Time charterparties usually require the charterer to provide a series of notices prior to redelivering the ship, informing the owner of the time and place of the redelivery. Very often, this will take the form of a series of “approximate” notices giving a decreasing amount of notice, followed by a series of “definite” notices even closer to redelivery. This should enable the owner to arrange for the ship’s next fixture and minimise any unemployment.
But what happens if a charterer does not give some (or all) of the required notices, or does not redeliver the ship in line with the notices that are given? In such situations an owner may look to claim damages, and in this regard might be attracted to an argument based on a case called The Great Creation  1 Lloyd’s Rep. 315, which provides a seemingly straightforward way to calculate damages.
However, for the reasons set out below we would caution against relying too heavily on The Great Creation decision.