The continuing utility of the action in rem

Considers the effect of the House of Lords decision in India v India Steamship Co Ltd (The Indian Endurance and The Indian Grace) (No.2) that an action in rem brought in the Admiralty Court is an action against the owners. Highlights criticisms of the decision by the Australian Federal Court in Comandate Marine Corp v Pan Australia Shipping Pty Ltd for failing to explain key features of the Admiralty jurisdiction, including the place of the maritime lien in the context of an action in rem and the traditional separateness of the judgment on the action in personam and in rem