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(i.) P. C.-Patent-Assignee-Prolongation-Patents, &c., Act, 1883.-An assignee of a patent, which he has bought as a commercial venture, has no claim to prolongation, because the patent has been unremunerative to him. In re Hopkinson's Patent, 75 L.T. 462.

(ii.) C. D.-Variation between Specifications-Rights of Patentee.-A provisional specification need not give more than a rough description of the invention, and need not describe details of its advantages or of the manner in which it is to be carried out. Where the invention consists of several parts, every part need not fulfil all the objects claimed, and advantages not expressly mentioned may apply to some of the parts. In the complete specification, the inventor may refer to the manner in which the invention can be applied to discoveries made by other persons since the date of the provisional specification. A patentee is entitled to the benefit of his invention if it is applied by other inventors to purposes not contemplated by him.-Pneumatic Tyre Co. v. East London Rubber Co., 75 L.T. 488.

(iii.) C. A.-English Patent-Infringement-Goods made abroad and sent through Local Agent to English Customer-Injunction.-Where goods infringing an English patent were made abroad, and handed by the manufacturers to a forwarding agent at the place of manufacture who sent them by post to a customer in England, and received payment through the post, the Court in an action by the owner of the English patent, granted an injunction restraining the foreign manufacturers or their agents from importing or bringing into or delivering in England, goods infringing the patent, or from selling or supplying, or assisting or taking any part in such importation or delivery.-Badische Anilin und Soda Fabrik v. Johnson & Co. and the Basle Chemical Works, Bindschedler, 76 L.T. 21.

Poor Law:

(iv.) C. D. & C. A.-Loans to Guardians-Repayment before fixed Date— Poor Law Loans Act, 1871 (34 Vict., c. 11), s. 2.-Guardians of a poor law union had borrowed sums of money before the date of the Poor Law Loan Act, repayable in periods not exceeding thirty years by annual instalments which included interest as well as principal. The instrument securing the loan contained a stipulation that with the consent of the lenders the whole sum might be repaid before the stipulated period. The Poor Law Loan Act enables guardians to pay off loans before the stipulated period on obtaining an order from the Local Government Board, but the Act has a proviso that loans outstanding at the date of the passing of the Act should not be paid off without the consent of the lender. Held (dissentiente, Smith, L.J.), reversing the decision of the Court below, that the Guardians could not even with the sanction of the Local Government Board redeem the loan prior to the stipulated date without the consent of the lender. -The Guardians of the Poor of the West Derby Union v. The Metropolitan Life Assurance Society, L.R. [1897] 1 Ch. 335; 75 L.T. 412 and 76 L.T. 73.

(v.) C. A.-Guardians-Judgment for Costs in Supreme Court-Date from which time runs-Poor Law (Payment of Debts) Act, 1859, s. 1.-Costs of an appeal which guardians are ordered to pay are not a "debt " within sect. 1 of the Poor Law Act, 1859, till after taxation, and the time for payment runs from the date of allocatur.-Manchester, Sheffield, and Lincolnshire Railway v. Guardians of Poor of Doncaster Union, L.R. [1897] 1 Q.B. 117; 75 L.T. 472.

(vi.) Q. B. D.-Settlement by Residence-Absence in a Hospital-9 & 10 Vict., c. 66, s. 1-Divided Parishes Act, 1876 (39 & 40 Vict., c. 61), s. 34.Where a man had resided in one parish from July, 1892, to April,

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1896, but during the months of May, June, and July, 1895, had been a patient in a hospital outside the parish, it was held that he had not acquired a status of irremovability in the parish of residence within the terms of the Divided Parishes Act, 1876.-St. Olave's Union v. Canterbury Union, L.R. [1897] 1 Q.B. 438; 76 L.T. 88.

Poor Rate:

(i.) Q. B. D.-Lighthouse-Dues.-Dues received on account of a lighthouse do not come under consideration in assessing its rateable value. -Commissioners of Port of Lancaster v. Overseers of Poor of Barrow-inFurness, L.R. [1897] 1 Q.B. 166.

