The strictissimi juris doctrine applicable to guarantees does not require courts to read down words of generality deliberately chosen by the parties; where a guarantee contains a broadly worded variation clause (such as 'any alteration to, addition to or deletion from the Contract'), it will be given its wide ordinary meaning. There is no general principle that a breach of the principal contract by the creditor discharges the guarantor where the principal debtor has not terminated the contract, particularly where the guarantee contains a broad variation clause. A contractual provision permitting withholding of payment for 'unsatisfactory performance' does not operate as a bar to recovery of all undisputed invoices but is limited to invoiced items bona fide disputed as unsatisfactory.
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