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SMITH, WILLIAM NORTHEY, West Kensington, Jeweller
High Court Pet Feb 8 Ord March 26
TASKER, FREDERICK TALBOT, Dartford, Solicitor High
Court Pet March 14 Ord March 23
TOAS, GEORGE, Astley Bridge, nr Bolton, Shoeing Smith
Bolton Pet March 30 Ord March 30
TOWLER, WILLIAM ABEL, Forest Gate High Court
Feb 22 Ord March 26

Pet

WARD, EDWIN, and NATHANIEL LEASK, North End passage, Wellclose sq, Cigar Merchants

High Court

Pet

March 12 Ord March 26

WILDGOOSE, JOB, Levenshulme, nr Manchester Manchester Pet March 29 Orl March 29

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Pet

March 29 Ord March 30

WILLIAMS, DAVID, Hulme, Manchester Manchester

March 28 Ord March 28

ADJUDICATION ANNULLED AND RECEIVING

ORDER RESCINDED.

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BROWN, JOHN CROXTON, Stanwick, Northamptons April 16
at 12 Off Rec, County Court bldgs, Sheep st, North-
ampton

BULLOCK, HERBERT WILLIAM, Chatham April 15 at 12
Bankruptcy bldgs, Carey st

CLEMENTS, FRANCIS, Wortbing, Provision Merchant April
13 at 12 Off Rec, 4, Pavilion bldgs, Brighton
CREIGHTON, ROBERT J, Langport, Major April 14 at 12.30
Off Rec, Endless st, Salisbury

Pet CROSBIE, CHARLES HOWARD, Mevagissey, Cornwall April
16 at 10 Off Rec, Boscawen st, Truro
DARTNALL, HENRY THOMAS, Cheltenham, Stationer April
14 at 3.15 County Court bldgs, Cheltenham
DENHAM, GEORGE, Brighouse, York, Cooper April 16 at 11
Off Rec, Townhall chmbrs, Halifax
DICKINSON, HENRY GEORGE, and JAMES WILLIAM DICKIN-
SON, Morpeth, Livery Stable keepers April 13 at 11.30
Off Rec, 30, Mosley st, Newcastle on Tyne
DORE, WILLIAM BRASHER, Oxford, Tailor April 13 at 3.30
1, St. Aldate's, Oxford

WILSON, JAMES GEORGE, Pembroke, Saddler Pembroke Dock Adjud Oct 25, 1897 Annul and Resc Feb 9 NOTE. Re Samuel Addingley, Wakefield. The Notice of Adjudication published in the London Gazette of March 25 is hereby cancelled, no Order of Adjudication having been made.

Lendon Gazette.-TUESDAY, April 5.

RECEIVING ORDERS. ALLINSON, JOHN BENJAMIN, Leeds, Boot Manufacturer Leeds Pet March 31 Ord March 31 BOULD, JOSEPH, Longton, Staffs, Wholesale Cabinet Maker Stoke upon Trent Pet April 2 Ord April 2 BRAMHAM, THOMAS SHEPHERD, Leeds, Builder's Manager Leeds Pet March 30 Ord March 30 BROWNE, OSCAR, Nottingham Nottingham

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FINE, JACOB, Aberdare, Glams, Furniture Dealer Aterdare Pet April 1 Ord April 1

GIFFORD, SYDNEY HERBERT, Willesborough, Kent, Miller
Canterbury Pet March 16 Ord March 31
GREEN, BERNARD JOSEPH, Wolverhampton, Architect,
Wolverhampton Pet April 1 Ord April 1
GUEST, ARTHUR, and WILLIAM PRESCOTT, Rotherham,
Builders Sheffield Pet April 2 Ord April 2
HERZOG, FREDERICK, Cranwick rd, Stamford Hill, Cotton
Broker High Court Pet April 1 Ord April 1
HUNT, ALFRED, Plumstead, Tailor Greenwich Pet March
30 Ord March 30

HUNTER, JOHN, Pwllheli, Carnarvons, Contractor Portmadoc Pet April 2 Ord April 2

JONES, CLEMENT SELKIRK, Peckham, Furniture Dealer High Court Pet Feb 24 Ord April 1