Practice :

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(ii.) C. D.- Solicitor· Costs · Administration Action-Person Liable Solicitors Remuneration Act, 1881--General Order, s. 7.-Solicitors to a testator, who were also solicitors to his executor, delivered a bill of costs to the person having the conduct of an action for the administration of the deceased's estate. The taxing-master's certificate was not made out for some time, and the solicitors claimed interest. Held, that the person liable under sect. 7 of the General Order was not the person having the conduct of the action, but the executor; and no demand having been made upon him, the solicitors were not entitled to interest. In re McMardo; Penfield v. McMardo, L.R. [1897] 1 Ch. 119; 75 L.T. 576.

(iii.) P. D.-Collision--Writ against Foreign Corporation-Service on Agents' Manager-O. ix., r. 8.-Where a foreign corporation paid a commission and annual allowance to an agent who rented offices in London, the service of a writ upon the agent's manager was held not to be service upon the corporation within the meaning of O. ix., r. 8. -The Princesse Clémentine, L.R. [1897] P. 18; 75 L.T. 695.

(iv.) C. D.-Service Out of Jurisdiction-Power of County Court and of High Court-O. xi., r. 2.-A county court action had been transferred to the High Court on the ground that the value of the estate concerned exceeded the county court limit. Service on the defendant, resident in Scotland, had been directed under O. li., r. 23, of the C.C. rules; and the defendant had answered interrogatories before the transfer. Held, that under the rule in question service out of the jurisdiction could in the circumstances of the present case be ordered by a county court; though under like circumstances these would be under the Supreme Court rules, O. xi., r. 2, a restriction on the High Court to "have regard to the comparative cost and convenience of proceedings in England" when there was a concurrent remedy in Scotland. And that as it would be unfair for a plaintiff to obtain an advantage by bringing an action in a wrong Court, the defendant should have an opportunity, there having been no waiver, to give evidence that the High Court has no jurisdiction without considering the question of cost and convenience.-Wood v. Middleton, L.R. [1897] 1 Ch. 151; 75 L.T. 480.

(v.) C. A.-Judgment under O. xiv.-Appeal from Chambers is to Court of Appeal. An appeal against an order of a judge in chambers giving leave to extend final judgment under O. xiv., r. 1, must be brought in the Court of Appeal, as it is a "matter of practice and procedure within sect. 1, sub-sect. 4, of the Judicature Act, 1894.-Cannon Brewery Co. v. Gilbey, 75 L.T. 407.

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(vi.) C. A.—0. xiv., r. 2—Summons for Judgment—Dismissal on Technical Objection-Second Summons-Res Judicata.-Unconditional leave to defend was given on a summons under O. xiv. in consequence of a

technical omission in the writ. The writ was amended and a fresh summons taken out, when the leave to defend was made conditional on payment into Court of the sum claimed. Held, on appeal, that the Court had power to adjudicate upon the second summons.-Dombey and Son, Limited (in_liquidation) v. Playfair Bros. and Others, L.R. [1897] 1 Q.B. 368; 75 L.T. 676.

(i.) C. A.-Suing in formâ pauperis-Affidavit-Case and Opinion Exhibits— Right to Inspect-O. xvi., rr. 23 & 24.—A defendant is not entitled to inspect the case and opinion of counsel which are made exhibits to the affidaxit of an applicant for leave to sue in formâ pauperis.—Sloane v. The British Steamship Co., Limited, L.R. [1897] 1 Q.B. 185; 75 L.T. 542. (ii.) C. D.-Third Party Procedure-O. xvi., r. 48.-On the ground that a banking account into which trust funds had been paid was the partnership account of a firm of solicitors of which a deceased trustee had been a member, the defendant a co-trustee of the deceased, obtained leave, in an action for alleged breach of trust, to serve a third party notice on the surviving members of the firm. Held, that as the claim of the defendant was not for indemnity, for, whether the action against him succeeded or failed, he could if the firm was liable pursue his remedy against the surviving partners, the third party notice must be discharged.-Wynne v. Tempest, L.R. [1897] 1 Ch. 110; 75 L.T. 624.

