denied that the results of this treatment of the bar were very different in the two cases. Of Sir William it has been said "few men ventured to exercise a patience which all men knew to be unbounded;" of the last Master of the Rolls we doubt much whether it could be said that his good-humoured spirit of endurance tended in the slightest degree to the close compression of the debate; it rather seemed, we fear, that argumentation grew and repetition was multiplied and fostered by the indulgence they met; at all events, certain it is, however the reasoning might be drawn out with linked dulness, however indulge in endless sinuosities, however return upon itself until it must now and then, we may suppose, have occurred to the mathematical mind of the court to indulge for a moment the question of what equation with what impossible roots would fitly represent a curve of so many isolated points and points of contrary flexure, and until the audience, tired out, gradually wasted away and the day began to wane, yet still Lord Langdale's patience neither wasted nor waned his powers in this respect were truly wonderful; you may look through whole volumes of Beavan's Reports, and scarce find an interpellation of his noted. He was an excellent arithmetician, and his love for dealing with figures displayed itself in the careful note he would take of almost every date and sum stated at the Bar; particularly where a balance was to be struck and a conclusion to be drawn upon the difference resulting from two columns of figures, would he show an instantaneous readiness in checking the calculation, delighting greatly when he could prove the processes of subtraction, &c. to be wrong, whether in the pence or the pounds. The result of the whole was this; a marvellous accuracy as to the facts of each case distinguishes his judgments, their general characteristic being, besides the soundness in almost all cases through fifteen years (we believe we may undertake to say) of the law laid down, great clearness arising from great command of language, enabling him to express every principle, with all the qualifications and modifications he attached to it, in such a way that no doubt as to the precise thing meant can ever remain upon the mind of the reader who gives only a moderate share of attention to the case. This high excellence is one which, like Servilius, nunquam effecisset ipsius Juris scientiâ, nisi eam præterea didicisset artem quæ doceret rem universam tribuere in partes, latentem explicare definiendo, obscuram explanare interpretando; ambigua primùm videre, deinde distinguere, postremò habere regulam, quâ vera et falsa judicarentur, et quæ quibus positis essent, quæque non essent, consequentia. For instances of his signal powers in these respects, we may refer to the long list of cases which he had to decide respecting the rights and powers of railway and other statutory corpora tions, the difficulty of dealing with which may be estimated from his own words in the House of Lords in February last. "Of a large class of cases of this kind it can hardly be said with truth that there is any law at all, any rule of right or wrong." Many of these decisions will be found to depend ultimately upon the doctrine stated by Lord Eldon in the leading case of Blakemore v. The Glamorganshire Canal Company; and others, to be little more than, in musical phrase, variations upon that theme; but in all of them, either the facility with which the rule is adapted to the particular circumstances, or the felicitous way in which it is moulded, or qualified or enlarged to meet the requirements of justice, cannot but be deeply admired. Probably no Master of the Rolls previously settled so many questions respecting so large an amount of property as Lord Langdale did by the decisions we are speaking of. It remains to glance at his appearances in the House of Lords. These were not frequent; he is reported to have spoken on nine several occasions in the year 1850, which almost equals the number of speeches he delivered during the remaining fourteen years in which he not only sat but was a very regular attendant there, his "general rule being," as he stated on one occasion, "not to trouble their Lordships with any remarks." He never spoke but once in any debate of a political character, namely, in that on The Protection of Life (Ireland) Bill,3 when he supported an amendment mitigating the rigour of the Bill with respect to the offence of being out of doors between sunset and sunrise on the following day. His exertions were wholly confined to improvements in the Law and in the Courts of Equity, His plan for the Reform of those Courts was first broached in the House of Lords, being afterwards published in a separate shape, the only occasion of his printing any thing. In one of the discussions on this subject he stated what will probably startle many persons. He said "Lord Chancellor Jeffries in all the decisions that he pronounced was considered as high authority as a lawyer. No one of his decisions had been overruled since." This is the more remarkable, coming from so singularly accurate a man, because to some extent it is 1 Vol. 114, Hans. Parl. Debates, p. 890. 