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T-500-82
Walter Kuhr, and Walter Kuhr, Charles R. Hart, Robert Allen and Walter Kuhr Jr., carrying on business as Dona Genoveva Partnership, and the said Dona Genoveva Partnership (Plaintiffs)
v.
The Ship Friedrich Busse and Hochseefischerei Nordstern A.G. (Defendants)
Trial Division, Addy J.—Vancouver, February 8 and 17, 1982.
Maritime law — Jurisdiction — Plaintiffs contracted to supply fish at sea to defendant vessel which was obliged to remain within specified fishing areas and to receive delivery of and pay for fish — Plaintiffs allege breach of contract — Defendants seek to set aside statement of claim and to dismiss action for lack of jurisdiction or because Canadian court is forum non conveniens — Defendants argue no action in rem against ship because there is no allegation against shipowner in statement of claim and therefore no action in personam — Whether Trial Division has jurisdiction under s. 22(2) of Federal Court Act over claims arising out of contract to supply fish — Whether general substance of matter falls within jurisdiction of Trial Division over Canadian maritime law pursuant to s. 22(1) of Federal Court Act — Whether Federal
Court constitutes forum conveniens Motion dismissed — Supply of fish is essential to operation of vessel — Matter is predominantly maritime in character — Federal Court Act, R.S.C. 1970 (2nd Supp.), c. 10, s. 22(I),(2)(i).(m).
The owners of the defendant ship, a fish processing vessel, apply for an order to strike out the statement of claim and to dismiss the action. The plaintiffs allege that the defendants are in breach of a contract whereby the plaintiffs were to supply fish at sea to the defendant vessel which was obliged to remain within the specified fishing areas and receive delivery of and pay for the fish. The defendant owners submit that the Court has no jurisdiction to entertain the action for three reasons: (1) there is no action in rem against the ship because there is no allegation against the shipowner as owner in the statement of claim, and therefore no action in personam (2) the supplying of fish under a contract does not fall within paragraph 22(2)(i) of the Federal Court Act which gives the Trial Division jurisdic tion over claims arising out of agreements relating to the use of a ship, nor within paragraph 22(2)(m) which gives the Trial Division jurisdiction over matters relating to the supply of goods to a ship for her operation, and (3) the substance of the matter does not fall within the general jurisdiction in admiralty matters granted to the Federal Court by section 22 of the Federal Court Act. The defendants further argue that a Canadian court constitutes a forum non conveniens.
Held, the motion is dismissed. The statement of claim con tains allegations against the defendant company for amounts due and for damages. This claim would be maintainable against the owners since they signed the contract and would be reaping the benefits of the contract. When the owner undertakes that his ship will be in a certain place at a certain time and will perform certain tasks, in this case take delivery of and pay for the fish caught by the plaintiffs, the owner is responsible at law for the performance of that contract. The supplying of fish to a vessel cannot be construed as an agreement relating to the use of a ship as contemplated by paragraph 22(2)(i). The use referred to is use of the ship by a party other than the owner. Paragraph 22(2)(m) must necessarily include, but is not limited to, the supplying of necessaries. In other words, the supplying of goods need not be necessary for the operation of the vessel but may be ancillary or complementary thereto as long as they are used or intended for use in the operation of the ship. In this case, the obtaining of fish is essential to the vessel being operated for the purpose for which it exists, the business of fishing. As to the third argument, the contract deals with the actual transfer and delivery of possession of goods on the high seas between two ships. The goods are to come from an agreed area of the sea and the contracting parties have mutually agreed that their vessels are to operate there and carry out the provisions of the contract in that specified area. It is difficult to conceive of a situation or of an undertaking which is more maritime in nature. The Admiralty Court of England from which the Federal Court derives its jurisdiction in admiralty matters would necessarily have assumed jurisdiction. Applying the test formulated in Sumitomo Shoji Canada Ltd. v. The Ship `fuzan Maru" [1974] 2 F.C. 488 of the true essence of the contract in all the circumstances and facts of the case, and the test formulated in Underwater Gas Developers Ltd. v. Ontario Labour Relations Board [1960] O.R. 416, of dominant features and objects, it is clear that the matter is predominantly maritime in character, and falls within the subject-matter of Canadian maritime law as provided for in subsection 22(1). As to the argument of forum non conveniens, the ship was arrested in Vancouver whilst undergoing repairs which had nothing to do with the performance of the contract. The plaintiffs are American, the defendant company is German, the ship is registered in Germany, the contract was made there and was to be performed out of this jurisdiction and payment was tendered and accepted in United States currency. However, as indicated in Antares Shipping Corporation v. The Ship "Capricorn" [1977] 2 S.C.R. 422, the overriding consideration must be the existence of another forum more appropriate for securing the ends of justice and therefore other factors have a direct bearing on the issue. An inspection revealed that the ship was probably underlogging fish and misrepresenting the contents of blocks of fish. The ship allegedly left American fishing waters to dispose of the catch and to avoid prosecution. The plaintiffs allege that in doing so the defendants were in breach of contract. In light of the alleged fraudulent conduct of the defendants and the fear that the release of the ship without proper security would result in their losing any chance of recovery, this Court is the forum most suitable for the ends of justice.
