LECTURE 2
Jurisdiction Method: Summarised
1.0 INTRODUCTION
2.0 ADMIRALTY JURISDICTION AND CLAIMS
2 (1) CLAIMS IN PERSONAM – Section 21(1) of the Supreme Court Act 1981
2.2 The In Rem Claim (Or The Old Action In Rem)
2.2 (i) Functions of In Rem Proceedings
• Secure the Claim
• invoke the jurisdiction of the English court for the merits of the claim
• crystallise the claimant’s right in rem concerning ‘non-truly in rem’ claims
from the moment the in rem claim form is issued.
2.2 (j) Who is identified as the defendant in the in rem proceedings?
2.2 (k) Consequences of The Indian Grace
3.0 THE PERTINENT CONDITIONS FOR ASSERTING IN REM CLAIMS
3.1 Exemption of Conditions in Truly In Rem Claims
3.2 Non-Truly In Rem -Section 20(2)(e)-(r) read along with Section 21(4)
3.3 Non-Truly In Rem -Subject to Section 21(4)
3.3.1 Beneficial Ownership and Arrest of the Relevant Ship or a Sister Ship
4.0 ASSETS ELIGIBLE FOR AN IN REM CLAIM
LECTURE 2
JURISDICTION METHODS
- INTRODUCTION
The Admiralty Court’s jurisdiction empowers it to address both claims in rem and claims in personam. This chapter illustrates how the conflict between common law courts and the Admiralty Court was resolved by granting the Lord Admiral the authority to adjudicate disputes related to maritime matters, such as collisions, salvage, ship mortgages, ship possession, and ship title. In these cases, the Lord Admiral was only allowed to pursue actions in rem against the ship itself. This marked the inception of truly in rem cases, focusing on proprietary rights and maritime liens, where the ship was the defendant, expanding the court’s jurisdiction.
The Admiralty Court Acts of 1840 and 1861 broadened admiralty jurisdiction to encompass other maritime claims, not all related to ship ownership or maritime liens (the non-truly in rem). The amalgamation of these additional claims with truly in rem claims, along with the merger of all courts under the Judicature Acts of 1873-75, led to the fusion of truly in rem claims with the non-truly in rem. As a result, actions in rem and actions in personam could be heard in the same courts. The distinction between truly and non-truly in rem claims, as well as in rem and in personam proceedings, has persisted in the exercise of jurisdiction and can be found in current statutes.
In summary, truly in rem claims can be brought against the relevant ship without considering personal liability or the ship’s beneficial ownership. Maritime liens, ship mortgages, and claims of ownership or possession of a ship fall under this category. Conversely, non-truly in rem claims take into account ownership and personal liability when brought against the relevant ship. Before delving into the specifics of these considerations, it is essential to understand the nature and functions of in personam and in rem claims. This understanding is followed by an examination of the impact of The Indian Grace on the nature of in rem claims and an analysis of how non-truly in rem claims can be initiated against a ship.
2.0 ADMIRALTY JURISDICTION AND CLAIMS
2.1 CLAIMS IN PERSONAM – SECTION 21(1) OF THE SUPREME COURT ACT 1981
As implied by the Latin phrase, these are claims directed against individuals or the companies that act as the beneficial owners or demise charterers of a ship. Accor ding to Section 22(1) of the SCA 1981, claims in personam can be initiated in the High Court for all matters falling under the admiralty jurisdiction of that court. These proceedings can be initiated using a claim form in personam or an in rem claim. Given that shipping companies are often incorporated abroad, serving an in perso nam claim form in person may not be feasible, unless the claim falls into specific categories where court permission can be obtained, in accordance with the Rules of Court. An in personam claim form can also be served outside the jurisdiction if the defendant agrees to submit to that jurisdiction or if the claim pertains to salvage services rendered within the jurisdiction.
However, initiating in personam proceedings in collision cases is subject to limitations unless the defendant voluntarily submits to the jurisdiction. Section 22(2) specifies that the High Court cannot hear such actions unless: (a) the defendant’s habitual residence or place of business is within England or Wales; or
(b) the cause of action arose within the inland waters of England or Wales or within the limits of a port of England or Wales; or
(c) a related action arising from the same incident or series of incidents is already underway in the court or has been heard and decided in the court.
