Athens Maritime Enterprises Corpn. v. Hellenic Mutual War Risks Association (Bermuda) Ltd. (The Andreos Lemos)

England: Piracy - Acts within territorial waters - Element of force

In a judgment delivered on 24 June 1982, Staughton J. held that, in the context of an insurance policy, there was no reason to limit piracy to acts outside territorial waters. If a ship was “at sea” in the ordinary meaning of the phrase, or if the attack upon her could be described as a “maritime offence”, then for insurance purposes she was in a place where piracy could be committed. Further, theft without force or a threat of force was not piracy under a policy of marine insurance.