Although the effect of the lien clause was considered by the courts in the early part of the twentieth century,3 it was not until 1978 that the courts considered the juridical nature of the lien4 and there followed a series of cases which decided that the lien, which was neither a maritime lien, a common law possessory lien nor a statutory lien under the Administration of Justice Act 1956, s.1 (now the Senior Courts Act 1981, s.20), was an equitable assignment by way of security.5 Most of these cases were decided in the Commercial Court, but The Ugland Trailer 6 was heard in the Companies Court, as the receiver of the charterers who had been appointed by the debenture holder had applied to the court for directions as to whom the freight which they had collected was to be paid to—the owners or the bank as debenture holder—both of whom claimed the freight. If the previous decisions were followed, then the owners’ claim to the freight would have failed, as they had not registered the lien as a charge on book debts under the Companies Act 1948, s.95 (now the Companies Act 2006, s.395), the charterers being a limited company to which the Act applied. In the face of the weight of authority against him, the owners’ counsel, Peter Millett QC, adopted the bold approach of submitting that the owners’ lien was not an equitable assignment but a lien sui generis given by maritime law and was therefore not registrable under s.95. This innovative argument was rejected by Nourse J