Protest RoomCases
Published cases and decisions that clarify rule interpretations.
Case 1
A boat that breaks a rule while racing but continues to race may protest over a later incident, even though after the race she is penalized for her breach.
Relevant Rules
Case 2
This case covers a situation involving two boats at a downwind mark in which a boat clear astern reaches the zone before a boat clear ahead. In that situation the boat clear ahead is required by rule 18.2(a)(2) to give mark-room to the boat clear astern.
Relevant Rules
Case 3
A leeward port-tack boat, hailing for room to tack when faced with an oncoming starboard-tack boat, an obstruction, is not required to anticipate that the windward boat will fail to comply with her obligation to tack promptly or otherwise provide room.
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Case 5
A boat that is anchored during a race is still racing. A boat does not break rule 42.1 or rule 45 if, while pulling in her anchor line to recover the anchor, she returns to her position at the time the anchor was lowered. However, if pulling in the anchor line clearly propels her to a different position, she breaks those rules.
Case 6
A starboard-tack boat that tacks after a port-tack boat has borne away to go astern of her does not necessarily break a rule.
Case 7
When, after having been clear astern, a boat becomes overlapped to leeward within two of her hull lengths of the other boat, the windward boat must keep clear, but the leeward boat must initially give the windward boat room to keep clear and must not sail above her proper course. The proper course of the windward boat is not relevant.
Case 8
Repeated helm movements to position a boat to gain speed on each of a series of waves generated by a passing vessel are not sculling unless they are forceful, and the increase in speed is the result of a permitted use of the water to increase speed.
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Case 9
When a starboard-tack boat chooses to sail past a windward mark, a port-tack boat must keep clear. There is no rule that requires a boat to sail a proper course.
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Case 10
If a boat hails ‘Room to tack’ when she is neither approaching an obstruction nor sailing close-hauled or above, she breaks rule 20.1. The hailed boat is required to respond even if the hail breaks rule 20.1.
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Case 11
When boats are overlapped at an obstruction, including an obstruction that is a right-of-way boat, the outside boat must give the inside boat room between her and the obstruction.
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Case 12
In determining the right of an inside boat to mark-room under rule 18.2(a)(1), it is irrelevant that boats are on widely differing courses, provided that an overlap exists when the first of them reaches the zone.
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Case 13
Before her starting signal, a leeward boat does not break a rule by sailing a course higher than the windward boat’s course.
Case 14
When, because of a difference of opinion about a leeward boat’s proper course, two boats on the same tack converge, the windward boat must keep clear. Two boats on the same leg sailing near one another may have different proper courses.
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Case 15
In tacking to round a mark, a boat clear ahead must comply with rule 13; a boat clear astern is entitled to hold her course and thereby prevent the other from tacking.
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Case 17
A boat is no longer subject to rule 13 when she is on a close-hauled course, regardless of her movement through the water or the sheeting of her sails.
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Case 19
Interpretation of the term ‘damage’.
Case 20
When it is possible that a boat is in danger, another boat that gives help is entitled to redress, even if her help was not asked for or if it is later found that there was no danger.
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Case 21
When a right-of-way boat is obligated to give mark-room to a boat overlapped inside her, there is no maximum or minimum amount of space that she must give. The amount of space that she must give depends significantly on the existing conditions including wind and sea conditions, the speed of the inside boat, the sails she has set and her design characteristics.
Case 22
A written protest does not need to identify a rule that the protestor believes was broken. If it does identify such a rule, it is not relevant to the validity of the protest that the protest committee decides that a different rule had been broken.
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Case 23
On a run, rule 19 does not apply to a starboard-tack boat that passes between two port-tack boats ahead of her. Rule 10 requires both port-tack boats to keep clear of her.
Case 24
When a boat becomes overlapped to leeward from clear astern, the other boat must act promptly to keep clear. When she cannot do so in a seamanlike way, she has not been given room as required by rule 15.
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Case 25
After an inside overlapped windward boat has been given mark-room, rule 18 no longer applies, but rule 11 continues to apply. The inside windward boat must keep clear of the outside leeward boat, and the leeward boat may luff provided that she gives the windward boat room to keep clear.
