2015 
Carrier Liability 
205 
1960s." 53 Yet, in the following decades, the development was 
slow at best. 
The International Convention for the 
Unification of Certain Rules Relating to 
Carriage of Passengers by Sea and Protocol of 
29 April 1961 had few adherents among 
States, and its update never even entered into 
force. More successful was the subsequent 
Athens Convention relating to the Carriage of 
Passengers and the Luggage by Sea of 13 
December 1974 (abbreviated by the 
International Maritime Organization (IMO) as 
"PAL" that, with 32 signatories, entered into 
force on 28 April 1987 (and its protocol of 19 
November 1976 on 30 April 1989) .... But 
[even by] ratification amongst EU Member 
States was limited to just six States. 54 
[...] 
The protocol of 29 March 1990 to the 1974 
Athens Convention with just five contracting 
States never had sufficient support for 
entering into force as it did not, in the eyes of 
many States, provide for a sufficiently high 
level of compensation. The [European] 
Commission expressed its discontent with 
this liability regime in its Maritime Passenger 
Safety Communication of March 2002 whilst 
outlining the features of more adequate rules 
for maritime transport, both international and 
53 Id. at 205. 
54 Id. (footnotes omitted).