There are two significant drawbacks to in personam proceedings: Firstly, it can be challenging to obtain permission to serve the defendant outside the jurisdiction. Secondly, unlike in rem claims, in personam claims do not provide security for the claim, which means that a judgement, if obtained, may remain unenforceable unless a quasi-security is acquired for satisfying the judgement through a freezing injunction. It’s important to note that a freezing injunction is not a form of guaranteed security, as when a ship is arrested. This is because the asset subject to the injunction may not be sufficient to cover the claim, and the defendant can seek a variation of the injunction to use the asset for business expenses.
2.2 THE IN REM CLAIM (OR THE OLD ACTION IN REM)
It is important to look at the origins of Non-Truly In Rem Claims. Statutory rights through an action in rem were initially established by the ACA 1840.
To quote Brandon J in The Monica S: “Such rights were granted under Section 6 for claims related to towage and for claims regarding necessaries supplied to foreign ships, whether within a country’s borders or on the high seas. Further rights of the same nature were introduced by the ACA 1861. Section 4 granted such rights for claims concerning the construction, equipping, or repair of a ship if, at the time of initiating the cause, the ship or its proceeds were under arrest of the court. Section 5 provided rights for claims related to necessaries supplied to any ship outside the port to which it belonged, unless at the time of the cause’s initiation, any owner or part-owner was domiciled in England or Wales. Section 6 extended these rights to claims by holders of bills of lading for goods brought into any port in England or Wales, in cases of damage to such goods, subject to the same proviso regarding the domicile of any owner or part-owner. Additionally, Section 10 covered master’s claims for disbursements. Section 35 further allowed the Admiralty Court to exercise jurisdiction either in rem or in personam.”
Subsequently, the Judicature (Consolidation) Act 1925 expanded the range of claims enforceable through an action in rem, and further extensions were made through the Administration of Justice Act (AJA) 1956, and the current statute, the Supreme Court Act (SCA) 1981, as mentioned earlier.
2.2 (i) FUNCTIONS OF IN REM PROCEEDINGS
(a) secure the claim, At the outset, an in rem claim is directed at the property in question, such as the relevant ship, cargo, or freight, and it requires the property to be within the court’s jurisdiction to be subject to arrest unless the defendant submits to jurisdiction and provides security instead of arrest. The uniqueness of an in rem claim under English procedural law lies in its threefold function: it helps the claimant to:
(b) invoke the jurisdiction of the English court for the merits of the claim, and (c) crystallise the claimant’s right in rem concerning ‘non-truly in rem’ claims from the moment the in rem claim form is issued.
- Secure the Claim The property owner has the option to arrange for security in the amount of the claim, along with interest and associated costs, as an alternative to releasing the ship from arrest. Standard letters of undertaking for this purpose can be obtained from the owner’s P&I club or their bank. These letters of undertaking include a commitment to have solicitors accept service on behalf of the owner and a willingness to submit to the jurisdiction. Currently, there is no requirement for the arresting party to provide an undertaking in damages to the shipowner in case of an unjustified or wrongful arrest. It is essential that the assessed amount of security for the ship’s release is reasonable and reasonably approximated.
The case of “The Moschanthy” involved a shipment of second-hand machinery from London to Tripoli, which was to be delivered to the plaintiff’s order. The machinery was placed with the defendant’s agents in Tripoli, who claimed a lien for unpaid freight. An application for an order of delivery of the goods against a bank guarantee in the Lebanese court was rejected. Subsequently, the plaintiff initiated an in rem action in the English Court against the vessel “M,” a sister ship of “A,” seeking damages or the value of the goods, along with damages. “M” was arrested in Liverpool, and a significant amount of security was requested for its release because the plaintiff anticipated making a 100% profit from the sale of the goods. Meanwhile, the defendants had commenced an action in Lebanon, claiming unpaid freight, and they applied to stay the proceedings in the English Court, arguing, among other things, that the requested security was excessive and should be reduced.
The court held that considering the value of the goods and the potential interest and security was not considered excessive. costs that the plaintiff would be liable for if successful, any assessment of a reasonable security figure could only be an approximation. The requested amount of security was not considered excessive.
In contrast, the case of “The Tribels” involved the plaintiffs’ vessel running aground while entering the harbor due to a strong northeasterly wind.
