The Court of Appeal in MV Tai Harmony v Sure Success Steamship SA upheld an order allowing a shipowner to increase security provided for the release of an associated ship arrested in support of foreign arbitration proceedings. It held that the shipowner had established a prima facie maritime claim and a genuine need for additional security, while questions concerning the validity of the underlying arrest had to be determined in separate set-aside proceedings.

The decision confirms the distinct nature of South African security arrests, emphasising that they serve to prevent the frustration of claims and may justify security exceeding the value of the arrested vessel. It also clarifies the evidential burden for topping-up applications and the jurisdictional consequences of providing alternative security.