3 certainly we submit incorrect; the case for instance of Knight v. Calthorp, decided by Lord Jeffries,1 has never been considered as rightly adjudged. Lord Langdale continued occasionally to address the House on his own class of subjects up to the 7th March last, when he delivered a long, clear and able speech in the debate on Lord Brougham's County Courts Extension Bill, among other matters advocating, in the last words he was to utter there, the propriety of appointing, "under some appropriate name, a minister of justice, whose duty, whilst in office, would be to attend principally, if not exclusively, to this most important of all subjects." With respect to the judicial business of the House, the reader will be surprised to find from the Reports that Lord Langdale does not appear to have attended those sittings more than twice during the fifteen years he was qualified to do so. Both were cases of wills; the first Allen v. M'Pherson occurred in 1847, and was decided by their lordships in opposition to his opinion and that of Lord Cottenham ;4 the other was Trevor v. Trevor in the same year, when however he did not deliver any judgment, perhaps because he had only attended the second argument.5 He sat as First Commissioner of the Great Seal in June and July, 1850. His attendances also at the Judicial Committee of the Privy Council were much fewer than has been supposed, from his having of late, as in the Gorham case and others, taken a leading part there; besides that case we can undertake to say not more than seventy of his sittings there are reported, the first being in 1841, on the second argument of the great case of the will of Mr. Wood of Gloucester, known as Hitchings v. Wood. This sketch, inadequate and feeble as it is, would be still more ineffective in its attempt to do justice to the man, if we omitted to state that all his public appearances, and especially those in the House of Lords, were marked by the sound discretion of his views, by the depth of his knowledge, and by his perfect command of temper. Hansard does not record (we will make the assertion) a single line of his that could give offence to any human being. Accordingly he always was listened to with great attention by the Lords. He had chosen for the motto of his arms the words suum cuique, and his whole public life seemed to be occupied in realizing the principle of them, as we believe his distribution of his church patronage while Commissioner of the Great Seal tended among other more important acts of his life to show. His supporters 11 Vern. 347. 2 See Powell v. Grigby, 3 Cla. & F. 103. 3 14 Hans. Parl. Deb. 1111. were also chosen with an apparent reference to qualities he sought to make his own. They are thus blazoned. Dexter a female figure representing Fortitude, vested gold, the zone and sandals gules, mantle azure, her exterior arm resting on a Tuscan column proper; sinister a female figure representing Prudence, vested azure, the zone mantle and sandals gules, in the exterior hand a mirror, entwisted by a serpent, all proper. He died at Tonbridge Wells of a paralytic seizure on Good Friday last, having resigned the Rolls only a few days before, and refused the Great Seal some months previously. He was buried April 24, 1851, in the benchers' vault of the Temple Church, hard by the remains of Sir W. Follett, the funeral being conducted with the greatest plainness, agreeably to his own wishes and to the simplicity and absence of parade that he loved in life. He leaves one daughter, Jane Frances, but no heirs male of his body; the title consequently becomes extinct. J. G. Notes of Leading Cases. EQUITY. INJUNCTION UNDER THE LANDS CLAUSES CONSOLIDATION ACT, 1845, SECTION 68. The London and North-Western Railway Company v. Smith, 1 M'N. & Gor. 220; The East and West India Docks and Birmingham Junction Railway Company v. Gattke, 2 M'N. & Gor. 155. THESE cases relate to a subject of great practical importancethe circumstances under which equity will interfere to restrain the owner of lands alleged to be injuriously affected by the execution of the works of a company, from enforcing against the company the summary remedy provided by the 68th section of the Lands Clauses Consolidation Act, 1845. The judgments call for further notice on account of their discrepancy. Previously to the act the remedy of a party claiming compensation for injuries occasioned by the execution of the works of a company was by mandamus, requiring the company to issue a precept to the sheriff to summon a jury to settle the amount of compensation; and upon the return to the mandamus the preliminary question of the title of the claimant to compensation could, if disputed, be discussed and determined. To diminish the inconvenience supposed to be incident to the proceedings by mandamus, the 68th section of the act provides a summary remedy for parties "entitled to compensation," enabling them to have the same settled either by arbitration or by the verdict of a jury. If the party "so entitled as aforesaid" desires to have such question of compensation settled by a jury, he is at liberty under this section to give notice to the company, stating the nature of his interest in such lands, and the amount of compensation claimed, upon which the company are either to pay the amount claimed, or within twenty-one days to issue their warrant to the sheriff to summon a jury "for settling the same.' In default, they are liable to pay to the party "so entitled as aforesaid" the full amount of compensation claimed, to be recovered with costs by action. The language of the act gives these summary powers to persons "entitled to compensation," and the |