Thirty years ago, Charles Baker and Paul David expressed surprise that “such a question as ‘safety’ [required] lengthy legal analysis”.1 However, the reality is that disputes about safe ports and berths are rarely straightforward. It is rare for the issue to be simply the validity of an order to proceed or, if the owner does proceed, for damage to be occasioned directly by the vessel sailing to an unsafe port, for example where she hits an invisible submerged object.2 More often, the port is unsafe only in particular weather or other conditions, when one of the issues is whether the set-up is adequate to deal with these situations. Usually also, there are other contributory factors, such as the master’s decision to proceed to the port, to remain or to leave it in hazardous conditions. Safe port clauses, moreover, do not exist in isolation, and the charterparty must be construed as a whole. It can, in principle, be argued that another clause, or clauses, provide a complete code for the unsafety that has occurred. Such were the complexities (by no means unusual) in The Ocean Victory, a recent decision of Teare J.3