FIRST MEETINGS. ATHERTON, WILLIAM, Birmingham, Joiner March 29 at 11 BAILEY, ARTHUR CRAWSHAY, Victoria st, Company Pro- March 28 BURTON, ERNEST HERBERT, and STUART KINGSLEY CORKE, DAVIES, WILLIAM, Tonypandy, Glam, Ironmonger March st FOORD, HENRY, Wormshill, Wychling, Kent, Farmer GREIG, ALBERT, West Hartlepool, Plumber March 28 at Apr HALEY, FREDERICK, Össett, Yorks, Labourer March 25 at MORGAN, EDWARD, Charlton Kings, nr Cheltenham, Inn- NORSWORTHY, CYRIL PROCTOR, Barnhurst, Kent March 25 RANKIN, ROBERT ELMAN, Battersea March 25 at 11.30 facturer March 28 at 11.15 115, High st, Rochester Bankruptcy bldgs, Carey st March 31 at 12 SANDERSON, JOHN WILLIAM, Milnsbridge, nr Huddersfield, SELLERS, GEORGE, Higham, nr Burnley March 25 at 1.30 SHANKLAND, WILLIAM, Oxted, Surrey March 25 at 11.30 SIMMONDS, GEORGE, Cardiff, Baker March 28 at 11 Off STOW, JOSEPH WILLIAM, Bradford, Leather Merchant SYKES, ELI, East Barnsley, Yorks, Painter March 25 at TRUMAN, WILLIAM HENRY, Lincoln, Cabinet Maker March UTTLEY, FRED, and FRANK AINLEY, Sowerby Bridge, VEALE, GEORGE, Stoke Newington, Builder March 30 at sage, Wellclose sq, Cigar Merchants March 25 at 2 30 WHIPP, JOSEPH, jun, Altrincham, Painter March 25 at 3 WOODCOCK, CHARLES HENRY, Sheffield, Grocer Sheffield London Gazette.-TUESDAY, Mar. 22. RECEIVING ORDERS. AIN SWORTH, ROBERT, Moss Side, nr Manchester, Calico CARTER, LORANCE WILLIAM, Old Broad st High Court DICKINSON, HENRY GEORGE, and JAMES WILLIAM DICKIN- DODWELL, CHRISTOPHER, Gt Yarmouth, Baker Gt Yar- DORE, WILLIAM BRASHER, Oxford, Tailor Oxford Pet GRAY, WILLIAM HARRISON, Tewkesbury, Surveyor Chel- HART, SIEBERT COLBURN, and CHARLES EDWARD FOWLER, HENOCHSBERG, JOSEPH, Broad st House, Mining Agent Ord HEPWORTH, JOHN, Startforth, nr Barnard Castle, Yorks, HOVELL, ARTHUR, Lakenham, Norwich, Wicker Chair Maker Norwich Pet March 19 Ord March 19 JUNIPER, BENJAMIN, Leeds, Insurance Agent Leeds Pet KERSEY, FRANK CHARLES, Lowestoft, Baker Great Yar- LITTLE, JOHN WILSON, Norfolk, Blacksmith King's Lynn LYDEARD, MAURICE ALBERT, Llandrindod Wells, Radnor, Bristol Pet March 18 Ord March 18 March 18 Ord March 18 Swansea Pet OAKLEY, JOHN, Deptford, Wheelwright Greenwich Pet OATES, JOHN HENRY, Sheffield, Confectioner Sheffield ORME-WEBB, ROBERT ORME, Dartmouth Plymouth Pet PALMER, STEPHEN WALTER, Brookland, Kent, Corn Factor PEARS, JONATHAN BOWRON, Sunderland, Ropemaker Sun- RICHMOND, WILLIAM HENRY, Nottingham, General Dealer ROBERTS, WILLIAM, Leeds Leeds Pet March 18 Ord SAWDAY, HENRY, South Kensington, Hotel Proprietor Pet March 18 Ord March 18 SPOUSE, HENRIETTA, Margate, China Dealer Canterbury THOMPSON, JAMES, Bolton, Fruiterer 17 Ord March 17 Bolton Bedford Pet LESLIE, WALTER ANTHONY, Brighton PARKER, WILLIAM, Blackpool Preston Pet Feb 26 Ord PARKINS. JOHN ASHLEY, Lower Broughton, Salford, Wandsworth Pet POCOCK, ALBERT. Pontypool, Furniture Dealer Newpo., ROWE, JAMES GEORGE WILLIAM, Croydon High Court SMEDLEY, NATHAN MARSDEN, Sale, Chester, Builder Man- UTTLEY, FRED, and FRANK AINLEY, Sowerby Bridge, WALKER, DAVID, Padiham, Lancs, Joiner Burnley Pet WALSH, ANDREW, Lytham, Lancs, Commission Agent Sheffield Pet WHITE, ELIZA, Newport, IW, Baker Newport Pet March WHITEHEAD, ARTHUR, Manchester, Cloth Raiser Salford WHITELEY, JAMES, Dewsbury, Shoddy Merchant Dews- TOWLEB, WILLIAM ABEL, Forest Gate High Court TRUE, CHARLES L, Pimlico High Court Pet Jan 28 Ord VICKERMAN, JOHN, Allerton, nr Bradford, Yarn Merchant WEBB, JOHN ABRAHAM, Coventry, Tinplate worker Pet March 18 Ord March 18 BirBolton WILSON, JOHN, South Bank, York, Accountant Stockton WRIGHT, WILLIAM, Hulme, Manchester