The vessel’s master engaged the defendants’ harbor tugs under the standard Lloyd’s Salvage Agreement. Pursuant to the contract, the salvors demanded security in the amount of £3,323,000. The plaintiffs sought an injunction to limit the salvors’ demand for security to a maximum of £1 million, as they believed this amount was sufficient. The estimated value of the property saved was approximately £16,150,000. The salvage agreement implied that the contractor should not unreasonably request high security.
The court ruled that a security amount of £1 million provided a substantial margin of protection for whatever sum the arbitrator might ultimately award after the salvage operation. Even when viewing the case in the most favorable light for the salvors, this sum was deemed more than adequate to cover their interests.
- invoke the jurisdiction of the English court for the merits of the claim Except in situations where the defendant is within the jurisdiction and can be served with the claim form or has agreed to the court’s jurisdiction, and in cases governed by the Brussels/Lugano Conventions, a claimant will require the court’s permission to serve legal proceedings outside of the jurisdiction. This rule can only be applied in specific instances where there is a connection between the claim and the jurisdiction.
For example, a contractual link may exist if the contract was made within this jurisdiction or is subject to English law. Another connection with this jurisdiction arises in cases of tort claims when the alleged tort occurred within this jurisdiction. The granting of permission is at the discretion of the court.
According to Order 11, Rule 4, the claimant must state the grounds for the application and demonstrate that they have a valid cause of action and a real issue to be tried, as per their belief. No permission will be granted unless it is sufficiently evident to the court that the case is suitable for service outside the jurisdiction.
In situations not covered by this order, the court cannot assume jurisdiction over a foreign defendant unless there is a convention jurisdiction basis or the parties involved have agreed to this jurisdiction. Even if English jurisdiction has been properly invoked, the English court retains the authority to exercise its discretion and halt legal proceedings before it when there are forum non-conveniens grounds.
For instance, in cases where there are significant connections with the jurisdiction of a foreign court that the defendant is subject to, the English court will assess, taking all circumstances into account, whether the foreign court is better suited to resolve the matter in the interest of justice and all parties involved.
- crystallise the claimant’s right in rem concerning ‘non-truly in rem’ claims from the moment the in rem claim form is issued. The establishment of the “non-truly in rem claim on the ship (against which in rem proceedings were initiated) occurred in 1967 through the ruling of Brandon J in The Monica S.
In The Monica S case, the cargo owners of the ship’s cargo filed a claim for damages to their cargo and initiated in rem proceedings. At the time of filing, the ship was named Monica Smith and was owned by S. Before the writ was served, the ship was transferred to T and renamed Monica S. Accordingly, the writ was amended to describe the ship’s name and defendants as “the owners of the ship formerly called Monica Smith and now known as Monica S.” The writ was then served on the ship. Subsequently, the new owner, T, entered a conditional appearance and filed a motion to set aside the writ or the service. After the service, T sold the ship to another party. T argued, among other things, that no lien or charge arose against Monica S due to the issuance of the writ or service, citing (1) T not being the owner of the vessel at the date of issuance or when the cause of action arose; (2) T not being liable in personam; and (3) the claim not giving rise to a maritime lien or charge on the ship. T contended that the plaintiff had only a statutory right of action in rem under the AJA 1956, which could be enforced against the ship if (i) the ship was arrested while still owned by the person liable in personam, or (ii) the writ had been served before a change of ownership.
Brandon J had to determine whether a change of ownership of the ship, occurring after the initiation of proceedings but before service or arrest, would defeat the statutory right of action in rem. After reviewing previous relevant authorities, Brandon J concluded that T was the owner of the vessel at the time of the writ’s service and had an interest in defending it. He emphasised that, as a matter of principle, the creation of a substantive right could occur at the date of action’s initiation, and there was a preponderance of authority to support the view that the defendant’s contention was incorrect. Brandon J maintained that, once the plaintiff had properly invoked jurisdiction under the 1956 Act by commencing an action in rem, they should be able to pursue it through all its stages, up to obtaining a judgement against the ship and receiving payment from the proceeds. Therefore, T’s motion was dismissed.
Brandon J referenced several decisions in his judgement, some of which appeared to support his perspective, while others were in conflict. He acknowledged that none of these decisions exactly matched the case at hand. He found that The Pacific, The Princess Charlotte, The Troubadour, The Two Ellens, The Heinrich Bjorn, and The Cella supported his view, while The Sara, The James W Elwell, and The Colorado were not clear or not directly relevant. Brandon J argued that the passage by Lord Watson in The Heinrich Bjorn strongly supported his interpretation.