Western Nova Scotia Bait Freezers Limited v. The Ship "Shamrock" [1939] Ex.C.R. 53, followed. Sumitomo Shoji Canada Ltd. v. The Ship "Juzan Maru" [1974] 2 F.C. 488, applied. Underwater Gas Developers Ltd. v. Ontario Labour Relations Board [1960] O.R. 416, applied. Antares Shipping Corporation v. The Ship "Capricorn" [1977] 2 S.C.R. 422, applied. Westcan Stevedoring Ltd. v. The Ship "Armar" [1973] F.C. 1232, distinguished. Elesguro Inc. v. Ssangyong Shipping Co. Ltd. [1981] 2 F.C. 326, distinguished. Marazura Navega- cion S.A. v. Oceanus Mutual Underwriting Association (Bermuda) Ltd. [1977] 1 Lloyd's Rep. 283 (Q.B. (Com. Ct.)), distinguished.
MOTION. COUNSEL:
John R. Cunningham for plaintiffs. D. G. Rae for defendants.
SOLICITORS:
Macrae, Montgomery & Cunningham, Van- couver, for plaintiffs.
Russell & DuMoulin, Vancouver, for defend ants.
The following are the reasons for order ren dered in English by
ADDY J.: The defendant ship was arrested in Vancouver at the request of the plaintiffs at the time of the issuing of the statement of claim in this action. Following the granting of leave to enter a conditional appearance, the present application was made on behalf of the owners of the defendant ship for an order to strike out the statement of claim herein and to dismiss the action on the ground of lack of jurisdiction or, alternatively, on the ground that a Canadian court constitutes a forum non conveniens.
The Friedrich Busse, which is registered in Ger- many, is a fish processing vessel and the plaintiffs, owners of the Dona Genoveva, who were fishing off the coast of Alaska and the Aleutian Islands, were delivering fish to the Friedrich Busse for processing at sea pursuant to a contract made and signed in Germany between the defendant com pany and a representative of the plaintiffs. In that contract (para. 2) the defendant company described itself as the owner of the Friedrich Busse. It now turns out, according to the affidavit evidence of the applicant, that the ship was and is, in fact, the property of a wholly owned subsidiary
company of the defendant, namely Reederei Frie- drich Busse Hochseefischerei Nordstern A.G. & Co. Kommanditgesellschaft.
In view of the similarity of names, the fact that the actual owners are a subsidiary of the defendant company and that the latter held itself out to be the owner, I attach no importance whatsoever to the fact that the contract was not in the name of the actual owner. I am assuming at this stage and for the purpose of the present motion and in the absence of any evidence to the contrary, that the contract was executed on behalf of the actual owners and with their full knowledge and consent.
The first ground alleged, namely that this Court has no jurisdiction to entertain the action, is based on three arguments.
