An essential part of any account of private law must be the relation between property and obligation. Sometimes property is thought of as inherently separate from obligations. Thus a distinction is often made between ownership and obligation, or between being an owner and being a creditor, which corresponds to some degree with the distinction between rights ‘in rem’ (against a thing) and rights ‘in personam’ (against a person). These latter expressions, however, lack consistent meaning in Anglo-American law, and often both have been applicable simultaneously. Equity, for example, always acts ‘in personam’, but equitable rights and interests, because they bind third parties, are frequently described as proprietary and therefore may be, and often are, called rights ‘in rem’. An obligation owed to persons generally is called by some writers an obligation ‘in rem’, but an action for personal injury or for defamation is an action against a person. Maritime law permits an action to be brought against a thing itself (a ship, or goods found at sea), with no person named as defendant, the decision of the admiralty court binding every potential claimant. This is, in a strict sense, an action ‘in rem’, but outside admiralty such a process is very rare: property claims are almost always vindicated by actions against persons. This fact has led some writers to subordinate property to obligations by suggesting that property is a ‘bundle of rights’ and so a shorthand term for describing obligations of many persons.