JONES, EMILY ELLEN, Walsall, Milk Purveyor Walsall Pet March 31 Ord March 31

LOCK, THOMAS, Reading, Horse Dealer Reading Pet March 29 Ord March 29

MARSHALL, CHARLES WALKDEN, Oldham, Greengrocer Oldham Pet April 1 Ord April 1

MORITZ, LIONEL, Bury st, General Merchant High Court
Pet March 31 Ord March 31

MORRELL, JOHN WILLIAM, Nidd, Yorks, Farmer York
Pet March 31 Ord March 31
MOULDING, HENRY, Blackburn, Cabinet Maker Blackburn
Pet March 29 Ord March 29
PAGETT, JOHN, Maindee, Newport, Mon, Boot Dealer
Newport, Mon Pet April 1 Ord April 1
PERKIN, MARY JANE, Milford Haven, Pembroke, Draper
Pembroke Dock Pet April 1 Ord April 1
POOLES, CLARA, Newport, I W, Schoolmistress Newport
Pet March 30 Ord March 30

POWELL, JAMES, Feltham, Farmer Kingston, Surrey Pet
Feb 12 Ord March 18

RILEY, OWEN, Mos, Side, nr Manchester, Grocer Salford Pet March 17 Ord April 1

SHEPPARD, HENRY JAMES, Bedford, Florist Bedford Pet March 25 Ord March 30

SNOW, ARTHUR, Essex st, Strand, Solicitor High Court Pet Feb 14 Ord March 31

STEVENS, ARTHUR HORACE, and PERCY CREW HANLEY,

Brockley rd, New Cross, Surrey, Accountants High
Court Pet April 1 Ord April 1

TALBOT, ELI, Worle, Somerset, Baker Bridgwater Pet
April 1 Ord April 1

THOMAS, JOHN, Treorky, Glam, Licensed Victualler Ponty-
pridd Pet April 2 Ord April 2
THORNLEY, HENRY, Essington, nr Wolverhampton, Farmer
Wolverhampton Pet April 2 Ord April 2
TIBBITTS, THOMAS WILLIAM, Wednesbury, Staffs, Butcher
West Bromwich Pet March 31 Ord March 31
TRUSCOTT, ELIZABETH ALICE HARRIS, Wadebridge, Corn-
wall Truro Pet Feb 17 Ord April 2
WILLIAMS, THOMAS, Brixton, Baker High Court Pet
April 2 Ord April 2

WILLIAMS, WILLIAM, Portb, nr Pontypridd, Engine Driver
Pontypridd Pet March 29 Ord March 29
Amended notice substituted for that published in the
London Gazette of April 1:
WILLIAMS, DAVID, Hulme, Manchester Manchester Pet
March 28 Ord March 28

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GARDNER, DOUGLAS, and EDWARD BERTRAM HARTLEY, Birmingham, Patentees April 15 at 11 174, Corporation st, Birmingham

GRANT, JOHN WALKER, Stantonbury, Bucks, Draper April 16 at 12.30 Off Rec, County Court bldgs, Sheep st, Northampton

FENTON, RICHARD, and JAMES BUCKLEY, Newhey, Lancs.
Calico Printers April 14 at 2.15 Townhall, Rochdale
FITZCLARENCE, The Hon WILLIAM GEORGE, Worthing April
14 at 3.30 Melville Green, Chapel rd, Worthing
HAMMOND, PERCY, Middlesborough, Butcher April 13 at 3
Off Rec, 8, Albert rd, Middlesborough
HARGBEAVES, LAW ALFRED JAMES, Buxton, Derbys April
14 at 2.30 Off Rec, Byrom st, Manchester
HARRISON, THOMAS, Edith Weston Rectory, Rutlands
April 14 at 12.30 Off Rec, 1, Berridge st, Leicester
HEBZOG, FREDERICK, Cranwick rd, Stamford Hill, Cotton
Broker April 14 at 1 Bankruptcy bldgs, Carey st
HUDDLESTONE, ANN, Grasmere, Westmrld, Temperance

Hotel April 16 at 12 Grosvenor Hotel, Stramongate,

Kendal

LAURENCE, JOSEPH, Aston, nr Birmingham, India Rubber Dealer April 14 at 12 174, Corporation st, Birmingham

LOWE, ERNEST ARCHER, Birkenhead, Grocer

April 14 at 2.30 Off Rec, 35, Victoria st, Liverpool MORRELL, JOHN WILLIAM, Nidd, York, Farmer April 15 at 12.15 Off Rec, 28, Stonegate, York NAYLOR, GEORGE HEATH, Hoyland Nether, nr Barnsley, Postmaster April 14 at 10.15 Off Rec, Regent st, Barnsley

OSBORNE, WILLIAM HENRY, St George's rd, Southwark, Publican April 14 at 12 Bankruptcy bldgs, Carey st OWEN, SEPTIMUS STANLEY, Openshaw, nr Manchester, Grocer April 14 at 3.30 Off Rec, Byrom st, Manchester

