Usually, this is a scarcely noticed and immediately forgotten seagull or rook, flying across the field of view. This can be frozen by the camera, with a wing upraised. If this looks like a head and neck then the photo enters the evidence. If it looks like a seagull, then it doesn’t. Boats tend not to be remembered either. Foreign bodies within the camera can also cause marks on the film.
Speck on the film :
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