When a collision occurs between two ships on the high seas, very likely one may need to determine who should be liable for the collision and the apportionment of liability between them. However, it is not unusual to see a collision between an anchored vessel and another vessel underway. When determining apportionment of liability between them, it seems that there is a presumption of fault against the vessel underway. To counteract such a presumption, the author discusses some issues in respect of collisions between a vessel at anchor and others underway under the International Regulations for Preventing Collisions at Sea, 1972 (COLREGs) by examining the obligations of anchored vessels to avoid a collision at sea.