POWELL, JAMES, Feltham, Farmer April 14 at 11.30 24,
Railway app, London bdge

RAWLINGS, WILLIAM ROBINSON, Worcester, Glover April
16 at 11.30 Off Rec, 45, Copenhagen st, Worcester
RULE, JOHN THOMAS, Camborne, Cornwall, Tin Streamer
April 14 at 12 Off Rec, Boscawen st, Truro
SHRIEBERG, JACOB, Bedford st, Commercial rd, Boot
Manufacturer April 15 at 2.30 Bankruptcy bldgs,
Carey st

SKEVINGTON, ALFRED, Leicester, Commercial Traveller
April 15 at 12 Off Rec, 1, Berridge st, Leicester
SPENSLEY, ROBERT, Gt Grimsby, Wholesale Fruiterer

April 15 at 11 Off Rec, 15, Osborne st, Gt Grimsby STEWART, FREDERICK GEORGE, Newport, Mon, Hairdresser April 14 at 12 Off Rec, Westgate chmbrs, Newport, Mon

THORMAN & Co, Market st, Finsbury, Leather Dealers
April 18 at 12 Bankruptcy blogs, Carey st
WATSON, THOMAS HENRY, Sheffield April 15 at 3 Off Rec,
Byrom st, Manchester

WEBB, JOHN ABRAHAM, Coventry, Tinplate Worker April
14 at 11 174, Corporation st, Birmingham
WILLIAMS, DAVID, Hulme, Manchester April 14 at 3 Off
Rec, Byrom st, Manchester

WILLIAMS, WILLIAM, Porth, nr Pontypridd, Engine Driver
April 12 at 12 65, Highs t, Merthyr Tpdfil
WILLIAMSON, HENRY ALBERT, Bedford, Builder

April 14

at 11.30 Off Rec, 1A, St Paul's sq, Bedford WILSON, JAMES, Harp lane, Great Tower st April 15 at 12 Bankruptcy bldgs, Carey st ADJUDICATIONS.

ALLINSON, JOHN BENJAMIN, Leeds, Boot Manufacturer Leeds Pet March 31 Ord March 31

BENTOTE, REGINALD JOSEPH, Acton, Financial Agent Brentford Pet Dec 18 Ord March 31

BLAKE, T F, Bristol, Grocer Bristol Pet March 4 Ord March 31

BOULD, JOSEPH, Longton, Staffs, Wholesale Cabinet Maker Stoke upon Trent Pet April 1 Ord April 2 BRAMHAM, THOMAS SHEPHERD, Leeds, Builder's Manager Leeds Pet March 30 Ord March 30

CLEWES, GEORGE HENRY, Derby, Grocer Derby Pet March 31 Ord April 1

DE BERNALES, EDGAR A, York bldgs, Adelphi, Editor
High Court Pet Nov 25 Ord March 31
DICKINSON, HENRY GEORGE, and JAMES WILLIAM DICKIN-
SON, Morpeth, Northumberland, Livery Stable Keepers
Newcastle upon Tyne Pet March 5 Ord April 2
DODD, ALEXANDER RUSSELL, Montagu st, Portman sq,
Surgeon High Court Pet Feb 25 Ord March 31
DREWITT, FRANK GIBSON, Gosport, Hants, Cycle Maker
Portsmouth Pet March 31 Ord March 31
EWING, BASIL, Chesterfield, Derby, Corn Merchant
Chesterfield Pet April 2 Ord April 2

FARMAN, HAROLD AUGUSTUS, Charing Cross, Solicitor
High Court Pet March 11 Ord March 30
FINE, JACOB, Aberdare, Glam, Furniture Dealer Aberdare
Pet April 1 Ord April 1

GREEN, BERNARD JOSEPH, Wolverhampton, Architect
Wolverhampton Pet April 1 Ord April 1
GUEST, ARTHUR, and WILLIAM PRESCOTT, Rotherham,
Builders Sheffield Pet April 2 Ord April 2
HOTINE, FREDERICK M, Regent st, Billiard Table Manu-
facturer High Court Pet Nov 23 Ord April 1
JONES, EMILY ELLEN, Walsall, Milk Purveyor Walsall
Pet March 31 Ord March 31

LARARD, FREDERICK, Gracechurch st, Watch Maker High
Court Pet Jan 26 Ord March 30

LOCK, THOMAS, Reading, Horse Dealer Reading Pet March 29 Ord March 29

LUNN, WALTER, Bellingham, Northumberland, Innkeeper Newcastle on Tyne Pet March 25 Ord April 1 MARSHALL, CHARLES WALKDEN, Oldham, Greengrocer Oldham Pet April 1 Ord April 1

