The UK and Greece, both surrounded by sea and both being island countries, are placed in the two corners, North-West and South-East, of Europe. The geographical distance of the two countries is also reflected on the divide between two distinct legal traditions. The UK clearly represents the Anglo-Saxon Common Law system. Greece, on the other hand, follows the Continental European (especially that of Germany, France and Italy) Civil Law system. The comparison of the two jurisdictions in two inter-related areas of Marine Insurance Law reveals commonalities and different approaches of the phenomenon of collisions between vessels, and the usually following phenomenon of abandonment of ship. The UK Marine Insurance Act has been in force since 1906. On the other hand, the Greek ship-owners are listed in the first place of the international catalogue of private owned vessels. The thorough examination of laws and cases in the two jurisdictions contributes to the drawing of useful conclusions for both the academic reader and the lawyer practicing maritime law in the UK and / or in Continental Europe, or worldwide.
Frankfurt am Main, Berlin, Bern, Bruxelles, New York, Oxford, Wien, 2007. 130 pp.
Contents: Collisions between vessels in the UK – Legal notion of collision between vessels in Greece – Collision liability
of the insurer in the UK – Collision liability rules and regulations regarding the underwriter in Greece – The main principles
and the exceptions of collision liability – Right of the assured to abandon the ship in the two jurisdictions – The notice
of abandonment in the UK and in Greece – A proposed EU Regulation statutory model for the abandonment procedure.