ob. 167); but
innovations were made upon this rule during the American Civil War which
seem to be demanded by the conditions of modern commerce, and might well
be followed by a British prize Court. It was held that contraband goods,
although _bona fide_ on their way to a neutral port, might be condemned,
if intended afterwards to reach the enemy by another ship or even by
means of land carriage--_Bermuda_ (3 Wallace); _Peterhoff_ (5 Wallace).
A consignment to Lorenzo Marques, connected as is the town by only forty
miles of railway with the Transvaal frontier, would seem to be well
within the principles of the Civil War cases as to "continuous voyages."

2. The carriage by a neutral ship of enemy troops, or of even a few
military officers, as also of enemy despatches, is an "enemy service" of
so important a kind as to involve the confiscation of the vessel
concerned, a penalty which, under ordinary circumstances, is not imposed
upon carriage of "contraband" property so called. See Lord Stowell's
luminous judgments in _Orozembo_ (6 Rob. 430) and _Atalanta_ (_ib._
440). The alleged offence of the ship _Bundesrath_ would seem to be of
this description.

The questions, both of "contraband" and of "enemy service," with which
our prize Courts must before long have to deal, will be such as to
demand from the Judges a competent knowledge of the law of prize,
scrupulous fairness towards neutral claimants, and prompt penetration of
the Protean disguises which illicit trade so readily assumes in time of
war.

Your obedient servant,
T. E. HOLLAND.
Oxford, January 2 (1900).

THE _ALLANTON_ _(Continuous Voyage)_

Sir,--I venture to think that the letter which you print this morning
from my friend Dr. Baty, with reference to the steamship _Allanton_,
calls for a word of warning; unless, indeed, it is to be taken as merely
expressing the private opinion of the writer as to what would be a
desirable rule of law.

It would be disastrous if shipowners and insurers were to assume, that a
neutral vessel, if destined for a neutral port, is necessarily safe from
capture. Words at any rate capable of this construction may, no doubt,
be quoted from one of Lord Stowell's judgments, now more than a century
old; but many things have happened, notably the invention of railways,
since the days of that great Judge. The United States cases, decided in
the sixties (as Dr. Baty thinks, "on a demonstrably false analogy"), in
which certain ships