During his long and distinguished career as a Jude of the Singapore Supreme Court, the Honourable Mr. Justice Victor Winslow handed down numerous important decisions in the field of commercial law. One of them - Overseas Union Bank Ltd. V Chua - is a leading case on the tender of certificates of inspection under documentary credits. The learned Judge's deep interest in the subject of letters of credit and of negotiable instruments renders this article - based on a paper delivered to the Wellington District Law Society in July 1977 - a suitable contribution to a publication dedicated to him on the occasion of his retirement.