Never gave this much of a thought, but its an interesting question. What is the scope of maritime lien? Does it attach to all items onboard? In the past, things like radio equipment, chronometer, replacement engines, eq. for telecommunication & internet, refrigeration eq. and slot machines have been held to be appurtenances subject to a maritime lien. In The Blue Star [2021], the question was whether artwork, specifically 14 paintings on this luxury pleasure yacht could be sold to satisfy the lien.
Here the repairer and unpaid crew had the yacht arrested. It was auctioned off but the money received wasn’t enough to satisfy the claims. They now wanted the artwork onboard to be sold off too. Yacht’s owner said that the paintings were not a part of the yacht, served no purpose and that it had been functioning as a pleasure cruise long before the paintings were even fastened to the walls of the yacht.
As per the court, the scope of a maritime lien includes the vessel, its apparel, fixtures, and appurtenances. An ‘appurtenance’ is an item that is essential to the ship's navigation, operation, or mission. The question essentially was whether paintings were appurtenances. In other words, were they essential to the yacht’s mission?
The yacht's mission was recreation and luxury. The feeling of pleasure Blue Star imparted to its occupants derived, at least in part, from the sense of sophisticated refinement it afforded, and its Russian artwork contributed to that. The paintings were therefore essential to the luxurious look-and-feel of the yacht, and thus also to its mission.
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