19.1 The claims enforceable by action in rem are those listed or referred to in the Supreme Court Act 1981, section 20. They are discussed in Chapter 2. As said in Chapter 17, the label “statutory liens” when used in an Admiralty context is used as equivalent to “statutory rights in rem” , and to some the latter is the more accurate description of the right. The present legislative framework provides for three categories of claim which, apart from the maritime lien, attract the action in rem and a fourth category which arguably does so. These are claims based on: