“…f, before the voyage, it renders the vessel unseaworthy. He relied upon various authorities, including the decision of the Court of Appeal in Dobell v Rossmore [1895] 2 QB 408, a case under the US Harter Act 1893, but stating principles equally applicable to the Hague Rules. The classic statement of the relevant principle that Articl…”
“…hin the exception in Article IV rule 2(a) and a defect in the plan cannot constitute unseaworthiness. It has been established, at least since Dobell v Passmore [1895] 2 QB 408, that a vessel may be rendered unseaworthy by negligence in the navigation or management of the vessel and, as Maxine Footwear established, the obligation to e…”