Summary and Facts
Monford Management Ltd (The Owners of the “Kiveli”) v Afina Navigation Ltd (The Owners of the “Afina I”) [2026] 2 Lloyd’s Rep 1 concerned a collision between two bulk carriers off the south coast of Greece. The ships were approaching from almost opposite directions before Kiveli turned sharply left. The trial judge applied Rule 14 of the international collision-prevention rules (COLREGs) and held Kiveli 80% at fault and Afina I 20% at fault. Kiveli's owners appealed.
Legal Issues
Which rule applied: the rule for ships meeting head-on, or the rule for ships crossing each other’s path?
Did the head-on rule apply only if the other ship was within three degrees on either side of straight ahead?
Did both side lights have to be visible, and did the head-on rule continue after the ships changed direction?
Court of Appeal’s Findings
Different rules govern head-on and crossing encounters. In a head-on encounter, both ships must turn right to pass safely with their left sides facing each other.
There was no strict three-degree limit on either side of straight ahead. The head-on rule continued until the original collision risk had passed.
For a ship ahead or nearly ahead at night, either its mast lights lined up or nearly lined up, or both side lights, could satisfy the lighting test.
The appeal was dismissed. The head-on rule applied and the existing split of fault—80% to Kiveli and 20% to Afina I—remained unchanged.
Practical Implications
A small change of direction does not automatically turn a head-on encounter into a crossing encounter while the original collision risk remains.
Do not rely on a precise angle or the absence of both visible side lights to rule out a head-on encounter.
Records of the ships’ movements, radar data and observed lights, together with expert evidence, help establish who was at fault.