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See also Negligence (Act of God). The Supreme Court of Kansas defined 'act of God' as an: irresistible superhuman cause such as no ordinary or reasonable human foresight, prudence, diligence, and care could have anticipated and prevented. Garrett v Beers, 97 Kan. 255, 155 P. 2 (1916). See also, Rundall, ' 'Act of God' as a Defense in Negligence Cases,' 25 Drake L.Rev. 754 (1976); Prosser on Torts, § 51 at 324 (3d ed. 1964); and 'Act of God' is an 'unforeseeable force of nature'; Manila School District No. 15 v. Sanders, 226 Ark. 270, 289 S.W.2d 529, 531-32 (1956). In order for an 'Act of God' to preclude liability in negligence, two elements must be present: the occurrence alleged to be an 'Act of God' must be such that it was incapable of being avoided by reasonable care or foreseen by reasonable prudence; and the resultant injury must have come about without the intervention of any human agency. See Rundall, supra, Note 61 at 754; Note, 37 Notre Dame Lawyer 734, 736 (1962). See also, Parrish v. Parrish, 21 Ga.App. 275, 94 S.E. 315, 316 (1917). 

This denotes those accidents which arise from ...

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