The first one is that there is no action in rem against the ship because there exists no action in personam against the shipowner. Counsel for the applicant argues in support of this proposition that the statement of claim contains no allegation against the shipowner as owner, nor could any claim against the owner be maintained at law even if such an allegation existed. The applicant relies on this in the case of Westcan Stevedoring Ltd. v. The Ship "Armar" [1973] F.C. 1232. I fully agree with the principle approved and adopted by my brother Collier J. in that case, to the effect that a right in rem against a vessel is dependent upon the existence of a liability on the part of its owner apart from statute and that Parliament did not, in granting admiralty jurisdiction to the Federal Court, intend to alter that principle. In the last- mentioned case, however, it is very important to remember that, unlike the case at bar, it is undis puted that there existed no liability on the part of the owners. This is brought out quite clearly by Mr. Justice Collier at page 1234 of the above-men tioned report:
Mr. Lutz candidly admitted he never at any time dealt with the owners of the vessel or the master of the vessel in respect of the supplying of these stevedoring services. He said his com pany was not looking to the credit of the vessel or her owners, but was supplying the services on the credit of the charterers or their subagents. [Emphasis added.]
In the present case the statement of claim in issue contains allegations against the defendant
company for amounts due for fish supplied the ship and for damages for failure of the ship to remain in the fishing waters in the Bering Sea, Aleutian Islands and Gulf of Alaska fishing areas. This claim would be maintainable against the owners as such, since they signed the contract (or for the reasons previously stated are, for the pur pose of this motion, to be considered as having signed it) and would be reaping the benefits of the contract. When the owner undertakes that his ship will be in a certain area at a certain time and will perform certain tasks, in this case take delivery of and pay for the fish caught by the plaintiffs, the owner is obviously responsible at law for the performance of that contract. The first argument of the applicant therefore cannot be sustained.
The second argument is to the effect that no action is maintainable against the ship in any event because the supplying of fish under a con tract does not fall within any of the paragraphs of subsection 22(2) of the Federal Court Act, R.S.C. 1970 (2nd Supp.), c. 10, or, more particularly, within paragraphs (i) and (m), on which the plain tiffs rely. This argument is also related to the third one to the effect that, in addition, the substance of the matter does not, in any event, fall within the general jurisdiction in admiralty matters granted to this Court by subsection 22(1). I shall deal with both these arguments at the same time.
The relevant portions of section 22 read as follows:
22. (1) The Trial Division has concurrent original jurisdic tion as well between subject and subject as otherwise, in all cases in which a claim for relief is made or a remedy is sought under or by virtue of Canadian maritime law or any other law of Canada relating to any matter coming within the class of subject of navigation and shipping, except to the extent that jurisdiction has been otherwise specially assigned.
(2) Without limiting the generality of subsection (1), it is hereby declared for greater certainty that the Trial Division has jurisdiction with respect to any claim or question arising out of one or more of the following:
(i) any claim arising out of any agreement relating to the carriage of goods in or on a ship or to the use or hire of a ship whether by charter party or otherwise;
(ni) any claim in respect of goods, materials or services wherever supplied to a ship for her operation or maintenance including, without restricting the generality of the foregoing, claims in respect of stevedoring and lighterage;
I agree that a contract for the supplying of fish to a vessel, merely by reason of the fact that the vessel is processing the fish and is thus using the fish supplied, cannot fairly be construed as an "agreement relating to ... the use ... of a ship" as contemplated by paragraph (i). When the word "use" is considered in that context it seems clear that the use referred to is use of the ship by a party other than the owner: an agreement for use and an ordinary contract for hiring would be ejusdem generis.
However, the question as to whether paragraph (m) applies is not nearly so clear. It might well be that the word "operation" in that paragraph does not refer only to the actual navigation of a ship over the water but to its operation generally where it has another function such as receiving delivery of fish on the high seas and processing same, even though the actual processing might well be the same as the operation carried on by a fish process ing factory situated ashore.
Nowhere in the specifically enumerated matters in subsection (2) of section 22 is there any mention of contracts for the supplying of necèssaries for a ship. This has long been recognized as a claim falling within the ambit of Canadian maritime law and also the jurisdiction of the former Exchequer Court of Canada and thus the Federal Court of Canada.
