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.