Concerns a salvage dispute between two groups of salvors (one of which was led by Sippe).
SS Tubantia was an ocean liner that sank in 1916, along with a large amount of gold coins. In 1924, the wreck was located and recovery was initiated. Sippe had marked the wreck with bouys, obtained limited access, and sent in divers – but the divers could only stay down there briefly, and had not yet retrieved anything of real value.
What is required for a salvor to have sufficient possession of a sunken shipwreck?
Possession requires that a person have sufficient control over the object. Control does not necessarily mean "complete dominion." Rather, control is subject to the particular context and type of property:
** Physically demarcating the area under which a wreck is found, accessing the wreck and sending in an exploration team constitutes sufficient possession in the case of a sunken shipwreck
The court found sufficient possession – Sippe had sufficient control and use of the wreck to support his intention to exclude.
Decision in favour of Sippe