MORRELL, JOHN WILLIAM, Nidd, Yorks, Farmer

Pet March 31 Ord March 31

York

MORTIMER, WILLIAM HENRY, Weston super Mare, Leather
Merchant Bristol Pet Dec 22 Ord March 31
MOULDING, HENRY, Blackburn, Cabinet maker Blackburn
Pet March 29 Ord March 29

PEEL, Sir ROBERT, Drayton Manor, Warwick, Baronet
High Court Pet Dec 8 Ord March 30
POOLES, CLARA, Newport, I W, Schoolmistress Newport
Pet March 30 Ord March 30

ROWLES, MATTHEW WILLIAM, Woking, Surrey, Builder
Guildford Pet Dec 1 Ord March 30

EQUIRES, THOMAS, Bletchley, Bucks, Butcher Northampton Pet March 30 Ord April 2

STEVENSON, MATTHEW SINCLAIR, Queen Victoria st, Company Promoter High Court Pet Feb 11 Ord April 1

TALBOT, ELI, Worle, Somersets, Baker Bridgwater Pet April 1 Ord April 1

THOMAS, JOHN, Treorky, Glam, Licensed Victualler
Pontypridd Pet April 2 Ord April 2

THORNLEY, HENRY, Essington, nr Wolverhampton, Farmer
Wolverhampton Pet April 1 Ord April 2
TIBBITTS, THOMAS WILLIAM, Wednesbury, Butcher West
Bromwich Pet March 31 Ord March 31
VEALE, GEORGE, Dunsmure rd, Stamford Hill, Builder
High Court Pet Feb 17 Ord March 31
WILLIAMS, THOMAS, Brixton, Baker High Court Pet
April 2 Ord April 2

WILLIAMS, WILLIAM, Porth, nr Pontypridd, Engine Driver
Pontypridd Pet March 29 Ord March 29

Amended notice substituted for that published in the London Gazette of Feb. 18:

DAVIES, DAVID, Abergwilly, Carmarthens, Saddler Carmarthen Pet Feb 12 Ord Feb 14

Amended notice substituted for that published in the
London Gazette of April 1:

WILLIAMS, DAVID, Hulme, Manchester Manchester Pet
March 28 Ord March 28

ADJUDICATION ANNULLED. PAGE, WILLIAM GRANT, Leicester, Shopkeeper Leicester. Adjud Nov 27, 1894 Annul March 31

AN IMPORTANT DECISION.

THE REPORT OF SIR CHARLES A. CAMERON, M.D. "Department of the Medical Officer of Health, and "Public Analyst.

"Public Health Office,

"Cork Hill, City Laboratory,
"17, Castle-street, Dublin.
March 26th, 1898.

"I have examined specimens of Vi-Cocoa, and have obtained satisfactory results. I find it to consist of nutritive materials of high value, and possessing agreeable flavour. Vi-Cocoa is easily digested. It is not usual for preparations sold under the name of Cocoa or Chocolate to contain so much albuminous (muscle-forming) material as Vi-Cocoa contains-namely, the high proportion of 163 per cent. As the article is nutritious and well-flavoured, I have no hesitation in recommending it.

"CHARLES A. CAMERON, M.D.,

"Ex-President and Professor of Hygiene, Royal College of Surgeons, Ireland, Caif Medical Officer of Health for Dublin."

A little book containing the reports of the very highest medical experts and analysts in the United Kingdom, showing the advantages of Dr. Tibbles' Vi-Cocoa over all other food products, will be forwarded post-free on application (a postcard will do) to any address. Also dainty sample tin. Address: Dr. Tibbles' Vi-Cocoa (1898), Ltd., 60, 61, and 62, Bunhill-row, London, E.C.

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INCORPORATED

LAW

LEGAL EDUCATION.

THE COUNCIL invite attention to the following scheme of education, adopted n 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.

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THEIR

EXTRACT FROM A LECTURE ON "FOODS AND VALUES," BY DR. ANDREW WILSON, F.R.S.E., &c.-"If any motives-first, of due regard for health, and second, of getting full food-value for money expended-can be said to weigh with us in choosing our foods, then I say that Cocoa (Epps's being the most nutritious) should be made to replace tea and coffee without hesitation. Cocoa is a food; tea and coffee are not foods. This is the whole science of the matter in a nutshell, and he who runs may read the obvious moral of the story."

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.

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After Inter. Examination. £4 4 0 | (12 months) £6 6 0 660 (2 years) 4 4 0 (5 months)

330

880 990

770

770 (4 months) 880

...

...

550

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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.

