ustom of the particular trade.

Rule III. deals with damage done in extinguishing fire on board a ship.
Modern decisions have cleared away the old doubts whether such damage to
ship or cargo should, at law, be allowed in G.A. But recent cases in the
United States have raised the question whether the allowance should be made
where the fire occurs in port, and is extinguished, not by the master, but
by a public authority acting in the interests of the public. The Supreme
Court of the United States decided against the allowance in 1894 in a case
of _Ralli_ v. _Troup_ (157 U.S. 386). The ship had there been scuttled to
put out a fire on board, by the port authority, acting upon their own
judgment, but with the assent of the master. It was held that the damage
suffered by ship and cargo ought not to be made good by G.A. contributions;
for the sacrifice had not been made "by some one specially charged with the
control and safety of that adventure," but was the compulsory act of a
public authority. On the other hand, in the English case of _Papayanni_ v.
_Grampian S.S. Co._ (I. Com. Ca. 448), Mathew, J., held that the scuttling
of a ship at a port of refuge in Algeria, by orders of the captain of the
port, was a G.A. act. It had been done in the interest of ship and cargo,
and there was no evidence of any other motive.

Rule V. deals with the question whether, and under what conditions, a
voluntary stranding of the ship is a G.A. act, in a manner which will
probably be held to express the law in England when the matter comes up for
decision.

Rules VI. and VII. deal with the damage sustained by the ship, or her
appliances, in efforts to force her off the ground when she has stranded.
Such efforts involve an abnormal use which is likely to cause damage to
sails and spars, or to engines and boilers; and they are treated as acts of
sacrifice. The case of "The Bona," 1895 (P. 125) shows that the rules are
in accord with English law upon the point. The court of appeal held that
both the damage sustained by the engines while worked to get the ship off,
and the coal and stores consumed, were subjects for G.A. contribution at
common law.

[v.03 p.0057] Rule VIII. allows as G.A. any damage sustained by cargo when
discharged and, say, lightered for the purpose of getting the ship off a
strand. And the corresponding damage in the case of cargo discharged at a
port of refuge to enable repairs to be done to the ship is allowed by Rule
X