspond to the condition of the goods as described. The SGA 1979, s.14(2) provides that the goods will be of a satisfactory quality and s.14(3) provides that goods will be fit for the purpose for which they are purchased. These three conditions are engaged in this particular scenario, as the Christmas trees must correspond to the description: ‘Christmas Trees, New Variety: Forever Green – will retain needles for at least four weeks!’. The satisfactory quality and fitness of the purpose also relate to the ability of the trees to remain green for a certain period of time, as that is specifically mentioned by Geneve at the time she is purchasing the trees.

Geneve has informed the manager of Casa Nautica (Mr Woods) about the purpose for which she is buying the trees. She told him that she wanted to use the trees as scenery for her theatre company’s Christmas show called ‘A Winter Skating Extravaganza.’ For the purpose to serve, the trees are to retain their needles for the period as advertised. Therefore, it can be said that it is a condition of the contract that the Christmas trees ‘Forever Green’ will remain green for the period specified and not loose their pine needles.

As far as the specific provisions that are attracted in this case, it is submitted that the description “Christmas Trees, New Variety: Forever Green – will retain needles for at least four weeks!” relates to the quality of the goods and not the description of the goods, therefore, s.14 (2) and (3) are engaged in this problem. This is as per the decision of the court in Ashnigton Piggeries Ltd v Christopher Hill Ltd.[23] As these conditions are breached in this case, Geneve can exercise her right to repudiate the contract and ask for the refund of the amount for the supply of the inferior trees.

Damages for the special loss suffered by Geneve

The second issue in this scenario is whether Casa Nautica will be liable to pay consequential and special damages to Geneve.

Geneve may ask for consequential damages of the breach. Consequential damages can include loss of profits due to the failure of the other party to abide by the terms of the contract. For consequential damages to be recoverable, an important condition is that such damages must be reasonably foreseeable at the time of the formation of the contract. As per the decision in Hadley v Baxendale,[24] wherein the Court of Appeal held that the plaintiff can be allowed to recover generally foerseeable losses only, the plaintiff will have to show that the losses were foreseeable by the defendant. Here, the plaintiff may show loss of profits as the generally foreseeable losses of the breach of contract as done in the case of Bacon v Cooper Medicals Ltd.

Special damages are payable when the loss suffered by the plaintiff is due to the special or unusual circumstances of the case.[26] For this to happen, the loss suffered by the plaintiff must not be attributable to the natural and probable consequences of the breach of the contract. In other words, the loss suffered by the plaintiff must not be a direct loss but it must be an indirect loss of the breach of contract. For the special damages to be recoverable, the special circumstances must be informed to the defendant at the time of entering into the contract as held in Hadley v Baxendale. [27] Finally, the losses should not be remote losses and the principle of remoteness is to be applied for ascertaining the losses and recoverable damages.

Applying the above analysis to the present case, it is seen that the foreseeable losses that could be considered at the time of the contract could not have been loss of ticket money. However, the special circumstances of the case were informed to the manager of Casa Nautica at the time of entering into the contract. These special circumstances were for the use of the trees for the theatre company’s Christmas show called ‘A Winter Skating Extravaganza’. Due to the poor and inferior quality of the trees, as compared to the one advertised, that is, ‘forever green’ trees, the show has been a failure. 27 people in the audience complained and were paid 405 GBP in refunds; and another 7,095 GBP were paid due to the problems faced by the skaters in the melting snow in the rink. While the former is a foreseeable loss, the latter was not foreseeable loss. As the special circumstances of the Christmas show were informed to Casa Nautica, the liability to pay special damages of 7,095 GBP will arise.

To conclude, Casa Nautica is liable to pay special damages (7,095 GBP) to Geneve for the loss of tickets through refunds due to the failure of Casa Nautica to sell goods that conformed with the description and fitness for the purpose.

In this scenario, the issues are:

Liability for the damage to industrial refrigerator due to light fuse

The first issue which arises in this situation is whether Casa Nautica is liable for the damage caused to the industrial refrigerator due to the fusing of lights bought from Casa Nautica.

The SGA 1979 provides that the goods sold by the seller shall be in corresponding format to the condition of the goods as described.[30] The SGA 1979, s. 14(2) provides that the goods will be of a satisfactory quality. Furthermore, the SGA 1979, s. 14(3) provides that goods will be fit for the purpose for which they are purchased. These are conditions of the sale of goods and non-conformity with the conditions can lead to the breach of contract and the liability for the breach.

In the present case, Paolo was informed by an employee at Casa Nautica that the lights are for indoor use only. The notice was written on the packaging of the lights and pointed out to Paolo by the salesman at the superstore. Nevertheless, Paolo chose to use the lights for outdoor purpose. He has purposefully chosen to disregard instructions given to him for the correct usage of the lights.

