Conflict of laws

Under English conflict of law rules, recognition of a right to enforce a maritime lien was a matter to be determined according to the law of the forum. There was no maritime lien of necessity under English law and the categories of maritime lien capable of recognition under English law could only be extended by statute. The mere fact that statute conferred a jurisdiction did not mean that under English law the claim in question assumed the nature of a maritime lien. Whilst in the English courts a supplier of bunkers to a vessel would be entitled to proceed by way of an action in rem, provided that the bunkers constituted necessaries, the supplier would not enjoy a maritime lien as a matter of English law