Hindustan Zinc Ltd. v. Tennant, Sons & Co.

667 F. Supp. 1000, 1987 U.S. Dist. LEXIS 7587
CourtDistrict Court, S.D. New York
DecidedAugust 22, 1987
DocketNo. 80 Civ. 3323 (MEL)
StatusPublished

This text of 667 F. Supp. 1000 (Hindustan Zinc Ltd. v. Tennant, Sons & Co.) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hindustan Zinc Ltd. v. Tennant, Sons & Co., 667 F. Supp. 1000, 1987 U.S. Dist. LEXIS 7587 (S.D.N.Y. 1987).

Opinion

LASKER, District Judge.

This case concerns a contract for the long-term supply of zinc concentrates between an Indian zinc smelter and an international trader of metals, ores and concentrates based in New York. Plaintiff Hindustan Zinc Limited (“HZL”), the buyer under the contract, seeks damages from defendant C. Tennant, Sons & Co. of New York (“Tennant”), the seller, for its failure to deliver eight shipments during the period 1977-81. Tennant counterclaims for damages relating to the same shipments on the ground that HZL wrongfully rejected Tennant’s offers of conforming material.

After hearing the testimony of eight witnesses at trial — including experts for both sides, reading the deposition testimony of several other witnesses, and examining hundreds of pages of documentary exhibits, I find this to be the rare case in which the parties to an ambiguous contract had such fundamentally different meanings in mind when they ostensibly agreed on terms that the contract is void under the doctrine of unilateral mistake. Alternatively, I find that even if the contract were not void, neither party has adduced sufficient proof of damages to support a money judgment in its favor.

I.

HZL is a corporation owned and controlled by the government of India which operates domestic lead-zinc mines and refineries, including an electrolytic zinc refinery in Viaskhapatnem on the southeast coast of India which is known as the Vizag smelter.1 The Vizag smelter was designed to produce refined zinc metal from material known as zinc concentrate, itself an intermediate product which is created when zinc-bearing ore is crushed, ground and processed in a variety of ways to separate zinc-bearing particles from useless residual substances such as rock and sand. Concentrate from which zinc is commercially recovered usually contains over 40 per cent zinc and smaller amounts of other “payable” elements (silver, gold, lead, cadmium), so called because the price for a particular concentrate is determined in part by the amount of such saleable materials the concentrate is expected to yield. Zinc concentrates also contain varying amounts of impurities which must be removed or otherwise controlled in the refining process. The amount of each component in a concentrate can be determined by chemically testing a sample, and concentrates can be [1002]*1002blended — i.e., physically mixed — for the purpose of altering the proportion of particular ingredients.

The number and amount of both payable elements and impurities found in concentrates vary substantially depending on the mine source, and may also vary between ores taken from different parts of the same mine. Contracts for the supply of zinc concentrate generally specify either the mine source of the concentrate or the assay — expressed as a percentage for each of as many as 25 named ingredients — of the concentrate expected to be delivered under the contract. The purchase price is generally expressed as a percentage of the currently reported price of zinc and each other element designated as payable under the contract, less a negotiated deduction known as a “treatment charge,” with some provision for the allocation of freight costs between buyer and seller.

The most common method for the commercial recovery of refined zinc is the electrolytic process. This process involves several stages in which impurities are removed, reduced, or separated by the use of heat or chemical additives before the final product emerges as zinc ingot. It is in the nature of the process that the non-zinc residue recirculates in the smelting system. If the impurities contained in the concentrate are not removed or sufficiently controlled in the roasting or purification stages, the extraction of zinc may be impaired or the final product rendered substandard. The cyclical nature of the process complicates these problems by permitting the buildup of both impurities and chemical additives. Although most electrolytic smelters use the same basic process, they vary significantly in the design of the purification stage. • Plants constructed to utilize specific concentrates of known composition from captive sources such as a mine owned by the smelter are designed with less complex, less flexible purification capabilities than “custom” smelters built to process concentrates from diverse sources.

The Vizag smelter was designed as a custom smelter by a Polish engineering firm under a contract with the Indian government. The parties agree that the engineering firm’s assay specifications for concentrate suitable for the Vizag smelter were so restrictive that no known mine production would conform.2 Moreover, HZL Chairman A.C. Wadhawan testified that the smelter’s purification system utilized an outmoded technology,3 and HZL admits that the smelter was not designed to cope with levels of concentrate impurities which could have been removed readily by other modern, more expensive custom smelters.4

Although construction of the Vizag smelter was not substantially completed until 1977, HZL in 1971 solicited offers from a number of producers and traders, including Tennant, for the long-term supply of concentrate for the new smelter. The solicitation letter described the facility as a new electrolytic smelter which was intended to process concentrate entirely imported from outside India.5 Enclosed with the solicitation letter was an assay, almost identical to the engineering firm’s specifications, which the letter described as an “approximate analysis of the concentrates on which the Smelter is designed.”6

Following the solicitation of supply proposals, representatives of Tennant and HZL corresponded and met periodically regarding the terms pursuant to which Tennant might provide concentrate to the Vizag smelter as well as HZL’s other refinery, the Debari smelter in northwest India. In the early exchanges of proposals, HZL described the material it would require by listing “permissible limits” of each of over 20 elements, expressed either as decimal percentages followed by the words “maxi[1003]*1003mum,” “minimum” or “average” or as “Trace.”7 Tennant’s early proposals introduced the specifications with the words “zinc concentrates ... assaying approximately as follows” and did not describe the percentages as máximums, minimums or averages.8 One early communication from Tennant to HZL foreshadowed later problems:

We have a great number of small productions of zinc concentrates available to us in Mexico, Peru and Canada and naturally the assays tend to vary to a large extent between productions. For this reason it is almost impossible to advise comprehensive assays for all productions, and indeed it is not usually the smelter’s practice to insist on assays for very minor or trace elements. I do not think that we have any productions available to us which would meet the permissible limits which you have set for zinc concentrates, in every respect. Accordingly if you have no flexibility in these limits, there may be no way for us to do business together.9

In November 1971, Tennant sent HZL a pro-forma contract containing specifications equivalent to earlier assays discussed by the parties but preceded by the words “zinc ores assaying typically.”10

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Cite This Page — Counsel Stack

Bluebook (online)
667 F. Supp. 1000, 1987 U.S. Dist. LEXIS 7587, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hindustan-zinc-ltd-v-tennant-sons-co-nysd-1987.