Although the exception of loss or damage by act of God1 is implied at common law2, it is often inserted expressly, probably to prevent any inference being drawn from its omission that the parties did not intend to include it3. It denotes natural accidents, such as lightning, earthquake and tempest, not due to the act of man and unavoidable by even extreme care4. To exempt the shipowner, he must show that the accident was due to natural causes directly and exclusively, and not to human intervention5,
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