This monograph is the first comprehensive work on maritime law that adopts a comparative methodology throughout. Maritime law has long remained marginal in comparative law because it is widely viewed as an area in which international unification has been relatively successful. Numerous international maritime conventions already govern the field and English law occupies a dominant position, serving as the governing law in many shipping contracts, including charterparties, shipbuilding agreements and marine insurance policies. As a result, traditional research in maritime law has largely focused on domestic rules, international conventions and English law.

The author of this monograph is a professor of Montenegrin origin who works at Kyushu University in Japan. He has obtained degrees from the University of Montenegro, the University of Belgrade, Kyoto University and the University of Zagreb. This multijurisdictional learning and working background provided the author with important foundational knowledge for this book. Compared with the various existing works on maritime law, there are three distinctive features of this monograph.

First, this monograph provides an exceptionally comprehensive examination of maritime law, spanning 15 chapters. Except for the introductory chapter on background and history (Chapter 1), each chapter focuses on a distinct regime, from shipbuilding (Chapter 3) and ship sale contracts (Chapter 4), which strongly embody freedom of contract and are largely governed by English law, to procedural regimes such as ship arrest and judicial sale of ships (Chapter 6), the latter recently revitalised by the United Nations Convention on the International Effects of Judicial Sales of Ships. The design of each chapter reflects a careful selection of the most critical issues within its domain. While topics such as the master and crew or general average are not treated in separate chapters, this omission is understandable: the former involves labour and social security matters beyond maritime law, and the latter shows little divergence among jurisdictions under the York–Antwerp Rules. Relevant aspects of these regimes are nonetheless addressed where appropriate.

Second, the monograph places particular emphasis on the historical development of each maritime law regime. Maritime law, as a branch serving international trade and shipping, has always been characterised by its strong practical orientation and pragmatism. Consequently, most authoritative reference books pay little attention to historical analysis. The author notes in the preface that extensive historical coverage is an essential element of this monograph, and rightly so, since history and comparative law are closely intertwined. A comparative understanding of law is incomplete without a historical perspective. For example, in Chapter 9, the author reviews the history of charterparties in four stages, namely ancient history, Nomos Rhodion Nauticos, Lex Mercatoria and developments in the nineteenth century (303–06). By contrast, the authoritative reference books on charterparties in the United Kingdom, such as Carver on Charterparties and the three works in the Lloyd’s Shipping Law Library, respectively, on voyage charters, time charters and bareboat charters, focus mainly on modern practice and case law, with little systematic discussion of their historical development. The author notes that charterparties have a much longer history than bills of lading, marked by early innovations in contractual practice. Only in the nineteenth century did the contract of carriage for liner services emerge independently, distinguishing common from private carriage. While laws on common carriage are mandatory, particularly regarding carrier liability, charterparties as private arrangements remain largely governed by freedom of contract.

Third, as reflected in the title, the most prominent feature of the book is its comparative perspective. The authors of this review fully understand the challenges of such research, one having been the first scholar to offer a course on ‘Comparative Maritime Law’ in China. Many question its value, given that few fields are as dominated by a single national law, namely English law, as maritime law. Moreover, language barriers remain significant, as most major civil law jurisdictions publish little in English. These constraints make the monograph’s publication all the more remarkable.

The author, through more than 20 carefully crafted ‘comparative notes’, distinguishes two levels of comparative analysis: first, between the common law and civil law systems; and second, among different jurisdictions within each system. For the first type, the negotiability of the bill of lading illustrates a complex issue in both legal systems. Most studies, however, adopt the common law notion of the ‘document of title’ and treat it as one of the bill’s three main functions, even when discussing civil law jurisdictions such as Germany and Japan. In practice, while common and civil law systems take different approaches, both conclude that possession of the bill represents possession, but not ownership, of the goods. The civil law system, however, is grounded in a completely different theoretical basis, in which statutes expressly provide that the transfer of the bill has the same legal effect as delivery of the goods. As the author notes, these differences arise from the fundamentally distinct nature of the two systems: civil law tends to rely on broad, inclusive concepts, while the common law favours narrowly defined, case-based rules. For the second form of comparative note, when discussing the liability of time charterers for collision, the author adopts a comparative law perspective based on the East Asian jurisdictions with which he is most familiar, and specifically elaborates on the laws of Japan, South Korea and China (430–32).

Of course, it should also be noted that the analyses of the corresponding regimes in each chapter of this monograph are not systematic. This is not a flaw, as the author clearly states in the preface that the goal is not comprehensive coverage but, rather, to highlight the different approaches adopted in various jurisdictions. Indeed, while the English-speaking world already has authoritative reference works such as the British Shipping Laws series and the Lloyd’s Shipping Law Library, these focus largely on domestic law with little comparative perspective. Expecting a single author to provide a complete comparative analysis of all maritime regimes within the space of a few years would be unrealistic. This monograph’s comparative analysis is undoubtedly its most valuable contribution. By bringing different legal jurisdictions into a single analytical frame, it highlights both structural differences and shared underlying concerns. For that reason, the book should inspire other scholars—whether in maritime law or beyond—to recognise the value of adopting a comparative lens in legal scholarship.