It has to be said first that the general approach in the case at appellate level seems somewhat removed from modern reality. Sheen, J., felt that, where containers were provided to a shipowner for use on his ships and were in fact used on his ships, they were “supplied to a ship for her operation or maintenance” within s. 20(2)(m) of the 1981 Act.1 In the Court of Appeal2 and in the House of Lords,3 a much more direct link between the arrangement and a ship was thought to be required before a claim could be said to be so supplied and therefore to found a “maritime claim” within Admiralty jurisdiction. The present claimants failed: on one view, because the arrangement was that the containers were to be delivered to shippers, not to a ship; and, on another, because the arrangement was with the shipowner and not with the ship, in that no particular ship was specified. The House of Lords reached its conclusion (expressed in a speech by Lord Brandon of Oakbrook) through a linguistic construction of the particular statutory provision at issue supported by the historical roots of the provision, which, in Lord Brandon’s view, were reflected in the Arrest Convention.