Eleven years later, Maersk Seoul ruling traces $13.3m casualty to dangerous goods packing failure

A calcium hypochlorite cargo that violently decomposed aboard the Maersk Seoul in the Strait of Hormuz in 2015 has resulted in a US$13.3 million judgment against the shipper, after an eleven-year legal battle that crossed three jurisdictions.

More than a decade after a calcium hypochlorite cargo triggered a major fire aboard the Maersk Seoul, an English Commercial Court judgment has put the spotlight on how dangerous goods were packed before they ever reached the ship, explains Clyde & Co.

Handed down on 28 July 2026, the judgment in Maersk A/S v Sree Rayalaseema Hi-Strength Hypo Limited (MV Maersk Seoul) [2026] EWHC 2005 (Comm) provides the first detailed public account of the 2015 casualty and finds the Indian chemical manufacturer, referred to as the Defendant, liable for the resulting losses.

The Court awarded Maersk US$13,178,280.51 for losses arising from the explosion and fire, along with a further US$168,064.48 and £16,296 for breach of an exclusive English jurisdiction clause. It also granted a permanent mandatory anti-suit injunction.

Clyde & Co notes that the ruling carries a wider message for the container industry: dangerous goods compliance goes beyond declaring what is in a box. The way hazardous cargo is packed can be critical to whether it can safely withstand an ocean voyage.

A fire in the Strait of Hormuz

The Maersk Seoul, a fully cellular, gearless container vessel built in 2006, was 332 metres long, 42.2 metres wide and capable of carrying 8,411 TEU. On 19 July 2015, roughly nine hours after leaving Jebel Ali in the UAE for Jeddah, the vessel suffered a major explosion and fire in the Strait of Hormuz.

The cargo at the centre of the case was calcium hypochlorite, a dangerous chemical capable of violent decomposition. The Defendant had shipped five containers of the material in July 2015. Two contained granules packed in plastic drums, while three contained larger tablets, or galets, individually wrapped in foil and packed in fibreboard cartons.

Three of those containers were loaded aboard Maersk Seoul on 18 July after first travelling on the feeder vessel Talassa.

The Court found that the explosion and subsequent fire were caused by violent decomposition of the calcium hypochlorite in containers MSKU7134795 and/or MSKU2820576.

How a packing failure became a major casualty

The fire broke out on deck above cargo hold No. 1 and required an extensive response. The crew released CO₂ and carried out boundary cooling, with assistance from the Royal Omani Navy. Salvors were brought in under Lloyd’s Open Form, but the fire was not fully extinguished until 23 July.

Firefighting water flooded cargo holds 1 and 2 to depths of 14.2 metres and 2.7 metres, respectively, submerging containers stowed inside them.

Multiple containers were destroyed or damaged, while the vessel’s deck plating and electrical systems suffered heat and fire damage.

The incident did not end there. Two additional containers carrying the same calcium hypochlorite cargo had been shipped separately aboard Maersk Indus. They were discharged at Jebel Ali on 22 July as a precaution and were being cross-stuffed into reefer containers.

The following day, before the doors of one reefer were closed, the contents of container MSKU4287300 violently decomposed and caught fire, destroying the container and its cargo. Another container, MRKU9908482, showed heat damage during the cross-stuffing operation.

The events provided further evidence of the instability of the cargo once conditions allowed the decomposition process to develop.

The IMDG Code at the centre of the case

The central issue was how the calcium hypochlorite had been packed. The applicable IMDG Code provisions required packages inside containers to allow adequate air circulation throughout the cargo. The Court found that the cartons containing the calcium hypochlorite had instead effectively been packed together as a block. That restricted air circulation and prevented heat from dissipating properly.

Expert evidence established that compliance with the IMDG Code requirement would have greatly reduced the risk of a runaway reaction and, more likely than not, would have prevented the casualty.

The finding carries a wider message for the carriage of dangerous goods. Correctly identifying and declaring a hazardous cargo is only part of the shipper’s responsibility. Packing, stowage and segregation requirements can be just as critical to whether dangerous goods can safely withstand an ocean voyage.

Shipper’s obligations go beyond the label

The contracts of carriage incorporated Safmarine’s standard terms, which the Court found had been sufficiently brought to the Defendant’s attention even though Maersk could not produce a complete set of booking confirmations and final bills of lading for every shipment.

Under those terms, the shipper warranted that dangerous goods would be adequately packed to withstand the risks of carriage and would comply with applicable laws and regulations. The Court found that the failure to pack the calcium hypochlorite in accordance with the IMDG Code breached that warranty.

The shipper had also warranted that its goods would not cause loss or damage to Maersk or other cargo. That warranty was breached as well. The Court additionally found liability at common law. A shipper has a duty to take reasonable care when presenting goods for carriage to ensure they can be transported without causing physical damage to other property.

The inadequate packing therefore had consequences well beyond the cargo itself.

Maersk was entitled to recover payments made to the vessel’s head owners and salvors, settlements with cargo interests and other losses, with the recoverable losses ultimately quantified at approximately US$13.18 million.

The judgment also contains an important point for carriers.

Clyde & Co also highlights an important point for carriers. Maersk’s own dangerous goods procedures were not without shortcomings. Its Dangerous Goods Team had not checked the relevant stuffing reports before shipment, and the containers did not comply with aspects of Maersk’s own acceptance policy.

However, the Court found no evidence that these shortcomings were the real or operative cause of the casualty. That did not make the issue irrelevant.

The case demonstrates that a carrier can ultimately succeed in recovering losses from a shipper even where its own dangerous goods controls were imperfect. But a different evidential picture on causation, or a properly advanced contributory negligence case, could have made those shortcomings considerably more significant.

A lesson for both sides of the bill of lading

The Maersk Seoul judgment comes more than a decade after the casualty, but its practical message is immediate.

For shippers, dangerous goods compliance means more than applying the correct classification and declaration. The cargo must actually be prepared, packed and presented in a manner capable of safely withstanding the intended voyage.

For carriers, meanwhile, the case reinforces the importance of ensuring that dangerous goods acceptance procedures are not merely written into company policies but followed in practice. The Maersk Seoul casualty ultimately began with a packaging failure, but its consequences extended across a vessel, cargoes, salvors, owners and an eleven-year legal dispute.

The judgment therefore leaves a straightforward message for both sides of the bill of lading: when dangerous goods are involved, what is inside the container matters—but so does how it gets there.

source : safety4sea