A decision of the Exchequer Court in point is that of Western Nova Scotia Bait Freezers Lim ited v. The Ship `Shamrock" [1939] Ex.C.R. 53. That vessel was also engaged in the fishing busi ness. The contract was for the supply of bait and ice to the ship to enable it to carry on with fishing. It was held therein that the bait and ice were necessaries having regard to the nature of the business of the ship. The learned Judge states at pages 54 and 55 of the above-mentioned report:
There are two defences set up to the action, the first that the goods supplied were not "necessaries" within the meaning of that word as interpreted by Courts of Admiralty, and in any event there is no proof that the bait and ice were necessary at the time of delivery. This vessel was engaged in the fishing business and it is shown by the evidence that ice and bait are essential for the prosecution of that industry as carried on by the Shamrock. I think, too, that without any evidence of the situation here one having knowledge of the business in which this vessel was engaged is bound to reach the conclusion that bait and ice were necessary for the proper prosecution of that
business because "necessaries" has been judicially interpreted as "whatever is fit and proper for the service in which the vessel is engaged; whatever the owner of that vessel as a prudent man would order if present at the time": Abbott C.J., in Webster v. Seekamp ((1821) 4 B. & E. Ald. 352; 106 E.R. 966).
It seems to me that the business of fishing can no more be considered navigation and shipping or the operation of a ship qua ship in a restricted sense, than the obtaining of delivery of fish on the high seas by purchase and the processing of same. In the case at bar the vessel was designed for and engaged in that business and nothing else. The obtaining of fish is absolutely essential to the vessel being operated for the purpose for which it exists. No distinction can reasonably be made on the facts between the two cases. I therefore feel that, failing an obvious error in law in the above- mentioned decision or a subsequent change in the law since then, I am required to follow the deci sion. There is, in my view, no error in law and the only change in law is the enactment of section 22 of the Federal Court Act.
The expression "supplying of necessaries" is not to be found among the specifically enumerated matters in subsection 22(2) of the Federal Court Act. In essence, however, it would be contained within the wording of paragraph (m) above and, if one were attempting to establish a distinction in meaning between the two concepts, one could only find that the wording of paragraph (m) must necessarily include, but is not limited to, the sup plying of necessaries; in other words, that the supplying of the goods, material or services need no longer be necessary for the operation but may be ancillary or complementary thereto, as long as they are used or intended for use in the operation of the ship. Altogether apart from the apparent extension given to the concept of ship's necessaries by paragraph 22(2)(m) of the Federal Court Act, we find that the rather restrictive interpretation originally applied to that term has been consider ably widened. In Roscoe's Admiralty Jurisdiction and Practice of the High Court of Justice (5th Edition) we find the following at page 203:
.., though primarily meaning indispensable repairs, anchors, cables, sails, and provisions, the term has now, it is clear, a wider signification, and has been and is being gradually ampli-
fied by modern requirements, as is instanced by the case of The Mecca, where canal dues were pronounced to be within the scope of the word. No distinction can be drawn between necessaries for the ship and necessaries for the voyage, and all things reasonably requisite for the particular adventure on which the ship is bound are comprised in this category.
What is of equal importance, however, is the question of whether a contract between the owners of two ships, one of which is to supply the fish on the high seas to the other which is obliged to remain within the specified fishing areas and receive delivery of and pay for the fish, would fall within the meaning of the words "Canadian mari time law or any other law of Canada relating to any matter coming within the class of subject of navigation and shipping" contained in subsection
22(1).
It is well established that the Federal Court of Canada, as was its predecessor the Exchequer Court of Canada, in addition to any other statu tory jurisdiction it might possess in admiralty mat ters or otherwise, is vested with the jurisdiction formerly exercised by the Admiralty Courts of England at the time that jurisdiction in admiralty matters was acquired by the Exchequer Court of Canada. It is obvious that fish processing ships did not and could not exist at that time and, therefore, there was no factual situation on which the Admi ralty Courts of England could have exercised their jurisdiction. The question one must ask, therefore, is not whether they did in fact exercise their jurisdiction in such cases but whether they would have been justified in law in doing so at the time, had the question arisen.
The contract is not merely one covering the transfer of property in goods but also more essen tially one which deals with the actual transfer and delivery of possession of those goods on the high seas between two ships. The goods themselves are to come from an agreed area of the sea and the contracting parties have mutually agreed that their vessels are to operate there and carry out the provisions of the contract in that specified area. It is difficult to conceive of a situation or of an undertaking which is more maritime in nature than the subject-matter covered by the contract in issue and I feel confident that had any Admiralty Court in England been faced with that factual
situation, it would necessarily have assumed juris diction and legally disposed of the issue between parties.