The case that is relevant here is that of Lambert v Lewis[31], in which the court held that if the buyer uses the goods in a manner that is contrary to the proper usage practice of the goods, then there is no breach of the SGA 1979, s.14(3) and the buyer cannot say that the goods are unsatisfactory or unfit for purpose for which they were bought.

Applying the above analysis to the facts of the case, it can be said that Casa Nautica bears no responsibility for the loss that is suffered by Jonathan as the latter has misused the product for a purpose that the product is not fit for, that is outdoor use.

Sale of salami and cheese to Casa Nautica by Jonathan

The second issue in this situation concerns the validity of the sale of salami and cheese by Jonathan to Casa Nautica.

S. 21(1) of SGA 1979 applies in situations where the goods are sold by a person who is not the owner of the same and does not have the authority to sell the goods by the owner of the goods. The rule is also contained in the maxim “Nemo Dat Quod Non Habet” , which means that no person can transfer a better title to goods than that possessed by himself.[32] The SGA 1979, s.21(1) provides an exception in the situation where the owner of the goods is by his conduct precluded from denying the seller’s authority to sell.

In Bishopsgate Motor Finance Corp Ltd v Transport Brakes Ltd,[33] it was held that no one can give a better title than he himself possesses, but a person who takes in good faith and for value without notice should get a good title. This can be understood from another case, Rowland v Divall,[34] in which the court has held that the title of the buyer in good faith is protected under the law.

In the present case, an estoppel by representation is also not created by Paolo as he moved the goods into Jonathan’s van out of necessity and as per the principle laid down in Jerome v Bentley & Co[35] if the true owner of the goods gives the possession of the goods to a third party an estoppel by representation is not created.

Jonathan does not have a title to pass to the Casa Nautica. Therefore, the goods must be returned to Paolo by Casa Nautica.

Bibliography

From the Western perspective, the increasing attraction to once colonial lands, is generally attributed to the attraction towards the exotic, indigenous and colonial, be it peoples, customs, artefacts, arts and crafts or lifestyle. Here otherisation is from the Western perspective, where all that is Oriental, is exotic and indigenous. Here the power to define what is exotic and indigenous is from the Western side. Everything that is not Occidental, must be exotic and ‘native’. Thus, the structures of knowledge and power are in the hands of the Western thinkers, writers and researchers. However, cultural idea is not a stagnant idea. It is, as Clifford (1988, p.9) writes, “an ongoing process, politically contested and historically unfinished.” This process is an important aspect of tourism studies as a lot of tourism discourse also revolves around cultural politics (Hall and Tucker, 2004, p.13).

Undoubtedly, postcolonialism has impacted to a great extent, the theories within tourism studies as well. Issues of identity, representation, the studies on the nature and implications of the political, cultural and economic encounters have regularly made references to postcolonial discourse (Hall and Tucker, 2004).

Ashcroft et al (1989) wrote that postcolonial theory, in both literature and scholarship is the result of the European inability to deal with the cultural complexities of the postcolonial texts.

Finnstorm (1997) wrote that colonial hegemony could not be the only source of power and cultural construction and the local populations cannot be reduced to “passive objects of cultural formation”. This has the undesired effect of homogenising postcolonial situations and objectifying postcolonial subjects (Finnstorm, 1997). On Community Development Programmes

Community based development programmes have been undertaken in different parts of the world as they are seen as more participative in nature, where the marginalised sections too stand to gain from such projects. For example, in the 1990s, communities in the St. Vincent region, Kenya, were involved in community based developmental programmes, which focussed on ‘nature tourism’. These communities found the programmes to their benefit and Zappino (2005, p.4) critiques the tourism sector in the Carribean region because the local community development is not considered by the system as it is “essentially managed by partnerships among international hotel chains, air companies and tour operators that are promoting all-inclusive holidays.” He also writes that the mass-tourism arrivals in the region are a threat to the environment and advocates a development of a more sustainable development model of tourism. Zappino (2005, p.5) argues that tourism also has collateral effects which are both environmental and social, and that these are seriously threatening sustainable development. These criticisms are the reasons why community development projects are encouraged in the first place. Thus, an important question is whether community development programmes' capacity to offer benefits of sustainable development can be seen in isolation from the impact of these programmes on the power structures of defining community and culture. Therefore, the critique of the community development projects must take into consideration these experiences as well. In a more stringent critique, he says that “postcolonialism is divorced from postcolony.”

Creative tourism, which is also on the rise, worldwide, is also mindful of community. McNulty (2010, p.72), writes that “tourism is too important to be left to the marketers. It needs to be owned and managed by the community to ensure that the benefits are realised.” Furthermore, he writes that tourism should be envisioned as a form of community development and as cities may have needs that the visitors can financially support.

