COLLISION.-1. Where a vessel having been run down, subsequently becomes unmanageable and gets upon a sand bank and is lost, the presumption of law is, that her eventual loss is attributable to the effects of the collision, and not to the mismanagement of the persons on board. The Mellona, 3 Adm. Rep. 7.

2. Look-out station. In a collision in the river Mersey, between a steam tug and a ferry boat: Held, by the Trinity Masters, that the proper station for the master or look-out man in such steamer is the bridge between the paddle-boxes. The Wirrall, 3 Adm. Rep. 56.

DAMAGE.-1. Collision.-The value of a vessel, condemned in a cause of damage by collision, is the existing value of the vessel at the time or immediately prior to the collision. Claim of the owners of a damaging vessel, to have their liability reduced to the value of their ship after the collision, overruled. The Mary Caroline, 3 Adm. Rep. 101.

2. Missing stays.-Defence of a vessel in a cause of damage, that from the proximity of the two vessels, and the fact of the damaging vessel missing stays, in consequence of a sudden squall of wind, the collision was inevitable, not sustained. Semble, if a vessel in close proximity to another vessel is put in stays and misses, it is the duty of the persons on board to square the mainyard and to let the vessel pay off. The Kingston-by-Sea, 3 Adm. Rep. 152.

3. Moiety of--The owners of a foreign vessel, which was run down by a British ship, brought an action for damages in the Admiralty Court, and a cross action was also entered against the foreigners by the British owners. The foreign owners being resident abroad and declining to give an appearance in the cross action, the cross action was discontinued, and the cause was heard upon the original action alone. The Trinity Masters being of opinion that both vessels were in fault, the court decreed the damage to be equally divided between them. This sentence was appealed and affirmed by the Privy Council and the cause was remitted. A motion was now made on behalf of the British owners, that the Registrar and merchants should be directed to ascertain the amount of the damage sustained by the British ship, and deduct a moiety of that damage from the compensation awarded to the foreign owners. The court rejected the motion, but withheld the payment of the sum claimed by the foreign owner, until he consented to a deduction of a moiety of the damage sustained by the British ship. The Seringapatam, 3 Adm. Rep. 38.

DEMURRAGE.- Collision.-Where a vessel is sunk in collision, and compensation is awarded by the Court of Admiralty to the full value of the vessel as for a total loss, the plaintiff will not be entitled to recover anything in the nature of a demurrage for loss of the employment of his vessel or his own earnings in consequence of the collision. The Columbus, 3 Adm. Rep. 158.

JURISDICTION OF ADMIRALTY COURT.-1. Receiver of droits.-Construction of the stat. 9 & 10 Vict. ss. 19 & 23. The Court of Admiralty has no jurisdiction to enforce a bond, given to the

receiver of droits, for the release of a vessel from his custody, under the provision of the 19th section. The Bagnall, 3 Adm. Rep. 112.

2. Special contract.—An agreement between the master of a vessel and a mariner to proceed on a voyage to the Danube, for the stipulated sum of £30: Held to be a special contract, over which the Court of Admiralty has no jurisdiction. The Debrescia, 3 Adm. Rep. 33.

LIGHT AT NIGHT.—Running down.-A vessel lying at anchor, in a track frequented by other ships, is bound at night to exhibit an efficient light. The owners of a vessel so lying at anchor, and run into by a vessel under sail: Held to have been in fault, in omitting to exhibit such light. The Victoria, 3 Adm. Rep. 49.

RUNNING DOWN.-Steamer.-The commander of a steamvessel of war condemned in a cause of damage. The excuse, that the vessel which was run down was mistaken for a fishing vessel at anchor, and that the helm was starboarded to avoid the fishing nets, not sustained. The steamer should have eased or reversed her engines, and have ascertained the fact, instead of proceeding on her course. Birkenhead, 3 Adm. Rep. 75.

The

SALVAGE.-1. Boats used for, without owner's presence.—The owners of boats rendering a salvage service, not having been personally present at the time the service is rendered, are not entitled to sue as salvors. Some remuneration, however, is due to them for the use of their boats, by way of equitable compensation. The Charlotte, 3 Adm. Rep. 68.

2. Costs. Claim for salvage pronounced for, but without costs, the nature of the claim being so trivial, that in the opinion of the court it ought not to have been brought into the Court of Admiralty. The Red Rover, 3 Adm. Rep. 150.

3. Deduction for want of skill.-Claim for salvage partially disallowed, upon the ground that the salvors in the performance of the salvage service had displayed great want of skill, and had brought the vessel into danger and difficulty thereby. Semble, the deduction in the amount of the salvage award is to be measured not by the amount of damage sustained, but in proportion to the quantum of negligence or ignorance displayed by the salvors. The Cape Packet, 3 Adm. Rep. 122.

SALVORS.-Towage-Costs.-Claim of the salvors overruled, upon the ground that their services under the circumstances of the case did not exceed a service of towage. The general rule with respect to costs, that they should follow the decision of the cause, modified and relaxed in respect to salvors. Claim of alleged salvors dismissed without costs. The Princess Alice, 3 Adm. Rep. 138.

SLAVE TRADE.-Bounty.-The principles of law which are applied to prize captures in time of war are applicable to questions of bounty for the capture of vessels engaged in the slave trade. The claim of one of H. M.'s slave cruizers to share in the bounties for the capture of a slave vessel overruled. The Felicidade, 3 Adm. Rep. 45.

TOWAGE.-1. Disobedience of master of tug.-Steam tugs employed in an ordinary service of towing merchant vessels are bound to be subservient to the orders of the pilot on board the vessel in tow. The master of the tug must implicitly obey the orders of such pilot, excepting in the case of wilful misconduct, or gross mismanagement on the part of the pilot. The master of a steam tug employed in towing a vessel from Gravesend to the Surrey Docks, having brought the vessel in tow into a collision by disobedience of the pilot's orders, Court pronounced against the owner's claim for towage remuneration. The Christina, 3 Adm. Rep. 27.

2. Contract. Where an agreement has been made with a steam tug belonging to a steam tug towing company, to tow a vessel from Dover to Gravesend for 40%., and the steam tug breaking down in the progress of the service, the towage was completed by other steam tugs, belonging to the same company, the defence of the owners of the vesseĺ in tow, that the contract was annulled by the non-fulfilment of the original agreement, not sustained. Semble, the acceptance of the services of the other steam tugs, by the master of the vessel in tow, a continuance of the original contract. The Lady Flora Hastings, 3 Adm. Rep. 118.

WAGES.-1.7&8 Vict. c. 112-Insolvency of owner-Construction of the statute 7 & 8 Vict. c. 112. The right of the master to sue for his wages in the Court of Admiralty is not taken away by the circumstance, that the owner, subsequent to the declaration of his insolvency, had compounded with his creditors and been released from his debts by the Lord Ordinary of Scotland. The Tecumseh, 3 Adm. Rep. 109.

2. Special contract-7 & 8 Vict. c. 110. In a suit for wages brought by the master under the stat. 7 & 8 Vict. an item of 61. per month for supplying cabin stores in the agreement for wages, directed to be struck out of the alleged agreement as being in the nature of a special contract. The Tecumseh, 3 Adm. Rep. 144.

3. Forfeiture.-Mere error of judgment on the part of the master in the management of the concerns of a vessel in a foreign port, unaccompanied by corrupt intention or wilful disobedience of orders, will not per se entail a forfeiture of his wages. Defence of the owners, that the wages were forfeited by reason of alleged losses sustained by them in consequence thereof, overruled. The Thomas Worthington, 3 Adm. Rep. 128.