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To Her Majesty, the Lord Chancellor, the Whole of the
Judicial Bench, Corporation of London, &c.

ROBES FOR QUEEN'S COUNSEL AND BARRISTERS.
SOLICITORS' GOWNS.

Law Wigs and Gowns for Registrars, Town
Clerks, and Clerke of the Peace,
Corporation Robes, University and Clergy Gowns.

ESTABLISHED 1689.

94, CHANCERY LANE, LONDON. LONSDALE PRINTING WORKS,

LONSDALE BUILDINGS, 27, CHANCERY LANE. ALEXANDER & SHEPHEARD,

PRINTERS and PUBLISHERS. BOOKS, PAMPHLETS, MAGAZINES. NEWSPAPERS & PERIODICALS. And all General and Commercial Work. Every description of Printing-large or small.

Printers of THE SOLICITORS' JOURNAL Newspaper.

Authors advised with as to Printing and Publishing.
Estimates and all information furnished.

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THE REVERSIONARY INTEREST SOCIETY,

LIMITED

(ESTABLISHED 1823), Purchase Reversionary Interests in Real and Personal Property, and Life Interests and Life Policies, and Advance Money upon these Securities.

Paid-up Share and Debenture Capital, £616,525. The Society has moved from 17, King's Arms-yard, to 30, COLEMAN STREET, E.C.

BRAND & CO.'S
SPECIALTIES
FOR INVALIDS.
ESSENCE OF BEEF,
BEEF TEA,

MEAT JUICE, &c.,

Prepared from finest ENGLISH MEATS
Of all Chemists and Grocers.

BRAND & CO., LTD., MAYFAIR, W., & MAYFAIR
WORKS, VAUXHALL. LONDON, S.W.
FEK 60 GUINEAS

SCHOOL SHIP "CONWAY"

LIVERPOOL.

FOR TRAINING

YOUNG GENTLEMEN TO BECOME OFFICERS IN MERCHANT STEAMERS. FOR PROSPECTUS APPLY TO THE CAPT., A.T.MILLER.R.N.

DIAMONDS, PEARLS,

GOLD JEWELLERY,

PLATE MEDALS

EST: 1772

Diamond Merchants

AND

FROM

1&2 GRACECHURCH ST LONDON.

&C.

VALUED

PURCHASED OR EXCHANGED

£5

ΤΟ

$10,000.

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Under the patronage of H.M. The Queen and H.S.H. Prince Louis Battenberg, K.C.B.

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To see that the Insurance Covenants include a policy covering the risk of
LOSS OR FORFEITURE OF THE LICENSE.

Suitable clauses, settled by Counsel, can be obtained on application to THE LICENSES INSURANCE CORPORATION AND

GUARANTEE FUND, LIMITED,

24, MOORGATE STREET, LONDON, E.C. Mortgages Guaranteed on Licensed Properties promptly, without special valuation and at low rates.

LEGAL AND GENERAL LIFE ASSURANCE
SOCIETY.

ESTABLISHED OVER HALF A CENTURY.
10, FLEET STREET, LONDON.

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IT HAS this week been suggested as a solution of the present difficulty with regard to the trial of patent actions, that they should be removed from the High Court entirely and submitted for the decision of the officials of the patent office. It is needless to say that the suggestion is not likely to be entertained for a moment, though the fact that it can be gravely made is a significant indication of the state to which matters have been allowed to come. The granting of a patent in the first instance is a question of administrative discretion, and in the exercise of the discretion by the patent office it is necessary to consider whether the applicant is prima facie entitled to the patent he is seeking. But this is a very different matter from deciding upon the validity of the patent when it has been formally put in issue by an opponent. The patent is a species of property and its protection must be referred to a court of justice. Or if this reason is too technical, the interests which are at stake entitle the parties to such a hearing of the case as can only be obtained by regular judicial methods. It may be predicted that if a special court were constituted for patent cases much of the present expense and waste of time would be avoided. Before a judge who was always dealing with this class of business. expert evidence, while not ceasing to be important, would probably be reduced in amount, and it would be easier to keep a check both upon the "advocacy" of expert witnesses and upon the length of the proceedings.

