"  The  King's  enemies  "  is  also  an  exception  at  common  law  {q) ;
and  its  effect,  when  expressed,  does  not  appear  to  be  any  wider ;
except,  perhaps,  iu  the  case  of  a  foreign  ship,  when  the  clause  wUl
be  read  to  include  the  sovereign  of  the  master  who  has  made  the
contract.
In  EusseU  ».  Niemann  (r)  the  ship  and  her  owners  belonged  to
Mecklenburg,  as  also  did  the  master  who  gave  the  bill  of  lading :
the  goods  were  shipped  in  Eussia,  and  were  to  be  carried  to  Eng-
land. The  Court  held  that  the  exception  "  King's  enemies  "  in-
cluded at  least  the  enemies  of  the  sovereign  of  the  person  who  made
the  stipulation  (s).
82.  "  Eestraints  of  princes,  rulers,  and  peoples "  covers  any
forcible  interference  with  the  voyage  or  adventure  at  the  hands  of
the  constituted  government,  or  ruling  power  of  any  country  (t),
whether  done  by  it  as  an  enemy  of  the  state  to  which  the  ship
belongs,  or  not.  Eor  example,  orders  of  government  prohibiting
or  restricting  the  exportation  or  landing  of  goods;  quarantine
regulations  (m)  ;    embargoes,   or  restrictions  on  particular  ships ;


(«)  Crooks  -0.  Allan,  5  Q.  B.  D.  38.
So  as  to  an  exception  of  "Jettison,"
The  Alliance,  64  Fed.  Eep.  871  (1894).
(o)  10  Q.  B.  D.  426  ;  12  ib.  218.
{p)  Supra,  a.  7.
{q)  Supra,  s.  11.
(r)  34  L.  J.,  C.  P.  10.
(s)  And  see  The  Teutonia,  L.  E,.,  4
P.  0.  171 ;  The  Heinrich,  L.  E.,  3  A.  &
E.  424.
{t)  Nesbitt  V.  Lushington,  4  T.  E.
