Kiran Khosla
Principal Director

Kiran, an English qualified lawyer, is the Principal Director (Legal), of the International Chamber of Shipping (ICS) and Secretary of the ICS Maritime Law Committee and the ICS Insurance Committee. She is responsible for the ICS Legal team and advising member associations on legal, insurance and competition related matters affecting shipowners.

The ICS Legal team is currently focused, amongst other matters, on the need to protect the international legal framework for shipping as contained in the UN Convention on the Law of the Sea (UNCLOS, 1982), and in particular, preservation of the principle of Freedom of Navigation. Outside of UNCLOS issues, the ICS Legal team is participating in the work of the IMO Legal Committee, notably, on developing a liability regime for Alternative Fuels, and addressing the use of fraudulent ship registries and fraudulent registrations and related unlawful practices.

Defending Freedom of Navigation and the Fair Treatment of Seafarers:

ICS at the Forefront of Maritime Advocacy

The international shipping industry depends on a predictable legal framework that allows vessels to navigate international waterways safely, freely and without discrimination. Yet recent events have demonstrated how vulnerable that framework can be when geopolitical disputes spill into vital shipping lanes as has been seen in the Strait of Hormuz.

ICS has been very focussed therefore in defending the transit passage regime established under the United Nations Convention on the Law of the Sea (UNCLOS) following attempts by littoral state interests to impose charges for transiting these international waterways or otherwise imposing restrictions on which vessels are permitted to transit. Both charges for, and restrictions on transiting such international waterways are illegitimate under international law. Through advocacy at the International Maritime Organization (IMO), and the United Nations – most recently, the UN Security Council – ICS has highlighted these challenges to freedom of navigation and argued that international straits must remain freely open and accessible to all vessels engaged in lawful commerce and must not become instruments of political leverage.

This commitment was reflected in the international maritime industry’s support for the ““No Tolls, No Control” campaign”, which emerged as a significant reaffirmation of longstanding principles of the law of the sea. This campaign was given strong support in October when more than 60 states, led by the EU, publicly declared opposition to the imposition of unlawful transit fees, tolls and discriminatory restrictions on navigation through straits used for international navigation.

For ICS, the campaign is not simply about defending a legal doctrine. It is about preserving the integrity of the international rules-based system that enables the movement of over 90% of global trade., recognising that restrictions on navigation affect far more than shipowners. They have direct consequences for global energy markets, food security, supply chain resilience and inflation. ICS has therefore continued to emphasise that freedom of navigation is not merely a maritime concern but a prerequisite for global economic stability and international cooperation.

Alongside its work on navigational freedoms, ICS has continued to strengthen its advocacy for the fair treatment of seafarers, recognising the underlying humanitarian imperative and that the effectiveness of global trade ultimately depends on the welfare of the people who operate the world’s ships. ICS continues therefore to work towards the recognition and protection of seafarers as “keyworkers” and to campaign for them to be accorded due process and fair treatment when governmental authorities conduct investigations following, for example, a maritime casualty or allegation of wrongful activity such as drugs smuggling on board ships.

Collaboration has been central to this effort. ICS has worked closely with the IMO, the International Labour Organization (ILO) and the International Transport Workers’ Federation (ITF) to strengthen awareness of international standards and encourage their implementation.

In summary, as pressures on maritime routes and seafarers continue to grow, ICS remains at the forefront of efforts to ensure that the rule of law at sea is upheld, international commerce can continue to flow without interruption, and the men and women who sustain global trade are afforded the protection and respect they deserve.