This article considers the less talked about outcome of the "OCEAN VICTORY" ([2017] UKSC 35) in the Supreme Court creating a new danger that, where a vessel is subject to a chain of charters, the wording of the charters may prevent a loss being passed down the charterparty chain, thereby, in effect, creating a bar to recourse action. The result is that underwriters, in particular, may wish to consider terms which preserve a recovery action in view of standard wording whose effect in the "OCEAN VICTORY" was to bar recovery for all insured matters.