Armada Lines v. Chaleur Fertilizers

The law regarding damages for wrongful arrest of a vessel has been settled for nearly 140 years: the court will only award damages where the arrest has been made with mala fides or crassa negligentia. This longstanding rule, one of the most venerable in English maritime law and one which has contributed significantly to the use of the world’s common law courts by claimants in maritime disputes,1 is most authoritatively stated by the Privy Council in The Evangelismos,2 a decision which, with one exception, has with little elaboration been uniformly applied by courts in England and throughout the Commonwealth. The Evangelismos rule for recovery of damages for wrongful arrest is