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Landon Ga..seue.—TussDAY, Mar. 22. RECEIVING ORDERS.

Am swoirru, Rossnr, Mow Side, nr Manchester, Calico Printer Salford Pet March 18 Ord March 15

Asswoarii, TIIoiiAs, Dulesgate, nr Todniorden, Farmer Burnley Pet March 19 Ord_ Mai-ch 19

BIsoLs\', Hasnr, Bradford, Ladies’ Hairdresser Bra-dford Pet March 17 Ord March 17 _

CAB-ran. Los.Axor. WILLIAII. Old Broad at High Court Pet March 19 Ord Mai :h 11)

Dicinxsos. Hiisar Gsosos. and JALiss WILLIAM DIcxixsos, Morpeth, Livery Stable Keepers Newcastle on Tyne Pet March 5 Ord March 17

DonwsLL, CHR18T0l’l1BB, Gt Yarmouth, Baker Gt Yurmouth Pet March 17 Ord March 17

Doss, WILLIAM Bsssiisn, Oxford, Tailor Oxford Pet Feb 2-1 Ord March 16

GaAr, WILLIAM HAsiiIsos, Tewkesbury, Surveyor Cheltenham Pet March 5 Ord March 18

HAn'r, Siiiosa-r CoLIiimx, and CIlAI1l.l!S'ED\\'AltD FowLss, Holland Park iwue, Auctioneers High Court Pet Feb 17 Ord March 18 _ _

Haxocnsnsiio, Jossr-Ii, Broad st House, Mining Agent High Court Pet March 17 Ord March 17 _

HssLIn', STEPHEN, Anerley, Corn Dealer's Assistant Greenwich Pet March 15 Ord March 15

Hsrwourii, Jons, Startforth, nr Barnard Castle, Yorke. Sl"fVB}'01‘ Stockton on Tees Pet March 16 Ord March 16 _ _ _

Hovsi.L, Asrnua, Lakenham, Norwich, Wicker Chair Maker Norwich Pet March 19 Ord Maich 19 _

HUGHES, HAROLD M, Threadneedle st, Bank Clerk High Court Pet Feb 28 Ord March 18

Josirsa, BENJAMIN, Leeds, Insurance Agent Leeds Pet March 16 Ord March 16

Knnssr. FRANK CIiArILzs, Lowestoft, Baker Great Yarmouth Pet Feb 24 Ord Mai-ch 18

Lir'rI.s, J on! WILSON, Norfolk, Blacksmith King’:-I Lynn Pet Miimli 17 Ord March 17

Li'nsAao, MAusIcs ALnsn'r, Llandrindod Wells, Badnor. Stationer Newtown Pet_March 19 Ord March 1_9

MAssnALL, Joas Puou, Bristol, Coiifectioner Bristol Pet March 18 Ord March 18

Mossis, ELEANOR, South Shields, Saddler Newcastle on Tyne Pet March 17 Ord March 17

NoIuiAs, GEORGE, Swansea, Wareinau Swansea Pet March 18 Ord March 18

OAKLEY, Joux, Defifoi-<1, Wlieelwright Greenwich Pet March 18 Ord arch 18 _

OA'I'se, Join: Hssnr, Blietlield, Coniectioner Sheflleld Pet Feb 28 Ord March 17

Osii:-Wsnii, Rossur Omia, Dartmouth Plymouth Pet Feb 21 Ord March 11

PAL1isn, B'rsI>nss \VAL'rsIi, Brooklnnd, Kent, Corn Factor Hastings Pet March 17 Ord March 17

PsAns, J oxArIiAs Bownos, Sunderland, Ropemaker Sunderland Pet March 16 OrdMs.roh 16

RICHMOND, W1LLlAM Hssnr, Nottingham, General Dealer Nottingham Pet March 16 O March 16

Rossnrs, WILLIAM, Leeds Leeds Pet March 1S Ord March 18

BA\vI>AY, Hsxnr, South Kensington, Hotel Proprietor High Court Pet Feb 21 Ord March 17

8soAo, Gsonc-I2, Chisulck, Oil and Colourman Brentford Pet March 18 Ord March 18 _