In summary, Brandon J contended that the institution of a suit in rem caused a statutory right in rem to accrue on the ship, and this right was unaffected by a change of ownership between the initiation of the proceedings and the ship’s arrest. He based this argument on the wording of the AJA 1956, which emphasized the critical moment as when the “action is brought” against the relevant ship. Despite persuasive arguments to the contrary, Brandon J believed it was necessary to protect maritime claimants, as purchasers could rely on contractual indemnities obtained from sellers in cases where the ship was encumbered by maritime liens or statutory rights in rem. This ruling has had a profound impact on ship purchasers who acquired a vessel after the writ was issued. It has remained unchallenged. We will later examine whether the recent decision of the House of Lords in The Indian Grace has undermined the effects of this ruling.
2.2 (ii) WHO IS IDENTIFIED AS THE DEFENDANT IN THE IN REM PROCEEDINGS?
Historically, there have been two prevailing perspectives. One perspective sees the in rem action (claim) as a way to compel the defendant responsible for the claim to personally appear in court and defend against the claim (referred to as the ‘procedu ral theory’). In essence, an in rem claim targets the person interested in the ship, who, upon appearance, becomes personally liable beyond the ship’s value if the claim exceeds its worth.
Another perspective considers it as an action against the res and has evolved from the concept of maritime liens, attaching to the ship from the incident giving rise to the claim (known as the ‘personification theory’). In this view, the res is regarded as the ‘personified’ defendant.
The procedural theory gained prominence among English judges, especially after the 1892 decision in The Dictator. This case involved the enforcement of a maritime lien claim for salvage, confirming personal liability for the ship owners beyond the bail amount.
Despite criticism, the procedural theory prevailed, with only a few decisions appearing to contradict The Dictator. Before delving into how The Indian Grace affected The Dictator, it’s crucial to outline the characteristics of in rem proceedings as they stood before this later decision.
Before The Indian Grace (No 2), in rem proceedings primarily served as a means to secure a claim, establish jurisdiction based on the merit of the claim by arresting the ship, and enforce maritime liens. Whether truly in rem or not, the in rem proceeding created a statutory right in rem, or lien, on the ship, making it enforceable against the ship regardless of ownership transfer. The value of the ship was the limit for satisfying maritime claims unless the defendant acknowledged service, turning the action into in personam.
In the absence of acknowledgment or submission to jurisdiction, the in rem proceeding remained solely in rem, compelling the defendant to ‘appear’ and either defend the claim or contest jurisdiction. A court sale extinguished all encumbrances on the ship, providing a clean title to the purchaser. Now, considering The Indian Grace, the House of Lords brought about changes affecting certain features of the in rem claim. It was determined that the action in rem is against the owners from the moment of service of the writ. This decision has potential implications, altering the nature of in rem claims as previously understood. The factual background of The Indian Grace involved a cargo dispute, and the decision clarified the relationship between actions in rem and in personam. The House of Lords held that an action in rem is considered against the owners from the moment the Admiralty Court gains jurisdiction.
This decision was based on the historical background of the struggle for power between common law courts and the High Court of Admiralty. Lord Steyn, delivering the judgment, traced the historical background of the action in rem, highlighting the decline of the personification theory after the Judicature Acts in 1873–75. He emphasized changes in procedure and the shift toward viewing the action in rem as an action against the owners. Lord Steyn also referred to sovereign immunity cases and recent decisions supporting the idea that once a defendant enters an appearance in an admiralty action in rem, the action continues against them as both in rem and in personam.
In summary, Lord Steyn argued that, given the similarity in wording between Art 21 and s 34 of Brussels Convention of 1968, interpreting ‘between the same parties’ differently would be curious. He suggested that The Indian Grace, No 2, had superseded previous decisions like The Nordglimt and should be considered the prevailing law. 2.2 (iii)
CONSEQUENCES OF THE INDIAN GRACE
Traditionally, it has been a well-established aspect of procedural law that acknowled ging the service of in rem proceedings, previously known as the defendant’s ‘appea rance,’ involves the defendant personally in the proceedings. This means that if the defendant is found liable, any outstanding balance of the claim beyond the ship’s value can be enforced against them through a writ of execution, specifically fieri facias.
