Admiralty Court ruling on the application of the “narrow channel rule” and the “crossing rule”

Irvine Marr, David Owens and Martyn Haines, of Clyde & Co, review a recent Admiralty Court ruling

In a recent decision concerning collision liability, the UK’s Admiralty Court has agreed with Alexandra 1 interests on the application of rule 9 of the Collision Regulations (Colregs) – the narrow channel rule. In The Alexandra 1 and Ever Smart [2017] 1 Lloyd’s Rep 666, the court considered which of two rules, the narrow channel rule (rule 9) or the crossing rule (rule 15), applied in circumstances where one vessel was exiting a narrow channel and the other vessel was navigating towards that channel in preparation for entering it. Both rules presenting different requirements, their simultaneous application would be unsafe, and the Admiralty Judge has confirmed that, on the facts of this case, the narrow channel rule applied, and the crossing rule did not apply. In the circumstances, Ever Smart was ordered to bear 80 per cent of the liability for the collision. Alexandra 1 interests were represented by Clyde & Co.