The law of maritime boundary delimitation has evolved from the early interpretations of Article 6 of the 1958 Convention, known as the equidistance-special circumstances rule, and the customary international law notion of equitable principles. The idea that delimitation requires a three-step approach of drawing a provisional equidistance line and then testing that line in the light of relevant circumstances and proportionality – the equidistance-relevant circumstances approach – has gained widespread acceptance by international courts and tribunals. The applicable law of maritime boundary delimitation today consists of a requirement to utilize a particular methodology and to engage in a particular process of assessment within that methodology. However, the application of that formula has not been consistent or always coherent. The tendency of courts and tribunals to merge the three stages by considering relevant circumstances in the first stage when drawing a provisional equidistance line and treating proportionality as if it were something different from a relevant circumstance, has led to confusion in the application of the principles of maritime delimitation. The result is that the law of maritime boundary delimitation while having the appearance of clarity in fact does not provide the certainty, objectivity and transparency claimed as its rationale