In a recent landmark decision1 the Dutch Hoge Raad has given its interpretation of the concept of “danger” in Art. 1 of the Brussels Salvage Convention of 1910. In doing this the Hoge Raad has terminated a debate that had been going on for decades among Dutch legal writers, but which surprisingly had not yet been brought before the highest court of the Netherlands. The direction taken by the Hoge Raad will be welcomed by the salvage industry, although its enthusiasm may be tempered slightly by the rather low amount awarded in this case.

After leaving Flushing with a cargo of meat, the Frio Alaska was forced to return to the port the very next day due to engine trouble. With the help of a pilot the Frio Alaska