^4ii  some  cases  where  a  blockading  squadron,  from  the  nature  of  the
channels  leading  to  a  port,  can  be  eluded  with  ease,  a  large  number  of

405


§  363.]  BLOCKADE.  [CHAP.  XVIII.
saccessful  evasions  may  be  insnfScient  to  destroy  the  legal  efficiency
of  the  blockade.  Thus,  daring  the  American  civil  war  the  blockade
of  Charleston  was  nsaally  maintained  by  several  ships,  of  which  one
lay  off  the  bar  between  the  two  principal  channels  of  entrance,  while
two  or  three  others  craised  oatside  within  signaling  distance.  This
amount  and  disposition  of  force  seems  to  have  been  thonght  by  the
British  Government  amply  sufficient  to  create  the  degree  of  risk  neces-
sary under  the  English  view  of  international  law,  although,  from  the
peculiar  nature  of  the  coast,  a  large  number  of  vessels  succeeded  in  get-
ting in  and  out  during  the  whole  continuance  of  the  blockade."

HaU,  Int.  Law,  618,  citing  Bernard,  Neat,  of  Great  Britain,  chaps,  x  and  xi.
"  If  approach  for  inquiry  were  permissible,  it  will  readily  be  seen
that  the  greatest  facilities  would  be  afforded  to  elude  the  blockade."

Field,  J. ;  The  Cheshire,  3  Wall.,  235 ;  S.  P.,  The  Spee,  5  C.  Rob.,  80 ;  The  Char-

lotte  Christine,  6  C.  Eob.,  lOl.
That  the  President  of  the  United  States  may  declare  a  blockade  wiihont  the

action  of  Congress,  see  The  Sarah  Starr,  Blatch.  Pr.  Ca.,  69;  The  Amj  War-

Tvick,  2  Spragne,  123;  8.  C,  2  Black.,  635.
(2)  Must  be  brought  to  prize  court.
§363.
The  subject  and  necessity  of  prize  courts  in  cases  of  belligerent  seizorea  of  nea-

trals  is  discussed  9vpra,  $$  329^.
