The cases are legion, but see, e.g.,Transfield Shipping Inc v Mercator Shipping Inc (The Achilleas)[2008] UKHL 48, [2009] 1 AC 61 [12];ICS(n. 56) 911ff;The Moorcock(n. 66) 68;M&S v BNP Paribas(n. 56) [16];Reigate(n. 76) 605. For the US, see Restatement (2d) of C...
The discussion of these two models takes up a whole chapter of AILR, i.e. chapter 5. What is worth pointing out is that while the authors declare to be of the view that these two models may overlap, in fact their opinion seems more to be that the rule model takes precedence over it...