Manchester Pet CATTE, GEORGE, Stockton on Tees, Corfectioner March 30 DAVIES, MARTIN, Llawhaden, Pembrokes, Farmer March Off Rec, 31, Manor row, Bradford March April 1 HELPS, WALTER, Bedminster, Bristol, Bootmaker 30 at 12 Off Rec, Baldwin st, Bristol HENNESSEY, ISABELLA MARY, Preston, Plumber at 3 Off Rec, 14, Chapel st, Preston HENOCHSBERG, JOSEPH, Broad st House, Mining Agent March 30 at 12 Bankruptcy bldgs, Carey st HIATT, RACHEL, Cradley Heath, Staffs, Grocer March 29 at 11 Off Rec, Wolverhampton st, Dudley HIGGINS, CHARLES GEORGE, Nottingham, Musician March 29 at 12 Off Rec, 4, Castle place, Park st, Notting ham JONES, ARTHUR JAMES, Worcester, Pawnbroker April 6 at 25 County Court, West Bromwich JUNIPER, BENJAMIN, Leeds, Insurance Agent March 21 at 12.30 Off Rec, 22, Park row, Leeds LESLIE, WALTER ANTHONY, Brighton, Tobacconist March 29 at 12 Off Rec, 4, Pavilion bldgs, Brighton LINDE, WILLIAM, Bournemouth, Musical Instrument Seller March 29 at 12.30 Off Rec, Endless st, Salisbury LOWSON, PETER, Barrow on Humber, Auctioneer March 20 at 11 Off Rec, Trinity House In, Hull MCKEAN, GORDON DALZIEL, Leadenhall st March 29 at 12 Bankruptcy bldgs, Carey st MARSHALL, JOHN PUGH, Bristol, Confectioner March 30 at 1 Off Rec, Baldwin st, Bristol MORGAN, BH, North Kensington March 29 at 11 Bankruptcy bldgs, Carey st NEWBORN, RICHARD ROBINSON, Hibaldstow, Lincs, Miller PALMER, STEPHEN WALTER, Brookland, Kent, Corn Factor tist's Assistant March 30 at 2.30 Off Rec, Byrom st, RYCROFT, JAMES, Great Grimsby, Artificial Tooth Manufacturer March 29 at 11 Off Rec, 15, Osborne st, Great Grimsby SATLE, GEORGE WILLIAM, Wadhurst, Sussex, Grocer March 31 at 11.30 21, Railway app, London bridge STODDART, WILLIAM, Blackpool, Printer April 1 at 2.30 Off Rec, 14, Chapel st, Preston TAYLOR, GEORGE WILLIAM, St George, Bristol, Baker March 30 at 12.30 Off Rec, Baldwin st, Bristol THACKRAY, SAM KERSHAW, Middlesborough, Watchmaker April 13 at 3 Off Rec, 8, Albert rd, Middlesborough THOMPSON, JAMES, Bolton, Fruiterer March 31 at 11 16, Wood st, Bolton WALL, WILLIAM, Birmingham, Cab Proprietor March 31 at 11 174, Corporation st, Birmingham WALTERS, BENJAMIN THOMAS, Carmarthen, Draper March 29 at 11 Off Rec, 4, Queen st, Carmarthen WHITEHEAD, ARTHUR, Cornbrook, Manchester, Cloth Raiser March 30 at 3 Off Rec, Byrom st, Manchester WHITEHURST, JAMES, Longton, Staffs, Grocer March 31 at 10 30 Off Rec, King st, Newcastle on Lyme WIGGINS, JOHN, Farnworth, nr Bolton, Plasterer April 1 at 11 16, Wood st, Bolton WILSON, JAMES, Leeds, Canvassing Bookseller Much 30 at 3 Bankruptcy bldgs, Carey st ADJUDICATIONS. AINSWORTH, ROBERT, Manchester, Calico Printer Salford BOURKE, ISIDORE MCWILLIAM, Nevern sq, Earl's Court, CORNEY, WILLIAM, Ledbury rd, Notting Hill, Cab Proprie- DODWELL, CHRISTOPHER, Gt Yarmouth, Baker Gt Yar- High GIBB, WILLIAM COWNIE, Wimbledon, Decorator HAWKINS, FRED, Finsbury pvmat, Solicitor High Court HENLEY, STEPHEN, Anerley, Corn Dealer's Assistant Ord HOVELL, ARTHUR, Lakenham, Norwich, Wicker Chair JUNIPER, BENJAMIN, Leeds, Insurance Agent March 16 Ord March 16 Leeds Pet KEYS, WILLIAM ARTHUR DAVID, West Kensington, Jeweller High Court Pet Oct 21 Ord March 17 LESIEUR, GUSTAVE ALFRED, Maida Vale mansions, Egg Merchant High Court Pet March 15 Ord March 16 LITTLE, JOHN WILSON, Terrington St Clements, Norfolk, Blacksmith King's Lynn Pet March 17 Ord March 17 MARSHALL, JOHN PUGU, Bristol, Confectioner Pet March 18 Ord March 19 NORMAN, GEORGE, Swansea, Wareman March 18 Ord March 18 Swansea Bristol Pet OAKLEY, JOHN, Deptford, Kent, Wheelwright Greenwich Pet March 18 Ord March 18 