The Comment by Geoffrey Hudson “Substituted Expenses: Fact or Fantasy” in a previous issue of this Quarterly 1 had a particularly appropriate title, for we were treated to an equal measure of both fact and fantasy, seemingly designed to set up a smoke screen and again to cloud the issues so lucidly exposed by Hobhouse, J., in his recent judgment in the case of The Bijela.2 The author suggested3 that: “Not since the case of The Makis 4 has a judgment been handed down from the Commercial Court which has been so disturbing to the shipping and insurance communities,” as though the decision were some great surprise. In fact, it had been tentatively forecast as long ago as 1955 by a youthful J. F. Donaldson (later Lord Donaldson, M.R.) in the 8th edition of Lowndes & Rudolfs General Average and the York-Antwerp Rules,5 repeated in the 9th6 and 10th7 editions, and re-written rather more strongly in the current, 11th, edition.8 The case was re-heard by the