Right of angary

The right of angary is a contested asserted belligerent power to requisition or use neutral private property under imperative military necessity, generally with compensation. Current military manuals and specialist references describe the doctrine, but its legal basis, territorial scope and application remain disputed.

Scope and distinctions

The property, owner and location matter. Neutral property in belligerent territory, property in occupied territory, enemy property and public property can fall under different rules. Private ships or other means of transport should not be treated as equivalent to every movable asset. Requisition also differs from seizure as prize, confiscation and destruction.

The Hague Conventions (1907) contain rules concerning requisitions and specified means of transport in land warfare. Those provisions do not by themselves codify every claimed maritime form of angary. Neutral rights and duties in maritime war (1856-1909) and Prize law and prize courts supply separate legal contexts.

Conditions and authority

Accounts commonly require imperative military necessity, temporary use or requisition, state authority and compensation. The source and legal character of each condition should be identified. Historical episodes from 1870 or 1918 illustrate state practice but do not prove a settled universal contemporary rule.

The Zamora (Privy Council, 1916) concerned judicial requisition of neutral goods in prize custody. It is not a general codification of angary and turned on its own procedure and evidence.

Assessment

Any modern claim should identify the armed conflict, property, nationality, location, authority, necessity, duration, compensation and review route. As at 30 July 2026, the doctrine remains better described as contested than as an unqualified current right.

Sources

1. United States Department of Defense, *Law of War Manual*, section 15.11, updated July 2023.
2. International Committee of the Red Cross, Customary IHL Rule 51 (accessed 30 July 2026).
3. International Committee of the Red Cross, Armed-conflict law dictionary.
4. International Committee of the Red Cross, Hague Convention IV treaty record (accessed 30 July 2026).