Sl'Ol'Sl£, Hsxnisr-rA, Msrgate, China Dealer Canterbury Pet March 4 Ord Mai-ch 17

B\'nnALi., SAMIIEL, Little Lever, Lance, Collier Bolton Pet March 19 Ord March 19

Taoiirsoii, JAMrs, Bolton, Fruiterer Bolton Pet March 17 OI-dMarch 17

To\vLsa, WILLIAM Assn, Forest Gate High Court Pet Feb 22 Ord March 17

Towivsssn, Owns, Dalston, Chair Manufacturer High Court Pet Feb 2-4 Ord March 17

Tans, CIIAaLss L, Pimlico High Court Pct Jan 28 Ord March 17

VIcI:lIiMAs, Joim, Allerton, nr Bradford, Yarn Merchant Bradford Pet March 17 Ord March 17

WATSON, 'l‘IIoiIAs Hsxsv, Chorlton cum Hardy, Lanes, Railway Contractor Balfozd Pet March 19 Ord March 19

Wane, JOHN AIIIIAIIAM, Coventry Tinplate worker Birmingham Pet March 18 Ord March 18

Wiooiss, -Tons, Farnworth, Lanes, Plssterer Bolton Pet March 18 Ord Maich 18

WiLsoiI Jons, South Bank, York, Accountant Stockton on Tees Pet March 18 Ord March 18

WOAM, MIcIiAsL, Worcester, Coal Merchant Worcester Pet March 16 Ord March 16

Wnioiir, WILLIAM, Hulme, Manchester Manchester Pet March 17 Ord March 17

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THOIIPSON, JAMES, Bolton, Fruiterer Bolton Pet March 17 Ord lllarcli 17

Tanuzsnxs, Smxav Gannon, and Ari-rnua 1I.\\'w00o Cauiri>,Fenchurch st High Court Pet Jan 19 Ord March 11

VICKERMAN, Jous, Bradford, Yarn Merchant Bradford Pet March 17 Ord March 17

WATSON, THOMAS HENRY, Chorlton cum Hardy, Lanes, Railway Contractor Salford Pct March 18 Ord March 19 _ _

Wane, Joiis ABRAHAM, Coventry Birmmgham Pet March 18 Ord March 18 _

Wznsran, JAMES, Liverpool, Daiiymin Liverpool Pet Feb 4 Ord March 17

WIGGINS, J our. Farnworth, Lanes, Plzisiercr Bolton Pet March 18 Ord March 1:)

WILSON, Jiiinis Leeds, Canvassing Bookseller Leeds Pet Feb 11 Ord MurehlB

WILEON. J oris, South Bank, York, Accountant Stockto n on Tees Pct March 18 Ord March ld

w0AN,MlCllAlZL, Worcester, Coal Merchant Worcester Pet Mai ch 16 Ord March 16

Wnii:|rr,Wii.Liin Hulme, Manchester Manchester Pet March17 Offl March 17 _

Ysssnav, Jons Siiirri, Bristol, Boot Manuf-ictiirer Bristol Pet Feb 23 Ord March 17

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T H E A T R E S .
COMEDY.

THIS EVENING, at 8.15, THE SEA FLOWER: Messrs. John Beauchamp, Arthur Playfair, Cosmo Stuart, W. T. Lovell, Vvilfred Draycott, A. E. Matthews, Frederick Volpe, Henry Ford, and Charles Groves; Miss Lena Ashwell, Miss Gladys Homfrcy, and Miss Eva Moore.

DUKE OF YORK’S.

THIS EVENING, at S45, THE DDVECOT: Messrs. Seymour Hicks, Chas. Sugden, George Raiemond, William Wyes, L\wrcnce Cnird, Chas. V. France, and James \Velch; Mcsdames Ellis Jellreys, S. Carlislc, L. Braham, K. Kearney, S. Grey, and Carlotta Addison. At 8.0, THE LADY \VRANGl.ER. _

DRURY LANE THEATRE ROYAL.
Managing Director, Arthur Collins.

