[445] See article of John Bassett Moore in Review of Reviews, May, 1899.

[446] The "Jonge Tobias," 1 C. Rob. 329.

[447] The "Staadt Embden," 1 C. Rob. 26; Takahashi, p. 94.

[448] Perels, "Manuel Droit Maritime," § 46, p. 283.

[449] p. 690, § 247.

[450] In some cases, belligerents exercise the so-called right of using or destroying belligerent property on the plea of necessity, giving compensation. This practice is called "angary" or "prestation," and is by most jurists either condemned or regarded with disfavor. An illustration is the sinking, during the Franco-Prussian War of 1870, by the Germans, of several British merchant ships in the Seine to prevent French gunboats from going up the river. During the same war, the Germans seized in Alsace, for military purposes, certain railway carriages of the Central Swiss Railway and certain Austrian rolling stock, all of which remained in the possession of the Germans for some time. See Lawrence, § 252; Hall, p. 765, § 278. See Appendix, p. [402].

[451] 6 C. Rob. 440, 454.

[452] U. S. Naval War Code, Art. 20; Appendix, p. [406].

[453] The "Orozembo," 6 C. Rob. 430.

[454] Wheat., D., p. 648.