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THE PROBABLE outbreak of hostilities between the United States and Spain makes it important to notice that neither nation is a party to the article of the Declaration of Paris according to which "privateering is and remains abolished." Privateering, or "cruising with private armed vessels commissioned by the State (Wheaton's International Law, 3rd English ed., p. 488), was formerly sanctioned by the laws of every maritime nation as a legitimate means of destroying the commerce of an enemy, but, like the confiscation of private property taken at sea, it is a relic of barbarous modes of warfare, and as between nearly all the States of the world it has

now been abolished. The first effort in this direction came, curiously enough, from the United States themselves, and Dr. FRANKLIN obtained the insertion in their treaty with Prussia of 1785 of a clause by which the two contracting Powers agreed to grant no commissions to private armed vessels; but the clause was omitted from the renewed treaty of 1799. Between 1823 and 1830 the United States were in negotiation with Great Britain, France, and Russia to obtain treaties abolishing privateering, but these Powers were unwilling to enter into separate agreements, though they were in favour of a general agreement of the chief maritime Powers to the same effect. Subsequently the United States altered their views on the subject, considering that privateering might be a useful means of making up for the smallness of their regular navy in the event of a conflict with a great European Power, while even with smaller Powers their widespread commerce and extended sea-coast would put them at a disadvantage; and the honour of taking the real initiative in the abolition of privateering lies with the original parties to the Declaration of Paris, including Great Britain, France, Russia, and Prussia. All civilized states have since become signatories of the Declaration except the United States, Spain, and Mexico. The Declaration is only a compact between the signatories to it, and privateering is still possible, therefore, in a war between any of the signatories and one of these three states, or, of course, in a war between any of the excepted states themselves.

THE ABOVE statement does not, however, represent fully the course taken by the United States with respect to the abolition of privateering by the Declaration of Paris. As a matter of policy they were, as already observed, in favour of preserving privateering, but they had the enlightenment to be willing to consent to its abolition provided an article was added prohibiting the capture of all private property at sea not contraband. The Powers generally were in favour of this amendment, but according to Wheaton (8th ed., p. 451) it was defeated in consequence of the opposition of Great Britain. This was in 1856, and in the following year the offer of the United States to accede to the Declaration of Paris on the proposed terms was withdrawn. Upon the outbreak of the American Civil War an offer of unconditional accession was made to the European Powers by President LINCOLN, but the terms which Great Britain sought to impose in favour of the belligerent rights of the Confederacy prevented this offer from becoming effectual. By the constitution of the United States, Congress has power to grant letters of marque, and during the Civil War an Act was passed authorizing their issue by the President; but in fact they were never issued by either side. Should the existing dispute lead to war between the United States and Spain there can be no doubt that each side will be within its right in permitting privateering. It may be noticed that in the war between France and Spain in 1823 the belligerents at the outset issued declarations both against the commissioning of privateers and against the capture of private property at sea. Having regard, however, to the considerations which have influenced the policy of the United States with regard to privateering, it is unlikely that any such mutual declarations will be made on the present occasion.

AN ESTEEMED Correspondent calls attention in another column to two matters in which a change is desirable. The first is the rule that the scale fee for a lease includes all charges for negotiating and for preparation of a preliminary agreement: Re Field (33 W. R. 553, 29 Ch. D. 608); Rs Emanuel and Simmonds (34 W. R. 713, 33 Ch. D. 40); Savery v. Enfield Local Board (1893, A. C. 218). As our correspondent says, there is often as much trouble in settling the terms of a lease as of a sale and purchase, and it is unreasonable that a negotiation fee should be allowed in the one case and not in the other. No doubt, one difficulty in the way of the appellants in the above-mentioned cases was that they had to claim fees according to the old system for the preliminary agreement and negotiations, the result of this being considered by Lord HERSCHELL in Savery v. Enfield

Local Board (1893, A. C., at p. 225) to be that it would really leave it open to the solicitor, in addition to the scale fee, to make a further charge, in the ordinary fashion which was in existence before the scale fee was arrived at for a considerable number of things which are said to be outside it. It would leave it in every case open to dispute and discussion how much there was outside of it, and it would necessitate in all those cases a taxation. That is the very thing which it was sought to avoid by this legislation." The obvious and best remedy is to make the negotiation fee extend to leases; and in the meantime practitioners should be careful to expressly stipulate that the agreement and negotiations for a lease are to be paid for in addition to the scale charge. The second point mentioned by our correspondent is the hardship of throwing on a purchaser the cost of procuring evidence to establish the vendor's title, as to which we think no practitioner will differ from him. This practice has, as we all know, given rise to the common form answer to requisitions-"This can be done at the purchaser's cost." No doubt the rule has the effect of choking off many requirements which would otherwise be made; but there are requirements which cannot be dispensed with, and our correspondent tells of a case in which the vendor purported to sell as heir-at-law, and the purchaser's solicitors had to make out at the purchaser's cost a pedigree with about twenty certificates, besides statutory declarations. We do not recall anything quite so unfair as this, but in a considerable proportion of purchases the result of the rule is to throw on the purchaser costs of making out the title which ought in fairness to fall on the vendor.

