{RQ 
A TREATISE ON THE LAW OF PRIZE. 
and the claim came before Mr. W. D. Hines as arbi 
trator under Article 300 of the Treaty of St. Germain- 
en-Laye. The arbitrator rejected Rumania’s claim on 
the ground that the vessels were engaged in inland 
and not in maritime navigation ; that they were regis- 
tered in or identified with the Danube ports and had 
not been taken on the high seas, but on a river, and 
that consequently the Rumanian Prize Courts had no 
jurisdiction to pass upon the validity of the capture.® 
The question as to the correctness or otherwise of 
this arbitration remains open. A review of the various 
decisions already examined shows that the majority 
of the Prize Courts assert jurisdiction on seizures 
effected in rivers and inland waters.® The matter in 
the case of the Danube was, however, further com- 
plicated by the fact that that part of the river which 
runs below the Iron Gates to its mouth in the Black 
Sea had been neutralised by Article 52 of the Berlin 
Convention, 1878, and consequently no acts of hostility 
could validly have taken place therein.* 
8 W. D. Hines, Determination in the matter of questions as 
to Danube shipping, 1921. 
9 Vide also Japanese Regulations of March 7, 1904, Art. 35; 
and of October 6, 1914, Art. 1; Chinese Regulations of October 30, 
1917, Art. 88; and Turkish Decree of January 81, 1912. 
1 Qee also post. p. 119, as to Russian captures in the Danftibe.