— Also termed danger of navigation; danger of river; marine peril; marine risk; (in regard to the Great Lakes) perils of the lakes; danger of the sea. [Cases: Insurance 2220; Shipping 120. C.J.S. Insurance § 998; Shipping §§ 276–277.]
“Of the marine perils, by far the most important are those ‘of the seas’. What is covered is not any loss that may happen on the sea, but fortuitous losses occurring through extraordinary action of the elements at sea, or any accident or mishap in navigation. By far the greatest number of claims for marine loss, and of the insurance problems connected with other topics treated in this book arise under this clause. Extraordinary action of the wind and waves is a sea peril. Collision, foundering, stranding, striking on rocks and icebergs, are all covered under these words. Even a swell from a passing ship may be a ‘peril of the sea’. On the other hand, ordinary wear and tear are not included under the coverage of this or any other phrase in the clause, nor are losses which are anticipatable as regular incidents of sea carriage in general or of navigation in a particular part of the world.” Grant Gilmore & Charles L. Black Jr., The Law of Admiralty § 2-9, at 72–73 (2d ed. 1975).