THIS EVENING, at 8.0, THE BABES IN THE WOOD : Messrs. Dan Leno, John A. Warden Griflin 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 PARTBIDGES. At 8.15, THE MUFF OF THE REGIMENT: Messrs. H. Reeves-Smith W. Everard, B. Paxton, G. Tomkins, G. Shelton, C. Tliornbury, Tovey, C. M. Lowne, E. Lovat Fraser, F. Everill; Mesdamss Ada Branson. Beatrice Ferrar, M. Allestree, Nordblum, 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 Erslune, 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 Clifie,_ Archer, Lacy, Belmore, Re riolds, Tabb, Howard, Marion, Graham; Miss Maud Milton, Miss Rockman.

ST. JAMES'S.
Mr. Geoge Alexander, Sole Lessee and Manager.

THIS EV NING, at 8.0, MUCH ADO ABOUI' NOTHING: Messrs. George Alexander, W. H. Vernon, H. V. Esmond. H. B. Irving, J . D. Beveridge, Nutcomba Gould, H. H. Vincent, Robert Loraine, Arthur Royutou, R. G. Legge, A. Holmes-Gore, Bertram Wallis, R. Dalton, Fred Terry ; Mesdames Julia Neilson, Hilda Rivers, Winifred Dolan, Fay Davis.

SAVOY.
R. D‘Oyly Carte Manager.

THIS EVENING, at 8.30, THE GON_D_0LIERS : Messrs. Walter Pasamore, H. A. Lytton, William Elton, Jones Hewson, Cory James,_L. Russell, _und Charles Kenninghaizn; Mesdnmes 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. Clare’, Barton dc Solla, Percy Percival, J. W. Macdonal , Metcalfe; Mesdames Louie Pounds, Alice Barth, Lillie Pounds, Hilda Jelfreys, and Kate Cutler.

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Under the patronage of H.111. The Queen and H.S.H. Prince Louis Battenbcfy, K.C'.B.

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IKGORPORALTEIJ

LAW sddxrrwsr.

LEGAL EDUCATION.

Tris 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 largo 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 8: 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 ]0l11 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 ; J anu to April; March to J unc.

Classes for Final Students are held at the Hall of tho 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 inslruction. '

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 perceutagte of passes _1s a high one, exceeding 8.5 per cent. of between two and three undred 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.

Equit , Conveyancing, Common Law, Bankruptcy—J. OARTIB. HARRISON’, 30, Bedgird-row, W.C.

Criminal and Magisterial Law, Probate, Divorce, Admiralty, and Ecclesiastical Law, Stephen's Commentaries-Laosmun H. \Vzsr, LL.D., 19, Southampton-buildings, Chancery-lane, W.C.

Subscription to postal instruction (12 months) £4 4 0 (12 monthfl) £6 6 0

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Subscription to Postal instruction (2 years) 6 6 0 ('2 years) 8 8 0
Class instruction (3 months) 4 4 0 (5 !11°!lI1I15) 9 9 0
For those who have previously subscribed for
Postal instruction 3 3 0 7 7 O
Class instruction (6 months) 7 7 0 (4 month!) 8 8 0
For those who have previously subscribed for
Postal instruction 5 5 0 6 6 0
For three months’ Class instruction _ 7 7 O
For those who have previously subscribed for Postal mstruction 5 5 O
Cheques and Post Oflice Orders should be made payable to the SECRETARY,

Students may subscribe for successivglasses.

Law Society's Hall. Chancery-lane.

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LIVERPOOL - Close to Central (Midland) s95l51°nBRADFORD - MIDLAND - Excellent Restaurant.

LEEDS - - QUEEN'S - In Centre of Town. _

DERBY - - MIDLAND - For Peak of Derhyshire. WOHEGAMBE - MIDLAND - Tennis Lawn to Seashore. Golf.

HI-IYSHAM—HI-IYSHAM TOWER, nr MORECAMBE. Lovely Country. Golf. Tar-ifs ml Application. Tolagrqhil. Address “ Midotel." Adelphi “Turtle” Soup forwarded from Adelghi Hotel, Iiverpool, per quart jar 188.; per pint jar, 9s. 6d., carriage psi . Speciality for Im-ahda.