Seizing another ship in the defendant’s fleet by the sheriff is only possible as a means of executing judgment, distinct from arresting the ship through a warrant of arrest. The implications of The Indian Grace could be significant, extending the effects of in rem proceedings even in cases where there is no acknowledgment of service or submission to jurisdiction by the defendant.
The long-standing principle of The Monica S has been that the issuance of in rem proceedings establishes a statutory right in rem on the ship, making it arrestable, even if subsequently sold to a bona fide purchaser without notice. The Indian Grace could potentially impact this principle, leading to two potential consequences: (a) The Indian Grace suggests that if an in rem action is against the owner of the ship from the point of service, a claimant who initiated in rem proceedings without obtaining security might not be allowed to pursue those proceedings by arresting the ship after a foreign judgment on the same issues.
However, this argument may not be valid for obtaining security, especially if the arrest is solely for that purpose and does not undermine The Monica S principle. (b) Another issue requiring clarification is related to the scenario where a ship burdened with claims is sold to a bona fide purchaser, and the ship is arrested after the transfer. The question arises about the potential personal liability of the new owner in the event of an in rem judgment obtained in default. The argument is presented that The Indian Grace primarily binds the previous owner, not the bona fide buyer. The potential risk of arrest of a ship purchased by an innocent buyer existed before The Indian Grace. The decision may impact personal liability, especially concerning other assets of the defendant liable in personam, potentially exposing them to the execution of judgment. The decision also raises questions about risk management, emphasizing the importance of obtaining insurance or security to safeguard against potential liabilities, especially under the new Civil Procedure Rules (CPR). The dynamics of personal liability and risk mitigation become crucial considerations for both claimants and defendants in maritime cases. In conclusion, the decisions within the framework of Article 21 of the Brussels/Luga no Conventions have underscored the significance of in rem proceedings. These decisions have clarified that the court is considered ‘seised’ of the matter at the time of service.
The courts’ concern in these instances is to prevent conflicting judgments from different Contracting States’ courts. The alignment of The Indian Grace’s conclusion that the court acquires jurisdiction upon the service of the writ for Sec tion 34 of the CJJA 1982 aligns with these decisions, suggesting a potentially limited application. This inference arises from Lord Steyn’s statement in the judgment, asserting that an action in rem against the owners begins when the Admiralty Court assumes jurisdiction. However, it is contended that this judgment, focusing on the issues in this case, doesn’t establish a broad principle conferring personal jurisdiction over the defendant in all in rem proceedings from the time of service. In summary, it is proposed that the following measures may address the challenges stemming from this decision:
(a) Regarding a bona fide purchaser of a ship unaware of the in rem claim form or maritime lien, service of the claim form does not confer personal jurisdiction because they are not liable for the claim. Enforcement of security through ship arrest would remain solely in rem unless alternative security is secured.
(b) Conversely, the service of the in rem claim form establishes personal jurisdiction against those interested in defending the claim, such as the owner or demise charterer of the relevant ship. The issue of obtaining security is distinct, and confusion arises under English law due to the dual function of ship arrest, serving both as a means to obtain security and to establish jurisdiction
(c) The timing of in rem proceedings’ service is pertinent only to the res judicata issue. Therefore, the defense of Section 34 should not impede in rem proceedings brought solely for obtaining or realizing security, unless sufficient security has been obtained.
The claimants in The Indian Grace initiated in rem proceedings in the Admiralty Court, seeking to relitigate the same issues and claiming higher damages than in the Indian jurisdiction. In rem rights are categorized into two groups: in
- THE PERTINENT CONDITIONS FOR ASSERTING IN REM CLAIMS (a)
Those inherently possessing proprietary characteristics, constituting ‘truly rem’ claims like maritime liens. This category also includes rights related to ship owners, mortgagees, ship forfeiture, and admiralty rights (s 20(2)(a), (b), (c), (s).
(b) All other statutory in rem rights under s 20(2)(e)–(r), referred to as ‘non-truly in rem’ claims.
- EXEMPTION OF CONDITIONS IN TRULY IN REM CLAIMS Section 21(4) of the Act distinguishes between these categories regarding jurisdiction exercise and imposes distinct conditions for each when pursuing an in rem action. According to sections 21(2) and (3), an in rem action can be initiated against the ship without consideration of the ship’s owner at the claim form’s issuance or the person liable in personam when the cause of action arose.
