nciple requires that, in order to have the character of G.A. a sacrifice
or expenditure must be made for the common _safety_ of the several
interests in the adventure and under the pressure of a common risk. It is
not enough that the sacrifice or expenditure is prudent, or even necessary
to enable the common adventure to be completed. G.A., on the English view,
only arises where the _safety_ of the several interests is at stake. "The
idea of a common commercial adventure, as distinguished from the common
safety from the sea," is not recognized. It is not sufficient "that an
expenditure should have been made to benefit both cargo owner and
shipowner."[1]

[Sidenote: Port of refuge expenses.]

Thus expenses incurred after ship and cargo are in safety, say at a port of
refuge, are not generally, by English law, to be treated as G.A.; although
the putting into port may have been for safety, and therefore a G.A. act.
If the putting into port has been necessitated by a G.A. sacrifice, as by
cutting away the ship's masts, the case is different; the port expenses,
the expenses of repairing the G.A. damage, and the incidental expenses of
unloading, storing and reloading the cargo are, in such a case, treated as
consequences of the original sacrifice, and therefore subjects for
contribution. But where the reason for putting in is to avoid some danger,
such as a storm or hostile cruiser, or to effect repairs necessitated by
some _accidental_ damage to the ship, the G.A. sacrifice is considered to
be at an end when the port has been reached, if the ship and cargo are then
in physical safety. The subsequent expenditure in the port is said not to
flow from that sacrifice, but from the necessity of completing the voyage,
and is incurred in performance of the shipowner's obligation under his
contract. The practice of English average adjusters has indeed modified
this strict view by treating the expense of _unloading_ as G.A.; but it may
well be doubted whether that practice can be legally supported. Moreover,
expenditure in the port which is incurred in protecting the cargo as in
warehousing it, is by English practice treated as a charge to be borne by
the cargo for whose benefit it was incurred.

If we turn now to York-Antwerp Rule X., it will be seen that a much broader
view is adopted. Whatever the reason for putting into the port of refuge,
provided it was necessary for the common safety, the expenses of going in,
and the conseque