Secretary of State for Trade v. Ewart-James (The NF Tiger) - Divisional Ct. (Lord Lane, Lord Chief Justice of England, O’Connor and Kerr L.JJ.) - 29 June 1982

Criminal liability of master under Merchant Shipping Act 1894 - Whether section 419(2) creates absolute offence

The respondent was the master of the motor vessel NF Tiger . He was charged in the Ramsgate Magistrates Court with failing to cross traffic lanes in the English Channel “as nearly as practicable at right angles to the general direction of the traffic flow, contrary to section 418, 419 and 680 of the Merchant Shipping Act 1894 and Rule 10(c) of the Collision Regulations . . .”