Some authors claim that the origins of a shipowner's right of limitation of liability can be traced to Roman Law. 1 To support their views they refer to the actio noxalis, the actio de peculio, and the cessio bonorum. However, from an analysis of these actions, it seems difficult to accept the idea that the origin of the shipowner's right to limit his liability is found in Roman Law. Indeed, it has been suggested that although notions of ‘limitation’ can be traced back to Roman times, there are no records of ‘limitation in maritime law’ from this period. 2