Therefore, these claims are deemed truly in rem. In the second category, a connection between the claim and the liability of the relevant person in personam is required. Factors of ownership are considered when the in rem proceeding is initiated, as discussed further below.
3.2 NON-TRULY IN REM
In Personam Link When the Cause of Action Arose: An in rem claim form for claims within Section 20(2) paragraphs (e)–(r), under Section 21(4) may be filed if:
(a) The claim is associated with a ship.
(b) The person who would be liable in personam (the relevant person) at the time of the cause of action was the owner, charterer, or person in possession or control of the ship. For claims under s 20(2)(e)–(r), the claimant must first identify the person liable in personam, who must have been the owner, demise charterer, or person in possession or control of the ship at the time of the cause of action. The term ‘owner’ refers to the registered owner.
Contrary to Lord Donaldson’s interpretation in The Evpo Agnic, ‘charterer’ encompasses both demise and time charterers. The case of The Span Terza clarified that ‘charterer’ includes time charterers, voyage charterers, and even slot charterers. The crucial factor is the relationship between the person liable and the ship at the time of the cause of action.
3.3 NON-TRULY IN REM
Ownership Criteria When Action Is Brought: Subject to the above, s 21(4) further specifies that the action may be brought against: (i) The ship, if, at the time of the action, the relevant person is the beneficial owner or charterer by demise. (ii) Any other ship, if, at the time of the action, the relevant person is the beneficial owner of all shares in it. The addition of ‘or the charterer of it under a charter by demise’ in s 21(4) of the 1981 Act emphasizes the ownership criteria. Beneficial ownership, not explicitly defined in the Arrest Convention 1952, includes the person in possession or control of the ship.
- 3.3.1 Beneficial Ownership and Arrest of the Relevant Ship or a Sister Ship As per s 21(4) of the SCA 1981, the arresting claimant must identify the relevant person liable in personam.
This person can be the owner, charterer, or person in possession or control of the ship related to the claim. Additionally, at the time of issuing the in rem claim form, the relevant person must be the beneficial owner of all shares in the ship or the demise charterer. The term ‘beneficially owned’ encompasses equitable ownership, regardless of legal ownership. While ‘owner’ refers to the registered owner, ‘charterer’ includes time and voyage charterers.
The concept of ‘beneficial ownership’ may extend to a demise charterer, as clarified in The Andrea Ursula and Congresso del Partido. In cases like The Father Thames, it was established that beneficial ownership, in the context of s 3(4) of the AJA 1956, does not apply to a demise charterer. The recent decision in Rangiora, Ranginui and Takitimu further emphasized the timing of termination in demise charter cases. The jurisdiction under s 21(4) allows the arrest of a sister ship if beneficially owned by the relevant person at the time of issuing the claim form. However, maritime liens may be forfeited in such cases. Finally, the conditions for bringing in rem claims vary based on whether they are truly in rem or non-truly in rem, with a focus on ownership criteria and the relationship between the person liable and the ship at the time of the cause of action.
4.0 ASSETS ELIGIBLE FOR AN IN REM CLAIM
The primary assets eligible for an in rem claim are the ship related to the maritime claim and/or its sister ship, provided that the conditions outlined in section 21(4) of the SCA 1981 are met.
A sister ship, in this context, refers to a vessel owned by the same company that owns the ship connected to the claim. It’s important to note that for claims falling under section 21(2) and (3), there is no provision for arresting a sister ship.
However, since claims with maritime liens are covered in section 21, paragraph (4), the arrest of a sister ship is permitted under this provision. It’s essential to be aware that arresting a sister ship for a claim with a maritime lien results in the loss of the lien privilege because the sister ship is not the property to which the lien is attached. If the ship is under a time charter, the bunkers aboard the ship are the property of the charterer.
Consequently, if a mortgagee arrests the ship, the charterer has the right to intervene in the action, and the sale proceeds of the bunkers, if the ship is sold by court order, will be directed to the charterer. In the case of cargo on board the ship or earned freight, arrest is only possible if a maritime lien is attached, such as when salvage services have been provided to rescue the ship and cargo. This principle also applies to bunkers on board that do not belong to the shipowner.
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