PEARS, JONATHAN BOWRON, Sunderland, Ropemaker Sunderland Pet March 16 Ord March 16 RICHMOND, WILLIAM HENRY, Nottingham, Fining Manufacturer Nottingham Pet March 16 Ord March 16 ROBERTS, WILLIAM, Leeds Leeds Pet March 18 Ord March 18 SYDDALL, SAMUEL, Little Lever, Lancs, Collier Bolton Pet March 19 Ord March 19 THOMPSON, JAMES, Bolton, Fruiterer Bolton Pet March KNIGHT, FRANK, & RUTLEY, VICKERMAN, JOHN, Bradford, Yarn Merchant Bradford THE CONDUIT ST. AUCTION GALLERIES, MORTIMER, EDITH, Weston super Mare, Leather Merchant FURNITURE, JEWELS, PLATE, PICTURES, Bristol Adjud Sept 23, 1897 Annul March 18, 1898 SIMMONDS, ARTHUR WALTER, Brighton, Tobacconist Brighton Adjud May 16, 1895 Annul March 11, 1898 All letters intended for publication in the "Solicitors' Journal" must be authenticated by the name of the writer. A COMMON-SENSE DIET. You will hear sufferers exclaim, "I feel out of sor's!" "I am below par!" "I am losing weight!" Some rush to quack nostrums and become worse. Some are unwilling -or unable to consult medical advisers, who would probably recommend things which might or might not help them. And, after all, a little common-sense must tell them that by following rational dietary rules they can maintain and restore that vigour which, by errors in diet, in conjunction with their surroundings, they have lost. Good health-the greatest blessing mortals can enjoy, and never really value till lost-can be preserved in the majority of mankind by attention to diet. A Food Beverage such as Dr. Tibbles' Vi-Cocoa, with its unique powers of nutriment and exceptional vitalizing properties, is a means whereby strength and nervous energy is gained as a rational outcome of increase vitality and the pleasing consequence of greater nourishment and sustenant force. It aids the digestive powers, and is invaluable to tired men and delicate women and children. It has the refreshing properties of fine tea, the nourishment of the best cocoas, and a tonic and recuperative possessed by neither, and can be used in all cases where tea and coffee are prohibited. It is not a medicine, but a unique and wonderful Food Beverage. The wonderful African Kola nut which it contains has concentrated powers of nutriment, and imparts stamina and staying powers, adds to power of endurance, and enables those who use it to undergo greater physical exertion and fatigue. The unique vitalizing and restorative powers of Dr. Tibbles' Vi-Cocoa are being recognised to an extent hitherto unknown in the history of any preparation. Merit, and merit alone, is what is claimed for Dr. Tibbles' Vi-Cocoa, and the proprietors are prepared to send to any reader who names the SOLICITORS' JOURNAL (a postcard will do) a dainty sample tin of Dr. Tibbles' Vi-Cocoa free and post-paid. Dr. Tibbles' Vi-Cocoa can be obtained from all chemists, grocers, and stores, or from Dr. Tibbles' Vi-Cocoa, Limited, 60, 61, and 62, Bunhill-row, London, E.C. THIS EVENING, at 8.45, THE DOVECOT: Messrs. Seymour Hicks, Chas. Sugden, George Raiemond, William Wyes, Lawrence Caird, Chas. V. France, and James Welch; Mesdames Ellis Jeffreys, S. Carlisle, L. Braham, K. Kearney, S. Grey, and Carlotta Addison. At 8.0, THE LADY WRANGLER. DRURY LANE THEATRE ROYAL. Managing Director, Arthur Collins. THIS EVENING, at 8.0, THE BABES IN THE WOOD: Messrs. Dan Leno, John A. Warden, Griffin and Dubois, C. Angelo, Whimsical Walker, and Herbert Campbell: Mesdames Ada Blanche, Violet Robinson, Alice Barnett, Kate Graves, and The Grigolatis. GARRICK. THIS EVENING, at 9.0, A BRACE OF PARTRIDGES. At 8.15, THE MUFF OF THE REGIMENT: Messrs. H. Reeves-Smith, W. Everard, S. Paxton, G. Tomkins, G. Shelton, C. Thornbury, Tovey, C. M. Lowne, E. Lovat Fraser, F. Everill; Mesdames Ada Branson, Beatrice Ferrar, M. Allestree, Nordblom, and Henrietta Watson, LYRIC. Lessee, Mr. William Greet. Mr. Arthur Roberts' Season. THIS EVENING, at 8.15, DANDY DAN, The Life Guardsman; Mr. Arthur Roberts, Messrs. W. H. Denny, Blake Adams, Frank Barclay, Arnold Lucy; Misses Isa Bowman, Jane Grey, Kate Erskine, and Phyllis Broughton. LYCEUM. THIS EVENING, at 8.0, THE MERCHANT OF VENICE: Henry Irving, Miss Ellen Terry; Messrs. F. Cooper, Macklin, Webster, N. Forbes, W. Farren, jun., Tyars, Mellish, Cooper Cliffe, Archer, Lacy, Belmore, Reynolds, Tabb, Howard, Marion, Graham; Miss Maud Milton, Miss Rockman. R. D'Oyly Carte, Manager. THIS EVENING, at 8.30, THE GONDOLIERS: Messrs. Walter Passmore, H. A. Lytton, William Elton, Jones Hewson, Cory James, L. Russell, and Charles Kenningham; Mesdames Emmie Owen, Louie Henri, Ruth Vincent, Jessie Pounds, and Rosina Brandram. At 7.45, OLD SARAH. VAUDEVILLE. THIS EVENING, at 8.20, THE FRENCH MAID: Messrs. Richard Green, George Mudie, Wyndham Guise, Murray King, H. O. Clarey, Barton de Solla, Percy Percival, J. W. Macdonald, Metcalfe; Mesdames Louie Pounds, Alice Barth, Lillie Pounds, Hilda Jeffreys, and Kate Cutler. DIAMONDS, PEARLS, COLD JEWELLERY, Spink AND FROM 1&2 GRACECHURCH ST LONDON. PLATE MEDALS EST: 1772 &c. VALUED PURCHASED OR EXCHANGED $5 ΤΟ $10,000. SPINK & SON beg respectfully to announce that they ACCURATELY APPRAISE JEWELS and SILVER PLATE, &c., for the LEGAL PROFESSION or PURCHASE the SAME for cash if desired. Established 1772. Tinder the patronage of H.M. The Queen and H.S.H. Prince Louis Battenberg, K.C.B. INCORPORATED LAW LEGAL EDUCATION. THE COUNCIL invite attention to the following scheme of education, adopted in 1892 with the object of affording assistance to Articled Clerks. For the benefit of Clerks resident in London or who are able to attend, these classes are held and Tutors give advice and assistance at the Hall of the Law Society. To those Clerks who are articled at a distance from large towns systematic instruction with advice and help is given, and a course of preparation through the post has been formulated. POSTAL INSTRUCTION. In the case of students who have not passed the Intermediate Examination the instruction is by means of monthly papers, and deals with the selected portions of Stephen's Commentaries. For those who have passed the Intermediate Examination instruction is afforded by fortnightly papers, and embraces the following subjects: Equity, Conveyancing, Common Law, Bankruptcy, Criminal and Magisterial Law, Probate, Divorce, Admiralty, and Ecclesiastical Law. These papers both before and after the Intermediate Examinations are varied each year, so that students who may subscribe for more than one year's tuition receive additional assistance. These courses may be commenced at any time, but the Tutors recommend that the Intermediate course should be commenced at an early stage of the Articles, and the Final course soon after the Intermediate Examination has been passed. Books can be obtained from Messrs. Stevens & Sons, or other law lending library, for a subscription of a guinea and a-half to cover the course of work for the Final Examination, and Stephen's Commentaries can be supplied to either Class of Postal Subscribers, at a subscription of one guinea, on application to the Tutor, Dr. West. CLASS INSTRUCTION. Class instruction is also provided on the selected portions of Stephen's Commentaries and the subjects above named, and it is recommended that