I’m Alone, PCIJ 1928

    The International Episode of ‘I’m Alone’


    This case of I’m alone is one of the most talked and discussed case laws in the area of International Law and it mainly deals with the concept of the international sea boundaries and the Doctrine of hot Pursuit. The concept of International Sea boundaries will be dealt along as the statement of facts will be discussed but to understand the case we need to know about the Doctrine of hot pursuit.

    The Doctrine of Hot Pursuit

    • This doctrine of hot pursuit acknowledges the right of a country to hunt a vessel, which belongs to a foreign country and has violated any rules and regulations within the territorial jurisdiction of the country in which the vessel is found.
    • This doctrine even gets rights to the country to hunt the so-called criminal vessel and take the person in charge into custody.
    • The rule of the maritime law states that all vessels have the right to move and navigate freely on the high seas. Even after that, the traditional idea has recognized this doctrine as an exception to the principles.
    • This doctrine came into force due to the sole reason of piracy and smuggling being rampant in many parts of the world, almost every sailor practiced this contraband, and the idea behind this doctrine was to curb this practice.
    • After coming of this doctrine, there was no easy escape from the punishment of bringing illegal objects to the areas of the foreign states.

    This is a case law of the year 1928 and after many years, there was codification of this doctrine in the year 1982 called as United Nations Convention on the Law of High Seas (UNCLHS).

    Statement of Facts

    •  The vessel I’m Alone was a well-known offender, which had been known to illegally contraband alcohol into the States.
    • On 20th March 1929 there was a Canadian registered vessel (Ship) named I’m Alone on the border of the United States border Coast by a vessel of their own named Walcott within 10 and a half miles of the Coast of the United States.
    • On repeated counts the Walcott gave warnings to, I’m Alone to halt for inspection.
    • On approaching the vessel by Walcott, I’m alone fled, even after making further announcements to halt I’m Alone did not stop and Walcott kept pursuing her.
    • Even after that when I’m alone did not obey, Walcott fired warning shots first across the bow and then to the sails, this pursuit continued for two more days.
    •  Then on 22nd March, there was another ship named Dexter, was deployed which came into the hunt after I’m alone to give additional firepower to Walcott because the barrels of the Gun had jammed in Walcott.
    •  Dexter made a couple of warning shots to make I’m Alone halt but the Commanding officer did not listen to the warning shots and continued to flee.
    • Finally, when I’m alone did not halt and there was no way of confirming that the ship would ever stop Dexter open fired into the ships riggings and hull making the ship to sink
    • One of the Crewmember of I’ m alone drowned before the Costal guard the rest crew members were taken under arrest and taken for trial in New Orleans.

    Contentions by the Supreme Court of Canada Chief Justice Lyman Poore Duff

    The Canadian Minster argues on the grounds that I’m Alone was at a distance of 14 and a half miles of the coast of the United States which was clearly outside the jurisdiction of the United States and they had no right to pursue that vessel as it was more than an hour away and more than 10 and a half miles as it was agreed upon by the countries.

    The Canadian minster also argued on the doctrine of hot pursuit stating that when Walcott was trying to hunt down I’m alone then Dexter came from a very different direction, which is not what the doctrine of hot pursuit approves of.

     The third contention made by the Minister of Canada was that the measures adopted for enforcing the rights which were offered by the Convention had to be reasonable, and that in the present case there were extreme measures that had been adopted which constituted unreasonable action by the United States.

    Contentions by the Supreme Court Justice Willis Van Devanter serving as arbiter for the U.S.

    The United States based its claim and stated that they had clear jurisdiction over the vessel, as I’m alone was not more than a distance of 10 and a half miles from the coast and to which distance, the countries had agreed upon in the convention and even after the chase was being made by Walcott and the commanding officer knew that he was well beyond the territorial jurisdiction of the U.S. Marines then they should have halted when warning shots were being fired upon them as they had nothing to run away from.

     As to the question of the doctrine of hot pursuit, the United States contended that the chase that began within the treaty limit was legal and if arrest is valid when the vessel is first hailed, pursuit is justified, and the distance of the pursuit are immaterial, provided that it is without the territorial waters of any other state and that the pursuit has been hot and continuous. The duration of the pursuit is unimportant.


    It was held that the U.S. might use reasonable and necessary force if required over apprehension of a vessel carrying contraband but the sinking of ship could not be justified, as there was nothing of that sort mentioned in the convention and even on the basic principles of international law, the sinking of the ship was unjustified.

    As to the matter of compensation the ship was owned and operated by the citizens of the United States of America so the question of the compensation on the destruction of the ship did not hold any water but it was ordered that along with a note of apology the U.S. government had to pay an amount of $25,000 to the government of Canada and an additional compensation to the crew members and the family of the deceased crew member was also recommended.