The applicant also relied on another decision of Mr. Justice Collier in support of his argument, namely the case Sumitomo Shoji Canada Ltd. v. The Ship "Juzan Maru" [1974] 2 F.C. 488; 49 D.L.R. (3d) 277. In that case the Court declined jurisdiction, but it was clearly on the basis that, on examining the true essence of the contract in the light of all the circumstances and the particular facts of the case, it appeared that the maritime or shipping aspects of the business arrangement be tween the parties were miniscule or incidental, (ref. p. 284 of the above-mentioned report) [[1974] 2 F.C. at pp. 496-497], and that the essence of the arrangement was not maritime. I fully agree with that principle and with the test of dominant features and objects applied in the case of Underwater Gas Developers Ltd. v. Ontario Labour Relations Board (1960) 24 D.L.R. (2d) 673; [1960] O.R. 416. Those are precisely the tests which, when applied to the facts of the present case, convince me that the matter is predominantly maritime in character.
I therefore find that, altogether apart from the question of whether the contract covers the supply ing of necessaries or whether it falls within para graph 22(2)(m), it would in any event fall within the subject-matter of Canadian maritime law as provided for in subsection 22(1).
I now turn to the argument of forum non conveniens.
The ship was arrested in Vancouver whilst undergoing repairs and therefore this Court has jurisdiction in rem over the vessel. The question of forum conveniens is, of course, a completely differ ent question from that of jurisdiction and does not arise unless the Court has jurisdiction.
The plaintiffs are American, the defendant com pany is German, the ship is registered in Germany, the contract was made there and was to be per formed out of our jurisdiction, payment was ten dered and accepted in United States currency and the repair and maintenance of the ship which led to its being in a Canadian port and to its arrest has nothing to do with the performance of the contract
which led to the present action. It would seem at first glance in the light of these facts that a Canadian court would not constitute a forum con- veniens to try the present issue between these parties.
There are, however, other factors which have a direct bearing on the issue. Although operations of the defendant ship were carried out to a very large extent within the U.S. 200-mile fishing limits, it is not subject to arrest there in admiralty matters, unless it also be within the 3-mile territorial waters portion of same, the remaining 197 miles being among other things a zone for management of fisheries but not subject to the general territorial jurisdiction of the United States.
During the performance of this contract and following reports that the defendant ship was in breach of its U.S. fishing authorization or licence to operate in U.S. Fishing Management waters, the vessel was boarded by inspectors of the U.S. Department of Commerce, National Oceanic and Atmospheric Administration. According to the report prepared by counsel for the U.S. Govern ment, who recommends prosecution of the vessel, the inspection revealed that it had in all probabili ty underlogged between 750 and 1,400 metric tons of cod and that, of the 100 samples of fish taken from blocks labelled as pollock, 94 samples were, in fact, cod. Conviction on the proposed charges would lead to very substantial penalties, that is, $2,500 per day for the period 13 January 1981 to the date of boarding, that is, 13 April 1981, and to the possibility of seizure of the vessel. The ship left American fishing waters on the day following the boarding and apparently went to Mexico, allegedly for repairs but, according to the plaintiffs, in order to escape action and to get rid of the catch. Part of the plaintiffs' claim is based on the allegation that, in leaving the fishing area, the defendants were in breach of contract.
The vessel did touch in at Dutch Harbour, Alaska, approximately five times since the dispute arose but apparently only for very short periods. The plaintiffs were unable to determine in advance when it would touch in at that port and evidence
was tendered that Dutch Harbour is extremely remote from the United States Federal Court in Alaska and that it is most difficult to send a marshal in time to seize a ship there when it merely touches port for the purpose of taking on supplies or fuel. There is no evidence that the ship will be entering United States territorial waters again although there is evidence that it intends to return to the fishing areas off the coast of Alaska in order to continue its usual operations following the repairs presently being carried on here.
There is no evidence of any hardship on the defendants should there be any requirement on their part to provide bail for the release of the ship, such as existed in the case of Marazura Navega- cion S.A. v. Oceanus Mutual Underwriting Asso ciation (Bermuda) Ltd. [1977] 1 Lloyd's Rep. 283 (Q.B. (Com.Ct.)).
