CIVIL PROCEDURE — Jurisdiction — Admiralty Jurisdiction — Claim for Breach of Contract Involving Carriage of Goods by Sea Not Admiralty
Ratio Decidendi
Per Mohammed, JSC, in Chevron Nigeria Limited v. Lonestar Drilling Nigeria Limited (2007) NLC-123-170-2002(SC) at p. 16; Paras B–D:
"The fact that the transaction between the parties giving rise to the Plaintiff's claim involves the conveyance of the Rig purchased from India to Nigeria by sea, does not give that transaction the character of an Admiralty action."
Explanation / Scope
Admiralty jurisdiction is specialized and limited to specific maritime causes, such as claims for salvage, towage, collision, or claims arising from ship mortgages. Not every contract that involves sea carriage or has a maritime connection falls within admiralty jurisdiction. The court must examine the nature of the claim, not merely the incidental involvement of the sea. The principle prevents the expansion of admiralty jurisdiction beyond its statutory limits and ensures that such claims are heard in the appropriate forum with the requisite expertise.