In The Anna Dorothea, the Court found that where a charterparty provides that no deduction from hire may be made without owners' consent, non-payment of hire is a "deduction" if the vessel is allegedly off-hire at the instalment date, thereby precluding charterers from making unilateral deductions. Whilst the case is fact specific, this is a welcome analysis of how provisions limiting charterers' rights to withhold hire payments are interpreted by the courts.