Abstract
The meaning of the term "underway" is defined in Collision Regulations and has been interpreted strictly in relation to its definition since it was defined. So a power-driven vessel, even lying still on the water, is "underway" and a sailing vessel, when hove-to, is "underway" I reexamined the leading cases being concerned in interpretation of "underway" and found the following factors exerting a influence upon interpretation of "underway" in the leading cases being established on such a interpretation on "underway". 1. a vessel lying to was judged her to be "underway" by her appearances showing lights or another elements. 2. a vessel lying to was able to manoeuvre as required by these Rules by using her engines or sails and was not unable to manoeuvre. 3. a vessel lying to was in some motions actually with another vessel approaching her and was no motionless I and opinion, upon the facts of leading cases, that interpretation of "underway" depend on definition would not apply to Steering and Sailing Rules without reserve.
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