SOME INTERESTING observations on the effect of Allen v. Flood

(46 W. R. 258; 1898, A. C. 1) will be found in an article contributed by Sir FREDERICK POLLOCK to the current number of the Law Quarterly Review. "There is no wrong," says Sir FREDERICK, "in persuading or inducing a man to do what he has a right or is lawfully free to do. The fact that such action may damage a third person can of itself no more give that person a right of action against the persuader than against the actor himself. And the precise point now decided by the House of Lords is that a cause of action cannot be made out of such facts by adding allegation and proof of malice, in the sense of actual evil motive, personal ill-will, or whatever term least favourable for the defendant can be found for the thing signified." A definite limit is thus put to the relevance of malice as an element in civil actions, and it appears to be entirely discarded as affording in itself a cause of action, even though accompanied by actual damage. "We think," continues the same writer, it must be taken, on the whole, as part of the ratio decidendi, that in general the combination of damage and malice will not suffice to make a cause of action (see especially per Lord MACNAGHTEN), but violation of some definite duty must be shown; and that, on the other hand, the cases where malice is really essential to the cause of action are in some way excep tional." The malice in these exceptional cases operates not directly as a violation of any right of the plaintiff, but indirectly as depriving the defendant of the benefit of a privilege which would otherwise make his conduct not actionable. Malice, for instance, forfeits the privilege which might have held the defendant harmless in an action for defamation. It has a similar operation in an action for malicious prosecution; such, at least, Sir FREDERICK POLLOCK Considers to be a proper inference from some of the judgments in Allen v. Flood. But, with these exceptions, motive does not seem to constitute an element in civil injuries. It is a further deduction from the judgments that there is no such thing as a right not to be hindered in one's occupation, except so far as the offender may expose himself to an action for trespass, nuisance, defamation, or something in the nature of deceit. "There is no better or higher right to carry on one's business than to do any other lawful act, and no need to invent any such right." A man has to bear with the malice of his neighbours, unless effect is given to it in acts which violate his independent rights. The result, Sir FREDERICK POLLOCK observes, tends to the simplification of the law, and he expresses the hope that, so far as civil actions are concerned, it will enable us to get rid of the perplexed and perplexing word "malice" altogether.

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THE PRINCIPLE of Allen v. Flood has been recognized and acted upon in an interesting case-People, &c. v. Davis-decided in the Criminal Court of Cook County, Illinois, in February, and reported in the National Corporation Reporter. The circumstances were very similar to those in the English case. The defendants, who were members of a trade union, threatened to call out the engineers of the Thomas Elevator Co. unless two workmen who were not members of the union were discharged. The threat was carried into execution, the works were stopped, and thereupon the obnoxious workmen were discharged. The defendants were indicted under the Illinois Conspiracy Statute, which provides that "if any two or more persons conspire or agree together with the fraudulent or malicious intent wrongfully and wickedly to injure the person, character, business, or employment, or property of another. they shall be deemed guilty of a conspiracy"; and the punishment is specified. The difficulty with which the court had to contend was caused by the words "wrongfully and wickedly." The mere agreement with a fraudulent or malicious intent to injure was under the statute not sufficient. There must also be a purpose to carry into execution the fraudulent or malicious intent "wrongfully and wickedly "—that is, it was held, by the use of wrongful and wicked means. But the means were those just described-namely, the calling off of the engineers, and the court declined to regard this as wrongful simply because of the malicious intent. There must, by the words of the statute, be malicious intent and also, as a separate matter, wrongful means, and for the means to be wrongful they must be wrongful in law. In a case like the present, where there was no suggestion of fraud, immorality, injury to the public, or violation of contract, it was held that wrongfulness in law must import at least a civil wrong, and on the authority of Allen v. Flood no such civil wrong was constituted by mere malice. The legal principle settled by the case, said BAKER, J., is that the existence of a bad motive will not convert an act which is not of itself illegal into a civil wrong. This states Allen v. Flood exactly, but it is curious to find the authority of the House of Lords invoked against the application of a criminal statute specially directed at malicious conspiracy.

