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WE are grieved to announce the death of Mrs. Harriet

Carmichael, widow of the late Editor of this Magazine, Charles Henry Edward Carmichael. She died at Fulham on the 13th day of April last, after a lingering illness.

The perusal of an interesting article on “Legal Entomology,” in the Law Times of 24th October, 1896 (by Mr. R. V. Rogers), suggests that there is a considerable amount of literature on the subject of prosecution of the lower animals, and even of inanimate things, for what in the case of human beings would have been called crimes. Mr. Rogers gives instances of prosecution of ants and beetles in Brazil and Italy, the Court going so far as to assign counsel to the insects. The writer has now before him two curious books full of historical detail, the one is modern, D'Addossio, Bestie Delinquenti (Naples, 1892). The other is older and very quaint in its title and contents, P. Ayrault, Des Procez faicts au Cadaver (sic), aux Cendres d la Mémoire, aux Bestes brutes, Choses inanimées, et aux Contumaux (Angers, 1591). The earliest recorded instance is perhaps the familiar one in Exodus xxi., 28: “If an ox gore a man or a woman that they die, then the ox shall be surely stoned.” In Attica the case of the axe mentioned by Pausanias and Porphyry

is curious. It was arrested and brought to judgment for the murder of the sacred ox of Zeus Polieus, and condemned to be cast into the sea. The legend is fully discussed by Mr. Farnell, Cults of the Greek States, i., 56. This and similar cases are also reviewed by Mr. ]ustice O. W. Holmes, Common Law, 7, and by Mr. W. Andrews, Legal Lore. The former learned author shews clearly that they proceed from the view that vengeance and not indemnity was the object of primitive delict-process. The owner of the offending thing might get rid of his liability by making noxze deditio in order that the injured person might have something to wreak his vengeance on. The Admiralty procedure in rem is perhaps the last survival of the principle in modern English law. Since the abolition of the law of deodand the ship is proceeded against by name, and she carries with her her liability into whatever hands she passes (The Bold Buccleugh, 7 Moo. P.C., 267). The principle of the ship as a noxa is expressed in very significant words by Bowen, L.J., in a later case. The learned Lord justice says: “ Damage done by a ship means done by those in charge of a ship, with the ship as noxious instrument” (The Vera Cruz, 9 P.D. 101).

In the course of an article, “ De la forme que doivent revétir les testaments rédigés a l’étranger par des Francais," the first instalment of which appears in the journal du Droit International Privé, 1897, p. 78, Professor Maurice Colin states, as a matter clearly settled, that the will of a Frenchman, made and duly attested in the English form in England, is valid in France under Art. 999 of the Code as a testament “par acte authentique, avec les formes usitées dans le lieu ou cet acte sera passé.” Frenchmen owning property in England willbe interested to know that, if M. Colin’s statement be correct, the simplest way .of

making a testamentary disposition which will be valid as to all kinds of property, whether in England or France, will be to take the opportunity, when in England, of making a will in the English form. Such a will, besides being valid for all purposes in France, will pass immovables in England, which a “holograph ” will, wherever made, will not in any case, and a will “par acte authentique” in France will not, necessarily, pass (see Arts. 970-974). It will be valid in England as a disposition of movables whether the Court holds the testator’s domicil to be English or French ; if English, cadit qnestio,—if French, the testament will be valid, not because loans regit actum, but as being in a form approved by the testator’s personal law as applicable to the circumstances of his particular case. The fact that the Frenchman was domiciled in England would not, it seems, put his case outside of Art. 999, so far as the application of that Article to awill made by him in England in English form, and sought to be established in France, is concerned (see Art. 1,000, and cf. In bonis Lacroix, 2 P.D. 94)- It may be added that if the testator had divested himself, under Art. 17, of his French nationality by becoming a naturalised British subject, and then made his will in England in English form, such will would be valid in France as well as in England (In bonis Lacroix) ii fortiori.

What is “ a pure and unadulterated accident?” _]udge Austin at the Bristol County Court on March 23rd last, in the case Skinner v. Gould, held that “the case fell into the class of pure and unadulterated accidents.” It was a casein which (as appears by the report in a local newspaper) the plaintiff claimed damages for serious personal injuries alleged to have been caused by the negligence of the defendant in having been knocked down by one of defendaut’s cabs whilst he was walking on the foot pavement in a public street, when the driver, in order to avoid a tram-car which was coming in the opposite direction, pulled the left rein and swept the plaintiff off the pavement so that he fell under the cab, the horses’ feet striking him just above the ankle, and both wheels of the cab passing over his thighs. We should have thought that this was as clear a case of negligence on the part of the driver as could well be imagined. judge Austin held that “negligence on the part of the driver was not proved, and the case fell into the class of pure and unadulterated accidents,” and judgm

was given for the defendant! It would have been interesting to have heard the opinion of the Judges of the High Court on this new exposition of the law of negligence, had the case come before them on appeal, and perhaps the converse of an impure and aclulterated class of cases would

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THE power of the Lord High Admiral of England is not

only of a "naval character, but is also judicial and ministerial. We are apt to forget this, accustomed as we are to the predominant naval jurisdiction. The same power is still vested in the Commissioners for executing the Office of Lord High Admiral. From very early times, and if we may credit the Black Book of the Admiralty (Vol. I., p. 64), as early as the reign of Henry I., Sessions were held by the Admiral. Again, the Ordinance of Grimsby, which, according to the same authority, was made in the reign of Richard I., evidences that a system of Admiralty jurisdiction was then in full force, that the Admiral was distinctly recognised, that his lieutenants were duly nominated, and that the acts of each and every

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