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Lloyd's Maritime Law Newsletter

Great Lakes Towing Company v. The Rhone - Supreme Court of Canada (La Forest, L’Heureux Dube, Sopinka, Gonthier, Cory, McLachlin and Iacobucci JJ.) - 25 February 1993

Collision action - Limitation of liability - Actual fault or privity - Whether all vessels in flotilla should be taken into account in determining extent of liability

The moored vessel Rhone was struck by the barge Peter A.B. Widener (“ Widener ”) in the Port of Montreal. At the time of the collision, the Widener was being towed by four tugs. Two of the four tugs, the South Carolina and the Ohio , were owned by Great Lakes Towing Company (“Great Lakes”). The master of the Ohio acted as de facto master of the flotilla. His navigational errors, compounded by a malfunction of his tug’s towing apparatus, caused the collision.

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