That  case,  therefore,  appears  to  show  that  the  action  of  rats  is
not  one  of  those  natural  causes  which  may  be  acts  of  God.  But
there  is  some  doubt  as  to  the  effect  of  the  decision.  In  Jones  on
Bailments  (r),  it  was  said  that  "the  true  reason  of  this  decision  is  not
mentioned  by  the  reporter ;  it  was,  in  fact,  at  least  ordinary  negli-
gence to  let  a  rat  do  such  mischief."  And  in  Abbott  on  Ship-
ping (-s),  the  case  was  treated  by  the  author  as  an  instance  of  the
principle  that  "the  master  and  owners  are  held  responsible  for
every  injury  that  might  have  been  prevented  by  human  foresight
or  care."

In  WiUiams  v.  Lloyd  (t),  it  was  held  that  a  bailee  of  a  horse
was  excused  from  re-delivering  it,  when  it  had  become  sick  and
died  without  any  neglect  on  his  part,  on  the  ground  that  this
happened  by  the  act  of  God.  Oases  of  this  kind  are  now  gene-
rally excepted,  as  we  shall  shortly  see,  on  the  ground  that  the
loss  is  by  a  defect  in  the  thing  itself.  But  such  a  case  may  fall
within  the  definition  of  "  act  of  God,"  if  the  defect  or  disease
which  has  caused  the  loss  has  been  in  no  way  caused  by  acts  of
man  (m).
(p)  See  The  Majestio,  166  U.  S.  376.  {t)  W.  Jones,  Eep.  179.
(g)  1  Wilfi.  281 :  A.r.  1760.  {»)  In  Warden  v.   Greer,   6  Watts,

(r)  Page  106:  publislied  a.d.  1781.  424,  a  loss  of  molasses  from  barrels  by

(s)  Dtii     p.    244 ;    (11th),    iv.    6,    4.  fermentation  and  expansion  was  said  to

Of.  Laveroni  v.  Driiry,  22  L.  J.,  Ex.  2.  be  a  loss  by  an  "  act  of  God."


12  THE  CONTRACT.