the classes should be joined after the expiration of a course of Postal instruction. Students can join the classes at any time, the fees being proportionate to the length of attendance. Rooms are provided where subscribers may study, and books are supplied without extra charge. Periodical test examinations are held by the Tutors. The Classes for Intermediate Students are held in the Hall of the Society on three afternoons in each week during the following periods: August to November; October to January; January to April; March to June. Students may subscribe for successive classes. SOCIETY. Classes for Final Students are held at the Hall of the Society on four afternoons each week during the following periods: August to January; January to June. These periods afford five months' class preparation, and students are advised to subscribe for a full course, and certainly for not less than three months, otherwise the work must necessarily be hurried. Students may join the classes either before or after the Intermediate Examination without subscribing to the course of Postal instruction, but it is recommended that they should avail themselves of both modes of instruction. Subscribers to either Postal or Class instruction have the opportunity of consulting the Tutors upon the work of the course in personal interview or by letter at any time. RESULTS AND HONOURS. The results obtained have been satisfactory. At each of the last twelve examinations pupils have obtained honours, and the percentage of passes is a high one, exceeding 85 per cent. of between two and three hundred pupils who last presented themselves for examination. It has happened on several occasions that all Class pupils have been successful, and the same has occurred in the case of subscribers to the Correspondence Courses. TUTORS. Equity, Conveyancing, Common Law, Bankruptcy—J. CARTER HARRISON, 30, Bedford-row, W.C. Criminal and Magisterial Law, Probate, Divorce, Admiralty, and Ecclesiastical Law, Stephen's Commentaries-LEONARD H. WEST, LL.D., 19, Southampton-buildings, Chancery-lane, W.C. After Inter. Examination. £4 4 0 | (12 months) £6 60 660 (2 years) 880 440 (5 months) 990 ... 330 770 (4 months) 770 880 For those who have previously subscribed for Postal instruction For three months' Class instruction For those who have previously subscribed for Postal instruction 550 Cheques and Post Office Orders should be made payable to the SECRETARY, and crossed "Messrs. BARCLAY & Co., LIMITED." Law Society's Hall, Chancery-lane. THE REVERSIONARY INTEREST SOCIETY, LIMITED (ESTABLISHED 1823), Paid-up Share and Debenture Capital, £616.525. TREATMENT of INEBRIETY and ABUSE of DRUGS. MAKERS. HIGH SHOT HOUSE, To Her Majesty, the Lord Chancellor, the Whole of the ROBES FOR QUEEN'S COUNSEL AND BARRISTERS. Law Wigs and Gowns for Registrars, Town ST. MARGARET'S, TWICKENHAM, For Gentlemen under the Acts and privately. Terms, 2 to 4 Guineas. Apply to Medical Superintendent, F. BROMHEAD, B.A., M.B. (Camb.), M.R.C.S. (Eng.) INEBRIETY. MELBOURNE HOUSE, LEICESTER. PRIVATE HOME FOR LADIES. Medical Attendant: CHAS. J. BOND, F.R.C.S. Eng., L.R.C.P. Lond. Principal: H. M. RILEY, Assoc. Soc. Study of Inebriety. Thirty years' Experience. Excellent Legal and Medical References. For terms and particulars apply Miss RILEY, or the Principal. BRAND & & CO.'S TWO per CENT. on CURRENT ACCOUNTS, on the BOOKS, PAMPHLETS, MAGAZINES, ESSENCE OF BEEF, SYSTEM PERFECTED OP LIFE ASSURANCE. AND SECURE. £3,000,000. INCOME Cases Reported this Week. In the Solicitors' Journal. ........................ In the Weekly Reporter. Baxter v. Middleton (In re Middleton 386 387 350 339 337 Cole, In re. Ex parte Attenborough 352 340 Gilbert, In re. Ex parte Gilbert......... 351 344 Maynards (Limited), In re... 346 Palmer, In re. Ex parte Brims 342 Rogers (Appellant) v. Manchester 380 Packing Co. (Respondents) 350 348 CURRENT TOPICS. IT IS UNDERSTOOD that the draft rules under the Land Transfer issued very shortly. Act, 1897, are now completed, and they may be expected to be HER MAJESTY's judges having recommended that, for the future, the Summer Assizes for Wales shall begin on the 7th of July instead of the 29th of May, the Lord Chancellor proposes to advise the issue of an Order in Council to give effect to that recommendation before the next circuit. That MR. JUSTICE STIRLING has come to the rescue of the profession from a portion of the difficulty occasioned by the decision in Re Tibbits' Settled Estates (1897, 2 Ch. 149). decision laid it down that jointures and portions charged under powers contained in a settlement constitute, together with the original settlement, a compound settlement; hence a purchaser from the tenant for life cannot safely pay his purchase-money to the trustees for the purposes of the Settled Land Acts of the original settlement, and trustees for the purposes of the Acts of the compound settlement must be appointed by the court for the purpose of receiving such purchase-money. That, at all events, has been generally understood to be the effect of the decision of Mr. Justice NORTH, although it is true that the strict question before him was as to the jurisdiction to appoint trustees of the compound settlement. We have repeatedly drawn attention to the extreme inconvenience occasioned by this decision, and we gave reasons (ante, p. 6) for believing that it is incorrect. We may add that (as Mr. CHALLIS has usefully pointed out in the preface to the new edition of Hood and Challis's Conveyancing Mellor, The Right Hon. John W., Q.C., Estates (1897, 1 Ir. Rep. 121), on which Mr. Justice NORTH and Settled Land Acts) in the Irish case of Re Meade's Settled case was not an authority for the doctrine that a mere charge of jointures and portions created a compound settlement. It will be seen from Re Keck and Hart's Settlement (reported elsewhere) that, upon a vendor and purchaser summons, Mr. Justice STIRLING has held that jointures appointed under a power in a settlement created by will do not constitute with the will a compound settlement; that, in such a case, the tenant for life could convey the land freed from the jointures, and that the trustees of the will for the purposes of the Settled Land Acts could give a good discharge for the purchase-money. So far the decision is very satisfactory, although, as we have apparently conflicting decisions of two very learned and careful judges, the practitioner, until the matter comes before the Court of Appeal, will remain in considerable embarrassment. THE DECISION, however, leaves open the other point which was decided in Re Tibbits' Settled Estates-namely, that under section 4 of the Settled Land Act, 1890, a charge on the estate of the tenant for life creates a compound settlement, as to which Mr. Justice STIRLING expressed no opinion. That section provides that every instrument whereby a tenant for life, in consideration of marriage, or as part or by way of any family arrangement, not being a security for payment of money advanced, makes an assignment of or creates a charge upon his estate or interest under the settlement, is to be deemed one of the instruments creating the settlement, and not an instrument vesting in any person