there anything to prevent her from enjoy ing the security of neutral waters for so long as may seem good to her."1 It has generally been assumed in current discussions (and Japan appears to have acted on this assumption) that it would be a breach of International Law for a neutral State to permit belligerent warships to remain in a neutral port longer than twenty-four hours, except in case of necessity, or to allow such vessels to take in supplies of coal oftener than once in three months, and then only in 'Hall, §231, p. 630. But Hall (p. 631) admits that "in the treatment of ships, as in all other matters in which the neutral holds his delicate scale between two belligerents, a tendency toward the enforcement of a harsher rule becomes more defined with each successive war." As everyone knows, the rule is entirely different with respect to belligerent troops which have been driven into neutral territory or which have sought refuge on neutral soil. Such troops are interned and kept there until paroled or until the close of the war. See Arts. 57 and 58 of the Regulations Respecting the Lau's and Customs of War on Land adopted by The Hague Conference, Holls, p 160. Dana (note 208 to Wheaton, p. 524) thus de fines the obligations of neutrals in respect to the use of its ports by belligerent cruisers: "It may be considered the settled practice of nations, in tending to be neutral, to prohibit belligerent cruisers from entering their ports, except from stress of weather or other necessity, or for the purpose of obtaining provisions and making re pairs requisite for seaworthiness. They must not increase their armament or crew, or add to their belligerent efficiency. It is now the custom to fix a short time for the stay of such vessels, after they have done what is permitted them, or the marine exigency has passed,—.usually twenty-four hours. These rules are. however, at the option of the neutral." Taylor (p. 690) lays down the following rules: "In addition to the observance of all quarantine rules, local revenue and harbor regulations, the belligerent ship must respect all prohibitions de signed to prevent the use of the neutral port for purposes other than those of immediate necessity. While the fighting force of such a ship may not be reinforced or recruited in such a port, nor supplies of arms and warlike stores or other equipments of direct use for war obtained, such supolies and equipments may be purchased as are necessary to sustain life or carry on navigation. If she is in need of repairs she may procure what ever is needful to put her in a seaworthy condi tion, including masts, spars and cordage. But she cannot make such structural changes as will in crease her efficiency as a fighting machine, either of offense or defense. She may take in such pro visions as she needs: and, if a steamer, she may purchase enough coal to enable her to reach the nearest port of her own country."
quantity sufficient to take them to the near est home port or to some nearer neutral destination. It is true that neutral States are under an international obligation to pre vent their ports from being used as a base of military operations or as a constant and regular base of supplies (whether of arms, coal or supplies), or for the purpose of aug menting the force of an armed vessel in the service of a belligerent or of increasing its military efficiency. It is also true that a considerable practice has grown up in re cent times in favor of the twenty-four hour rule and in favor of strictly limiting the sup ply of coal permitted to belligerent vessels in neutral ports. But the details and specific content of such means or measures for car rying out their international obligations has been left by International Law to neutral Governments. The rule limiting the stay of belligerent armed vessels in a neutral port to twenty-four hours, "except in the case of stress of weather, injuries or exhaustion of provisions necessary for the safety of the voyage, save that an interval oí twenty-tour hours must elapse between the sail ings of vessels of opponents," was first intro duced into international practice by France in 1861. See Walker, Scieitte, p. 455. Similar reg ulations were adopted by Great Britain, Spain. and Brazil. On January 31, 1862, the British Government published a series of neutrality reg ulations more stringent than any heretofore is sued. They provided that "war vessels of either belligerent should be required to depart within twenty-four hours of their entry, unless they needed more time for taking in innocent sup plies or effecting lawful repairs, in which case they were to obtain special permission to remain for a longer period, and were to put to sea within twenty-four hours after the reason for their re maining ceased. They might freely purchase provisions and other things necessary for the sub sistence of their crews: but the amount of coal they were allowed to receive was limited to as much as was necessary to take them to the near est port of their own country. Moreover, no two supplies of coals were to be obtained in British waters within three months of each other." Law rence, Principles, pp. 310-11. These restrictions upon the liberty of belliger ent ships in neutral ports were adopted by the United States in 1870, and they have been reimposed by Great Britain and the United States in successive wars. They have also been copied, either in whole or part, by other States, e.g., by Spain and Brazil. It is well known that the twenty-four-hour rule was enforced by Great Britain and Portugal during the Spanish-Ameri-
