The Admiralty Court (part of the High Court in London) has held that two elements are necessary to constitute a salvage service by a tug under contract to tow:
(1) the tow must have been in danger due to circumstances which could not reasonably have been contemplated by the parties to the towage contract; and (2) risks were incurred or duties performed by the tug which could not reasonably be held to have been within the scope of the towage contract.