any right as assignee for value within the meaning or operation of section 50 of the Act of 1882. As we have before pointed out, the object of this provision is to render it unnecessary for a person entitled to pin-money, &c., charged on the life interest of the tenant for life to concur in the exercise of his statutory powers under section 50 of the Settled Land Act, 1882. It does not in any sense relate to the appointment of trustees for the purposes of the Settled Land Acts, and we have always failed to see how the phrase "one of the instruments creating the settlement" can be construed as meaning "one of the instruments creating a compound settlement." It is very much to be hoped that this question will shortly be brought before the court, and that we may be completely relieved of the inconvenience caused by the decision in Re Tibbits' Settled Estates. A VERY important question as to solicitor's lien was decided by the Court of Appeal, on appeal from KEKEWICH, J., in Re Hawkes, Ackerman v. Lockhart (reported elsewhere). In that case a solicitor had an admitted lien on certain documents belonging to a deceased person named HAWKES. The executors of the deceased employed the same solicitor to take proceedings for the administration of the deceased's estate, which was insufficient to pay his debts, and an administration order was obtained. Afterwards the conduct of the action was given to a creditor; but the executors remained parties to the proceedings, and the solicitor continued to act for them. A question arose as to whether proceedings should be taken to recover a debt which was supposed to be due to the deceased, and on this question the executors desired to be advised by counsel. A case for the opinion of counsel could not be prepared without seeing certain documents upon which, as against the deceased, the solicitor had an admitted lien. KEKEWICH, J., ordered the solicitor to produce the documents at his office. This decision the Court of Appeal has now affirmed. The authorities were elaborately reviewed; but the Master of the Rolls came to the conclusion that "none of them were exactly in point, and it is necessary to consider the question on principle." He and RIGBY, L.J., decided the case on the ground that the solicitor's lien was simply a right to retain documents as against the client and persons representing him, and gave the solicitor no greater right, as between himself and third parties, to refuse production, than the client would have had if the documents had been in his own possession. The curious thing, on this view, is that in the present case the solicitor is compelled, in an administration action which was commenced by the executors of the deceased, though a creditor now has the conduct of it, to produce documents of which, ex hypothesi, neither the deceased nor his executors could have compelled production. VAUGHAN WILLIAMS, L.J., while "agreeing in the result," preferred to rest his judgment on the ground of a duty from the solicitor to his client. The solicitor employed in any cause, his lordship thought, when he accepted the client's retainer, impliedly agreed to waive his lien so far as production of the documents might be necessary for the purposes of the proceedings, and this implied agreement covered not only documents received by the solicitor in the suit, but those which were in his possession before its commencement. The result thus unanimously arrived at is, that at least in "administration and representative actions," and perhaps in any action-a solicitor who has a lien must, notwithstanding, produce documents