Tourists would see the existential authentic experience offered by local communities as the ideal experience (Barbara, 2014, p.11) and that is the USP of creative and nature tourism, both models that depend so heavily on communities and therefore are closely related to community development discourse.

Indeed tourism and development are interconnected because tourism so often provides the impetus for development projects and the latter may lead to more tourism. Edwards et al (2008, p.1038), state that tourism is one ‘among many social and economic forces in the urban environment. It encompasses an industry that manages and markets a variety of products and experiences to people who have a wide range of motivations, preferences and cultural perspectives and are involved in a dialectic engagement with the host community. The outcome of this engagement is a set of consequences for the tourist, the host community and the industry’.

Collantonio and Potter (2006, p.63) write that tourism has been used by governments as a tool of economic policy capable of generating income and employment, of diversifying the economy, and of promoting regional development through multiplier effects and the building of local productive capacity. Rogerson & Visser (2007), point at significant investigations and research that evidence and demonstrate the role of tourism in the development of African cities, particularly in the context of poverty alleviation, economic development, sustainable development and employment opportunities. They contend that smaller towns and cities in Africa, such as Bonnievale, Clarens, Greyton and Robertson, which faced decline in the agricultural sector, have emerged as rising small town or city tourism centres (Rogerson & Visser, 2007).

Irrespective of the benefits that tourism may give to the local population, it is worthwhile to understand how far they do accept the intrusion into their perceived spaces by people who they may feel are objectifying them. This is particularly important in the postcolonial discourse surrounding tourism and community development. Chase et al (2013) write that the public may often perceive the negative impacts of tourism development to be greater than their economic gains, resulting in the negative feelings that the residents may garner for the tourists. While this may be true of any resident community, anywhere in the world, the feeling of negativity towards tourists may be intensified, where the tourists have a binary self and other viewpoint towards the local communities. The tourism industry too is to be blamed for this as it repackages culture often in a way that is not a true representation of that culture. This erodes the authenticity and value of local culture (Chase et al, 2013, p.12) and instead of the culture and cultural stories being told by the actual inheritors of that culture, the narrative is taken control of by outside influences.

Bologna and Spierenburg (2014), refer to the conservation areas in South Africa, that have become an important aspect of nature tourism as well. These projects are the result of the community based conservation concerns, which became so dominant in the 1980s linking community and environment together. However, what was the real benefit to the communities for whom these conservation projects were implemented?

On Orientalism

Moosavinia et al (2011) say that Orientalism is a Western perspective of the Orient. In particular, the Western knowledge of the Orient from nineteenth century has influenced the definition of the Orient using a “set of recurring images and clichés” and that “this knowledge of the Orient is put into practice by colonialism and imperialism.” To a great extent Edward Said’s work is responsible for the binary opposition critique of Western scholars on the Orient. Said (1978) based his critique on orientalist studies on the ground that the European representation of the Orient contributed to the creation of a binary opposition between Europe and its ‘other’, the Orient. The biggest concern for Said (1978) was that orientalism fosters power structures, where the knowledge of the Orient is in the hands of the Western scholars (Moosavinia et al, 2011). The problem with the approach of Orientalism as adopted by Western writers and critiqued by Said, is that it describes the various disciplines, institutions, process of investigation and styles of thought by which the Europeans came to 'know' the 'Orient'. This system as a ‘willed human work’, institutionalises the imaginary boundary between ‘two unequal halves’ and materialises it in the shape of colonialism and imperialism (Moosavinia et al, 2011, p.105).

Tourism depends on the preconceived ideas and definitions of a place and its people. From the Western traveller’s point of view these preconceived ideas are to a great extent constructed not from experience but imagination of what a place and its people will be like. Therefore, many Western tourists would find a certain charm in the thought of quaint postcolonial lands, and would definitely be disappointed to find that the reality does not justify the notions. Therefore, from that point of view, there is greater possibility of attracting more tourists if the place and people retain the charm of that preconceived notions have bestowed them with. This can be problematic for those who are the locals or natives of the place. Hollinshead (1992, p.44) points out: “in the postcolonial setting, indigenous people may find themselves trapped, in a sort of tourized confinement in the suffocating straitjacket of enslaving external conceptions. They are caught in the objectifying stant of the Whites, Westerners or Wanderers-From-Afar, in an anonymous but continuing process of subjugation.” An example of this can be found in Carr (1999), when he recounts the Maori experience in the New Zealand tourist culture of using Maori culture for attracting more tourism, with the effect that “there was a time when foreigners would have been excused for thinking, by posters and videos they saw, that New Zealand existed solely of flax-skirted Maori jumping in and out of steaming pools” (Carr, 1999, p.19).