WILLIAM TOWLE. Manager Midlsnd Railway Hotels. Tm: OLDEST c WEALTHIEST EXISTING MOBTGA or INSURANCE OFFICE‘. THE LAW GUARANTEE AND TRUST SOCIETY, Lrunnn.

SUBSCRIBED CAPITAL - £1,000,000. PAID-UP - ,5‘ 100,000. FIDELITY Gussanrsss or ALL xmns. Anmmrsrasrrou AND Lurmcv Bonus. IHORTGAGE, DEBENTURE, Lrcsnss, AND Con-rrrzosucv Issunancs. TRUSTEES!-IIPS FOR Dsssnruxs-uowans, &c.

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',,' The Editor cannot undertake to return rejected contributions, and copies should be kept of all articles sent by writers who are not on LONDON‘ N‘W_ (Within Shilling cub,/‘are oj Grnylg-in7l,InIl8 of Court, Temple Par; flu regular staff of the JOURNAL

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Cases Reported this Week.

In the Solicitors’ Journal.

Andrew v. St. 0lave’s Board of Works 381 Gage v. Br-aeley ........................... .. 38 Gibbs, Re. Thorne v. Gibbs ............. .. 379 Hawlres, Re. Aekerman v. I1ockhart.. 381 Keck and Hart’s Contract and the Vendor and Purchaser Act, 1874, Be 380 Maw v. Beet .................................. .. 382

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Verney's Settled Estates, In re . 348

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CURRENT TOPICS.

I1 Is unnsnsroon that the draft rules under the Land Transfer Act, I897, are now completed, and they may be expected to be

SOCIETY. ESTABLISHED OVER HALF .4 CENTURY. .0, FLEET STREET, LONDON.

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issued very shortly.

Hun Ms.Ir:s'1'Y’s udges having recommended that, for the future, the Summer Assizos 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 Oouncil to give effect to that recommendation before the next circuit.

Mn. JUSTICE STIRLING has come to the rescue of the profession from a portion of the difficulty occasioned by the decision in Ra Tihbita’ Settled Estates (1897, 2 Oh. 149). That 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 efiect of the decision of Mr. Justice Noam, 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. OHALLIS has usefully pointed out in the preface to the new edition of Hood and Challis’s Conveyancing and Settled Land Acts) in the Irish case of Re Mimic’: Settled Estates (I897, 1 Ir. Rep. 121), on which Mr. Justice Nonrn relied as exactly in point on this question, the appointment comprised not only jointures and portions, but also pin-money, which sfiected the estate of the tenant for life, and brought the case within the inter retation given by the learned judge to section 4 of the Settled Land Act, 1890 : consequently the Irish

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case was not an authority for the doctrine that a mere charge of jpintures and portions created a compound settlement. It will

e seen from Re Keck (met 1[art'e Settlement (reported elsewhere) that, upon a vendor and purchaser summons, Mr. Justice STIRmrzc 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.

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THE DECISION, however, leaves open the other point which was decided in Re Tibbits’ Settled Estatee—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 Tz'bbz'ts’ Settled Estates.

A vnav important question as to solicitor’s lien was decided by the Court of Appeal, on appeal from Kxxawrcn, J., in Re Hawkee, Ackerman v. Locklmrt (reported elsewhere). In that case a solicitor had an admitted lien on certain documents belonging to a deceased person named Hawicns. The executors of the deceased employed the same solicitor to take proceedings for the administration of the deceased’s estate, which was insnfficient 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 afiirmed. 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 hypotlwsi, neither the deceased nor his executors could have compelled production. Vacuum Wmmams, L.J., while

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“ 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.

Tun 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 lnstitute 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 Lmnnnv, 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 Davsr, when, after a discussion of the duty of the auditors to value the assets, he asked, “ls 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.

Ir I8 a well-settled rule that where a wife mortgages he!‘ property to raise money for the purposes of paying 1161'

usband’s debts, she is entitled to be indemnified by the husband (Hzmtingdon v. 1Tunt1'n_qdon, 2 Bro. P. C. 1), but tho judgment of the Court of Appeal in Puget v. Puget (reported elsewhere) enforces the qualification that the rule is based upon the assumption that the parties intended that the wife’s property should be exonerated by the husband, and

_where the circumstances do not justify this assumption the

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