The order almost always relates to the freezing of money but there was an interesting variation several years ago. It was invoked by CISBACLUB (the predecessor to ITIC – the shipbrokers P & I Association). The problem was that money was due to an agent by a time charterer thus arresting the ship involved was not an option. However, time charterers supply (and therefore own) the bunker fuel under a time charter and so the Mareva injunction was in respect of the bunkers. This effectively immobilised the ship as it was not permitted to take that fuel out of the court’s jurisdiction and the outstanding debt was paid. This device, however, is unlikely to be repeated because it could be argued that if the time charterer should prove insolvent, the shipowner would suffer despite having no part in the dispute. The basic principle enshrined in the Brussels Convention is that a defendant domiciled in a Contracting State must be sued in the courts of that state. However, where there is no express choice of law in the contract, a person domiciled in a Contracting State may be sued in another Contracting State “in matters relating to a contract, in the courts for the place of performance of the obligation in question”. Once a judgement has been rendered it can be enforced against a defendant in any Contracting State; the Jurisdiction Convention excludes Arbitration.