“Success is necessary for a salvage reward. Contributions to that success, or as it is sometimes expressed meritorious contributions to that success, give a title to salvage reward”. If there is not success there can be no reward.
Cases: Maritime Law
Clan Steam Trawling Co Ltd v Aberdeen Steam Trawling & Fishing Co Ltd (1908) SC 651
Here, a fishing boat, provided assistance to a vessel whilst it was sinking. They provided them with ropes, set out the fire and towed the ship. They went to court to request a salvage award. However, as they were both in the same P&I club it meant that this was not voluntary service as a…
The Neptune (1824) 1 Hagg 227
Here, the court provided us with the definition of Voluntary Service. “What is a salvor? A person who, without any particular relation to a ship in distress (not his, not contractually obliged), proffers useful service, and gives it as a volunteer adventurer, without any pre-existing covenant that connected him with a duty of employing himself for the preservation of that ship”. (The…
The Winson (1982) 1 Lloyd’s Rep 117
What can be considered a recognised subject of Salvage. Here it was explained that commercially carried cargo can only be considered a recognized subject of Salvage. For example, if the captain lost his watch, this wouldn’t be considered a recognised subject of salvage.
The Cythera [1965] 1 Lloyd’s Rep 454
What is Salvage: “A service which saves or helps to save a recognised subject of salvage when in danger, if the rendering of such service is voluntary in the sense of being solely attributable neither to pre-existing contractual or official duty owed by the owner of salved property nor to the interest of self-preservation.”