LAST WEEK, at the Kingston quarter sessions, a man was tried for larceny under circumstances which, if the newspaper reports are to be trusted, point to a case of great hardship. The prisoner was charged with stealing lead, the property of Her Majesty. It appears that he was arrested near one of the rifle ranges at Ash, near Aldershot, picking up spent bullets among the gorse, and it was for the larceny of these bullets that he was indicted. He was very properly acquitted, and, unless it were conclusively proved that these spent bullets are collected by the military authorities and that the accused knew that such was the fact, it is impossible to see how any jury could have found any other verdict. The essence of larceny is the animus furandi, or the intention of depriving the owner of his property against his will. Hence a thing abandoned by its owner cannot be stolen, as the common law has for centuries recognized. Now, to the ordinary mind, nothing can appear to be more thoroughly abandoned by the owner than the bullet which is fired from a rifle, and it is difficult to see how magistrates could have brought themselves to send a man for trial under circumstances which of themselves raise a strong presumption of innocence, without the clearest proof of guilty intent. As Baron PARKE said in the case of Reg. v. Thurborn (1 Den. C. C. 387), "the guilt of the accused must depend on the circumstances as they appear to him, and the crime of larceny cannot be committed unless the goods taken appear to have an owner and the party taking must know and believe that the taking is against the will of the owner." The worst feature, however, in this case is the fact that the accused person was kept three months in prison awaiting trial on this most trumpery charge. The judges have lately made some very severe comments on the conduct of magistrates in unnecessarily keeping accused persons in prison, but surely this case is a harder one than any of those which called for such comments, and the Surrey grand jury very properly made

a presentment to the court as to the hardship inflicted. The learned chairman defended the conduct of the committing justices on the ground that the prisoner was given the option of having his case tried summarily, but preferred to be tried by a jury. No doubt there may have been something in what the chairman said, although it does not appear that the justices gave the prisoner any opportunity of finding bail. But the prisoner had a right to be tried by a jury, and most people will sympathize with him in his desire to avail himself of this right.

THE EXCEPTIONS usually introduced into a bill of lading ale wide enough to save shipowners from much of the liability which would fall upon them in consequence of loss or damage to the cargo in the course of the voyage, but, as several recent cases have shewn, they have not hitherto been extended to relieve the shipowner from providing at the outset proper accommodation for the safe keeping of the cargo. In Maori King v. Hughes (44 W. R. 2; 1895, 2 Q. B. 550) it was held that in a bill of lading stated to be for the carriage of frozen meat, there was an implied warranty that the ship was at the time of shipment fit to carry such cargo. Hence the shipowner would be liable if he did not start the ship with proper refrigerating machinery, although the exception in the bill of lading would relieve him in case of a breakdown of the machinery in the course of the voyage. An interesting case of a similar nature arose in Queensland National Bank v. Peninsular and Oriental Steam Navigation Co. (46 W. R. 324). Gold coins were shipped on board one of the ships of the defendant company under a bill of lading which contained an exception against loss by robbers or thieves. The box containing the gold was placed in the bullion-room of the ship, and during the voyage the room was broken into and the box stolen. The question arose whether there was any implied warranty that the bullionroom was fit to resist thieves, and the Court of Appeal held that there was. The gold was shipped on the understanding that it would be placed in a bullion-room, and the specific object of such a room is to prevent theft. The warranty applied to the soundness of the room at the commencement of the voyage, and was not excluded by the exception in the bill of lading in respect of loss in the course of the voyage. Hence the question of warranty was decided against the shipowners.

THE PRIORITY OF EQUITABLE INCUMBRANCERS. AN interesting example of the rule that as between successive incumbrances upon an equitable interest priority is gained by the incumbrancer who first gives notice to the trustees in whom the property is vested is afforded by the decision of KEKEWICH, J., in the recent case of West v. Williams (46 W. R. 362). WALTER WILLIAMS, the elder, by his will dated in 1889, devised all his real and personal property to trustees upon trust as to the ultimate residue thereof to pay the income to his son, the defendant WALTER WILLIAMS, during his life, and after his death upon the further trusts declared by the will. The testator died in March, 1892. By a mortgage dated the 24th of December, 1895, W. WILLIAMS, the younger, assigned to the plaintiff WEST all his interest under the will as security for an advance of £600, and he covenanted that during the existence of the security he would not further deal with such interest. So long as there was no breach of covenant, notice of the assignmeut was not to be given to the trustees of the will. On the same date W. WILLIAMS charged his interest under the will with the repayment of the sum of £150 to the defendant TEMPLE. This charge was expressly made subject to the mortgage just mentioned.

In 1896 further dealings with the life interest took place. By a mortgage dated the 2nd of April in that year W. WILLIAMS assigned his interest under the will to the defendants P. A. WILLIAMS and J. W. WILLIAMS as security for an immediate advance of £2,297 and for such further annual sums of £200 as should be advanced under a covenant contained in a settlement of even date with the mortgage. By this settlement W. WILLIAMS assigned the equity of redemption in his life interest

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