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Narrow channel (Rule 9) vs. Crossing rule (Rule 15)

Do the CROSSING RULES (rule 15) apply where an outbound vessel is navigating within a NARROW CHANNEL and the other vessel is approaching the channel with the intention of entering it? This question on INTERPLAY between r.9 and r.15 was up before the UK Supreme Court in The Alexandra 1 [2021].

Collision between outbound vsl and Alexandra 1 (inbound - waiting for pilot) took place within the pilot boarding area, just OUTSIDE the dredged [narrow] channel. Alexandra 1, though not on a steady course was approaching other ship on a steady bearing. Various shortcomings led to the collision such as defective lookout (aural & visual), unsafe speed etc. but that was a separate matter. So was Alexandra 1 the GIVE WAY VESSEL? Her owners said that she was not on a steady course for r.15 to engage.

On r.09 vs. r15, the Court said crossing rules (r.15) are overridden only when the approaching vsl is shaping to enter the channel, adjusting her course so as to reach the entrance on her final approach. Alexandra 1 was not doing any of it.

On engagement of r.15, court emphasized on the difference between “STEADY BEARING” and “course”. Rule 15 deals with a steady bearing (as opposed to a steady course) collision situation, and both vsls were approaching each other on a steady bearing.

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