As Said (1978) points out, the problem with the preconceived notions is that the representation given to a place and its peoples is often the one that is found in the Western literature and theory. This gives the Westerners an upper hand in defining a place and its culture. This representation is strong and powerful enough to create a binary opposition of the self and the other as seen from the Western point of view. Here the self is seen as privileged observer and articulator of the culture and peoples of the Orient and the actual people become mute objects of study (Moosavinia et al, 2011). Ooi (2005) writes a critical review of orientalism and in the context of tourism. She takes the example of the BBC series Holiday Programme, and criticises the representation of Singapore as made in the programme to reinforce her point that oriental perspectives as Said (1978) had said are sadly misconstruing of the East, where the West dominates the narrative of the Eastern people as well as culture. She writes of the BBC programme:

The programme did not mention that the current government was one of the parties who drove the British colonial masters out in the 1950s, few Singaporeans use Chinese medicine as the first choice of cure today and many of the so-called strict rules and regulations are also common in other countries, including the UK. Implicit in the messages are: Singapore is a successful colonial legacy (thanks to the British); Singapore is still an exotic Asian destination; and Singapore is not a democracy. Viewers will get to experience Britain’s colonial heritage in Singapore, see how those Asians heal themselves and experience life in an autocratic regime. Such types of images and messages enthuse viewers, sell destinations and also caricaturize host societies (Ooi, 2005, p.287).

Clearly, the Western viewpoint, which unfortunately is the first and sometimes the only point of reference for travellers is misrepresentative of Eastern or Oriental culture.

References

• Ashcroft, B., Griffiths, G., Tiffin, H. (1989). The Empire Writes Back : Theory and Practice in Postcolonial Literatures. London: Routledge.
• Barbara, N. (2014). The Business of Creative Tourism and Creativity in the Tourism Business. In Anthony David (Ed.), Barker Identity and Intercultural Exchange in Travel and Tourism. Bristol: Channel View Publications.
• Bologna, S.A. and Spierenburg, M. (2014). False Legitimacies: The Rhetoric of Economic Opportunities in The Expansion of Conservation Areas in Southern Africa. In René Van der Duim, Machiel Lamers, Jakomijn van Wijk (Eds.), Institutional Arrangements for Conservation, Development and Tourism in Eastern and Southern Africa: A Dynamic Perspective. Springer.
• Carr, A. (1999). Interpreting Maori Cultural and Environmental Values: A Means of Managing Tourists and Recreationists With Diverse Cultural Values. Te Waipunamu (unpublished paper).
• Chase, L., Boumans, R., Morse, S. (2013). Participatory Modeling as a Tool for Community Development Planning: Tourism in the Northern Forest. In Rhonda Phillips and Sherma Roberts (Eds.), Tourism, Planning, and Community Development. Routledge.
• Clifford, J. (1988). The Predicament of Culture : Twentieth Century Ethnography, Literature and Arts. Massachusetts: Harvard University Press.
• Colantonio, A., Potter, R.B. (2006). Urban Tourism and Development in the Socialist State: Havana During the 'special Period’. Hampshire: Ashgate Publishing Ltd.
• Edwards, D., Griffin, T., & Hayllar, B. (2008). Urban tourism research: developing an agenda. Annals of Tourism Research, 35(4), pp.1032–1052
• Finnstrom, S. (1997). Postcoloniality and the Postcolony : Theories of the Global and the Local. Working papers in cultural anthropology, No.7.
• Hall, M., Tucker, H. (2004). Tourism and Postcolonialism: An Introduction. In Colin Michael Hall, Hazel Tucker (Eds.), Tourism and Postcolonialism: Discourses, Identities and Representations. Psychology Press.
• Hollinshead, K. (1992). White Gaze Red People-Shadow Visions: The Disidentification of Indians in Cultural Tourism. 11 Leisure Studies.
• Moosavinia, S. R., Niazi, N., Ghaforian, A. (2011). Edward Said’s Orientalism and the Study of the Self and the Other in Orwell’s Burmese Days. 2 Studies In Literature And Language 1, pp. 103-113
• Ooi, C.S. (2005). The Orient responds: Tourism, Orientalism and the national museums of Singapore. 53 Tourism 4. Rogerson, CM, Visser, G. (2007). ‘Tourism Research and Urban Africa: The South African Experience’ in Christian Myles Rogerson, Gustav Visser, Urban Tourism in the Developing World: The South African Experience. New Jersey : Transaction Publishers.
• Zappino, V. (2005). Carribean Tourism and Development: An Overview. Discussion Paper at the European Centre for Development Policy Management. Retrieved from http://ecdpm.org/wp-content/uploads/2013/11/DP-65-Caribbean-Tourism-Industry-Development-2005.pdf