subject thereto, if required to do so by parties other than his client. This seems considerably to abridge what has commonly been supposed to be the extent of the professional privilege. THE DUTIES and liabilities of an auditor formed an interesting topic of discussion in the House of Lords Committee on Company Law on Monday, when Mr. WHINNEY, ex-president of the Institute of Chartered Accountants, was giving his evidence. It is admitted that the functions of an auditor are not limited to a mechanical examination of the accuracy of the accounts as submitted to him by the company. He is bound to examine into the meaning of the accounts, and to ascertain that the results presented in the balance-sheet are not misleading. "His business," said LINDLEY, L.J., in Re London and General Bank (44 W. R. 80; 1895, 2 Ch. 673), "is to ascertain and state the true financial position of the company at the time of the audit." But he does not, as the lord justice went on to say, discharge this duty by examining the books of the company without inquiry and without taking any trouble to see that the books themselves show the company's true position. At the same time, to go behind the books and to investigate the true value of the assets entered there very soon lands the accountant in the position of valuer, and a limit must necessarily be placed upon his researches. The limit is stated in another passage from the same judgment. "An auditor is not bound to exercise more than reasonable care and skill in making inquiries and investigations." The limit is necessarily indefinite, and in practice it means that the auditor is not concerned to inquire into the accuracy of particular items of valuation unless there is some special ground for suspicion. The matter was neatly put in the committee by Lord DAVEY, when, after a discussion of the duty of the auditors to value the assets, he asked, "Is not the sounder principle this-that the auditor is bound to know everything the books tell him, to have all the suspicions that the book suggest, and to make all the inferences to which what he finds in the books would lead him?" At the same time, if this standard of perfection is set up, it is not surprising that Mr. WHINNEY, speaking for accountants generally, desires to limit their liability for any defect of duty to a specified multiple of the annual fee, and not to impose on them as a penalty the full loss which their error may impose on the company or its creditors. We are glad to see that attention was called in the committee to clause 36 of the Companies Bill, which allows of unlimited liability being placed upon the members of a company in cases where a certificate of incorporation has been obtained by fraud, misrepresentation, or mistake. In cases of fraud this may be right enough, but to apply it to cases of mistake is in conflict with the principle of limited liability and also with the spirit of the declaration at the commencement of the Bill that the certificate of incorporation is to be conclusive. The Lord Chancellor characterized the proposal as very extreme. IT IS a well-settled rule that where a wife mortgages her property to raise money for the purposes of paying her husband's debts, she is entitled to be indemnified by the husband (Huntingdon v. Huntingdon, 2 Bro. P. C. 1), but the judgment of the Court of Appeal in Paget v. Paget (reported elsewhere) enforces the qualification that the rule is based upon the assumption that the parties intended that wife's property should be exonerated by the husband, and where the circumstances do not justify this assumption the the |