Case 26
A right-of-way boat need not act to avoid a collision until it is clear that the other boat is not keeping clear. However, if the right-of-way boat could then have avoided the collision and the collision resulted in damage, she must be penalized for breaking rule 14.
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Case 27
A boat is not required to anticipate that another boat will break a rule. When a boat acquires right of way as a result of her own actions, the other boat is entitled to room to keep clear.
Case 28
When one boat breaks a rule and, as a result, causes another to touch a mark, the other boat is exonerated. The fact that a starting mark has moved, for whatever reason, does not relieve a boat of her obligation to start. A race committee may abandon under rule 32.1(c) only when the change in the mark’s position has directly affected the safety or fairness of the competition.
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Case 29
A leeward boat is an obstruction to an overlapped windward boat and a third boat clear astern. The boat clear astern may sail between the two overlapped boats and be entitled to room from the windward boat between her and the leeward boat, provided that the windward boat has been able to give that room from the time the overlap began.
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Case 30
A boat clear astern that is required to keep clear but collides with the boat clear ahead breaks the right-of-way rule that was applicable before the collision occurred. A boat that loses right of way by unintentionally changing tack is nevertheless required to keep clear.
Case 31
When the correct visual recall signal for individual recall is made but the required sound signal is not, and when a recalled boat in a position to hear a sound signal does not see the visual signal and does not return, she is entitled to redress. However, if she realizes she is on the course side of the line she must return and start correctly.
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Case 32
A competitor is entitled to look exclusively to the notice of race or to written sailing instructions for all details relating to sailing the course. If the race committee wants to change the direction in which boats are required to cross the finishing line to finish, this must be stated in the sailing instructions. When a boat fails to finish correctly because of a race committee error, but none of the boats racing gains or loses as a result, an appropriate and fair form of redress is to score all the boats in the order they crossed the finishing line.
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Case 33
When a boat approaching an obstruction hails ‘Room to tack’, but does so before the time when she needs to begin the process described in rule 20 to avoid the obstruction safely, she breaks rule 20.1(a). However, even if the hail breaks rule 20.1(a), the hailed boat must respond. An inside overlapped boat is entitled to room between the outside boat and an obstruction under rule 19.2(b) even though she has tacked into the inside overlapping position.
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Case 34
Hindering another boat may be a breach of rule 2 and the basis for granting redress and for action under rule 69.2.
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Case 35
When a boat hails ‘Room to tack’ at an obstruction and the hailed boat replies ‘You tack’, and the hailing boat is then able to tack and avoid the hailed boat in a seamanlike way, the hailed boat has complied with rule 20.2(c).
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Case 37
Each race of an event is a separate race. In a multi-class event, abandonment may be suitable for some classes, but not for all.
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Case 38
The International Regulations for Preventing Collisions at Sea (IRPCAS) are intended to ensure the safety of vessels at sea by precluding situations that might lead to collisions. When the IRPCAS right-of-way rules replace the rules of Part 2, they effectively prohibit a right-of-way boat from changing course towards the boat obligated to keep clear when she is close to that boat.
Case 39
A race committee is not required to protest a boat. The primary responsibility for enforcing the rules lies with the competitors.
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Case 40
Unless otherwise specifically stated in the class rules, notice of race or sailing instructions, the owner or other person in charge of a boat is free to decide who steers her in a race, provided that rule 46 is not broken.
Case 41
A discussion of how rule 19.2(b) and the definitions Obstruction, Continuing Obstruction, and Clear Astern and Clear Ahead; Overlap apply when two overlapped boats on the same tack overtake and pass to leeward of a boat ahead on the same tack. There is no obligation to hail for room at an obstruction, but it is prudent to do so.
Case 43
A close-hauled port-tack boat that is sailing parallel and close to an obstruction must keep clear of a boat that has completed her tack to starboard and is approaching on a collision course.
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Case 44
A boat is not permitted to protest a race committee for breaking a rule. However, if she tries to do so, her ‘protest’ may meet the requirements of a request for redress, in which case the protest committee shall treat it accordingly.
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Case 46
A leeward boat is entitled to luff to her proper course, even when she has established a leeward overlap from clear astern and within two of her hull lengths of the windward boat.
Case 47
A boat that deliberately hails ‘Starboard’ when she knows she is on port tack has not acted fairly, and has broken rule 2.