Furthermore, as the ship will not be returning to Germany but will be remaining off the west coast of North America, that is, relatively close to this jurisdiction, I can foresee no particular difficulty for the defendants or prejudice to them from an evidentiary standpoint. In addition, the agent for the defendants in the United States is but a few miles away, in Seattle, in the State of Washington.
The cases of Sumitomo Shoji Canada Ltd. v. The Ship "Juzan Maru" [supra] and Elesguro Inc. v. Ssangyong Shipping Co. Ltd. [1981] 2 F.C. 326; 117 D.L.R. (3d) 105, referred to by the defendants are of little help and are readily distin guishable. In neither one of these do the causes of action pertain to the ship which was arrested.
The most recent leading case governing factors to be considered by a trial judge in exercising his discretion on the issue of forum conveniens is the decision of the Supreme Court of Canada in Antares Shipping Corporation v. The Ship "Capricorn" [1977] 2 S.C.R. 422. In that case Mr. Justice Ritchie in delivering judgment on behalf of the majority of the Court stated at page 448:
The factors affecting the application of this doctrine have been differently described in various cases, to some of which refer ence will hereafter be made, and they include the balance of
convenience to all the parties concerned, including the plaintiff, the undesirability of trespassing on the jurisdiction of a foreign state, the impropriety and inconvenience of trying a case in one country when the cause of action arose in another where the laws are different, and the cost of assembling foreign witnesses.
In my view the overriding consideration which must guide the Court in exercising its discretion by refusing to grant such an application as this must, however, be the existence of some other forum more convenient and appropriate for the pursuit of the action and for securing the ends of justice. Each such case must of necessity turn upon its own particular facts ....
At page 451 of the same report the learned Justice also quoted with approval the statement of Megar- ry J. in G.A.F. Corporation v. Amchem Products Inc. [1975] 1 Lloyd's Rep. 601 (C.A.), where the latter stated:
When I consider the forum conveniens, I bear in mind that it has been said that the term means not the `convenient' Court, but the `appropriate' Court or the court 'more suitable for the ends of justice': See The Atlantic Star, 1973 2 All E.R. 175.
At page 453, Mr. Justice Ritchie also quoted with approval the following pronouncement of Lord Sumner in La Société du Gaz de Paris v. La Société Anonyme de Navigation Les Armateurs Francais [1926] S.C. (H.L.) 13:
The real proposition is, I think, that the Court has to consider how best the ends of justice in the case in question and on the facts before it, so far as they can be measured in advance, can be respectively ascertained and served ... The object, under the words 'forum non conveniens' is to find that forum which is the more suitable for the ends of justice, and is preferable because pursuit of the litigation in that forum is more likely to secure those ends.
He also approved the following statement of Lord Simon in The Atlantic Star [1973] 2 All E.R. 175 at 197-198:
Ships are elusive. The power to arrest in any port and found thereon an action in rem is increasingly required with the custom of ships being owned singly and sailing under flags of convenience. A large tanker may by negligent navigation cause extensive damage to beaches or to other shipping: she will take very good care to keep out of the ports of the `convenient' forum. If the aggrieved party manages to arrest her elsewhere, it will be said forcibly (as the appellants say here): 'the defendant has no sort of connection with the forum except that she was arrested within its jurisdiction.' But that will frequently be the only way of securing justice.
Had the ship been arrested in U.S. waters or had security been furnished a U.S. Court, trial in that jurisdiction would certainly have been prefer able. But such is not the case and, in the light of
the alleged fraudulent conduct of the defendants which is supported to some degree by evidence and the fear of the plaintiffs that the release of the ship without proper security being furnished would in all probability result in their losing any chance of recovery, the fact that the ship is arrested within this jurisdiction assumes added importance.
As has been stated in The Atlantic Star case and many other admiralty decisions, a ship, because of its very mobility is an elusive asset which can easily be disposed of in some distant place and the proceeds of the sale can easily be put beyond the reach of a legitimate claimant.
Having regard to the circumstances as they exist at the present time, I feel that this Court is the forum most suitable for the ends of justice and, in fact, it appears to be the only place where justice could be secured.
The defendants' motion will therefore be dis missed with costs.
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