Registration of Drilling Rigs Under the Coastal Inland Shipping Act: Review of the Transocean Decision

The recent decision of the Court of Appeal in Transocean Support Services Nigeria Limited & 3 Ors. v Nigerian Maritime Administration and Safety Agency & Anor1 (Transocean Decision) that an oil drilling rig is not a vessel and is therefore not engaged in coastal trading within the definition of Sections 2 and 22(5) of the Coastal and Inland Shipping (Cabotage) Act, 2003 (Cabotage Act), appears to have provided some respite as it relates to the debate whether drilling rigs qualify as vessels required to be registered under the Cabotage Act.

Prior to delving into the Transocean Decision, it may be useful to provide some background on the position of the law pre the Transocean Decision. 

The Cabotage Act, which is the principal legislation regulating cabotage in Nigeria, defines coastal trade or cabotage2 as generally relating to the carriage of goods by vessel or other means of transport or the carriage of passengers by vessel, including the engaging of vessels in other forms of marine transportation of a commercial nature.

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