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Case 48
Part 5 of the racing rules aims to protect a boat from being unfairly treated, not to provide loopholes for protestees. A protestee has a duty to protect herself by acting reasonably before a hearing.
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Case 49
When two protests arise from the same incident, or from very closely connected incidents, they should be heard together in the presence of representatives of all the boats involved.
Case 50
When a protest committee finds that in a port-starboard incident S did not change course and that there was not a genuine and reasonable apprehension of collision on the part of S, it should dismiss her protest. When the committee finds that S did change course and that there was reasonable doubt that P could have crossed ahead of S if S had not changed course, then P should be disqualified.
Case 51
A protest committee must find that boats were exonerated at the time of the incident when, as a result of another boat’s breach of a rule, they were compelled to break a rule.
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Case 52
Rule 16.1 does not restrict the course of a keep-clear boat. Manoeuvering to drive another boat away from the starting line does not necessarily break this rule.
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Case 53
A boat clear ahead need not take any action to keep clear before being overlapped to leeward from clear astern.
Case 54
Interpretation of rule 20’s requirements for hails and signals and their timing.
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Case 57
When a current, properly authenticated certificate has been presented in good faith by an owner who has complied with the requirements of rule 78.1, the final results of a race or series must stand, even though the certificate is later withdrawn.
Case 58
If a buoy or other object specified in the sailing instructions as a finishing-line limit mark is on the post-finish side of the finishing line, a boat may leave it on either side.
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Case 59
When a boat comes abeam of a mark but is outside the zone, and when her change of course towards the mark results in a boat that is in the zone and that was previously clear astern becoming overlapped inside her, rule 18.2(a)(2) requires her to give mark- room to that boat, whether or not her distance from the mark was caused by giving mark-room to other boats overlapped inside her.
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Case 61
When the decision of a protest committee is changed or reversed upon appeal, the final standings and the awards must be adjusted accordingly.
Case 63
At a mark, when space is made available to a boat that is not entitled to it, she may, at her own risk, take advantage of the space.
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Case 65
When a boat knows that she has broken the Black Flag rule, she is obliged to retire promptly. When she does not do so and then deliberately hinders another boat in the race, she commits a breach of sportsmanship and of rule 2, and her helmsman commits an act of misconduct.
Case 67
When a boat is racing and meets a vessel that is not, both are bound by the government right-of-way rules. When, under those rules, the boat racing is required to keep clear but intentionally hits the other boat, her helmsman commits an act of misconduct.
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Case 68
The failure of a race committee to discover that a rating certificate is invalid does not entitle a boat to redress. A boat that may have broken a rule and that continues to race retains her rights under the racing rules, including her rights under the rules of Part 2 and her rights to protest and appeal, even if she is later disqualified.
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Case 69
Momentum of a boat after her preparatory signal that is the result of being propelled by her engine before the signal does not break rule 42.1.
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Case 73
When, by deliberate action, L’s crew reaches out and touches W, which action could have no other intention than to cause W to break rule 11, then L breaks rule 2.
Case 74
There is no rule that dictates how the helmsman or crew of a leeward boat must sit. Contact with a windward boat does not break rule 2 unless the helmsman’s or crew’s position is deliberately misused.
Case 75
When rule 18 applies, the rules of Sections A and B apply as well. When an inside overlapped right-of-way boat must gybe at a mark, she is entitled to sail her proper course until she gybes. A starboard-tack boat that changes course does not break rule 16.1 if she gives a port-tack boat adequate space to keep clear and the port-tack boat fails to take advantage of it promptly.
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Case 77
Contact with a mark by a boat’s equipment constitutes touching it. A boat obligated to keep clear does not break a rule when touched by a right-of-way boat’s equipment that moves unexpectedly out of normal position.
Case 78
In a fleet race either for one-design boats or for boats racing under a handicap or rating system, a boat may use tactics that clearly interfere with and hinder another boat’s progress in the race, provided that, if she is protested under rule 2 for doing so, the protest committee finds that there was a reasonable chance of her tactics benefiting her final ranking in the event. However, she breaks rule 2, and possibly rule 69.1(a), if while using those tactics she intentionally breaks a rule.
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