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(iii.) H. L.-Statute of Frauds--Pleading- ·O. xix., rr. 4, 15, 20.-The respondents were printers of a newspaper, and the appellant was the publisher and also the managing director of a company who were the proprietors of the paper. An action in which the respondents were plaintiffs, was brought on a guarantee signed by the defendant, the present appellant which ran, If you will bring out the present number, I will repeat my guarantee to see you paid in full," and the question arose whether the document guaranteed payment for a single number, or for the amount due for printing this and other numbers. At the trial the plaintiff gave evidence, that the document was in substitution of a parol guarantee, previously given for the whole debt, and the defendants not having pleaded the Statute of Frauds (which would have been irrelevant to the Statement of Claim), were held not entitled to rely on the statute. Held, reversing the decision of the Court below (see Vol. 22, p. 22, iv.) that if the evidence was admissible, the defendant was not debarred from relying on the statute by the fact that he had not pleaded it.- Brunning v. Odhams Brothers, Limited, 75 L.T. 602.

(iv.) C. A.-Payment into Court before Defence-Defence denying Liability—— O. xxii., rr. 1, 4, 6, 7. —A defendant paid a sum into Court and served notice that it was sufficient to satisfy the plaintiff's claim. A month afterwards the defendant delivered a defence denying liability, and the plaintiff joined issue. Held, that the defence and the joinder of issue should be struck out, and that the only question for the Court was damages.-Dumbleton v. Williams, Torrey, and Field, Limited, 76 L.T. 81.

(v.) C. D.-Plaintiff Improperly Joined-Action Discontinued―Jurisdiction -Old Practice-0. xxvi., r. 1.—Solicitors of a company joined, without authority, the company with themselves as co-plaintiffs in an action and costs were incurred. On a notice of motion by the company to strike out its name, the solicitors gave notice to discontinue the action, and took the objection that as the action was gone, the Court had no jurisdiction. Held, that there being no rule on the point, the old practice in Chancery prevailed, and that the Court had jurisdiction to deal with the motion.-Gold Reefs of Western Australia v. Dawson, L.R. [1897] 1 Ch. 115; 75 L.T. 575.

Cambridge, of Lincoln's Inn, Barrister-at-Law. Cambridge: at the University Press. 1897.

To those who desire to penetrate the deeper waters of our early history, the publication of this book will prove invaluable. Domesday Book must be mastered to understand our English History. When the Conqueror charged his barons, legates, and justices to collect a descriptio of his new realm, various documents were compiled for that purpose; of which we have two manuscript volumes, known as the Domesday Book. Little Domesday, as the second of these volumes is sometimes called, deals with Essex, Norfolk, and Suffolk; the first volume relates to the rest of England. We also have the Inquisitio Comitatus Cantabrigia, the Inquisitio Eliensis, the Exon Domesday, an account of Cornwall and Devonshire, and of part of Somerset, Dorset, and Wiltshire, and the Exchequer Domesday. The Domesday Book is not a treatise on law, although it contains mention of some provincial privileges, nor is it a register of title; but it is a Geld-book. Professor Maitland elaborates many obscure questions concerning Book-land and the Landbook, Sake and Soke, Boroughs, Manor and Vill, and the Village community, to say nothing of Domesday statistics. Excellent is the compilation, and of immeasurable value to students of archæology.

Encyclopædia of the Laws of England, being a new Abridgment by the most eminent Legal Authorities. Under the general editorship of A. WOOD RENTON, M.A., LL.B., of Gray's Inn, and of the Oxford Circuit, Barrister-at-Law. Vol. I. London: Sweet and Maxwell, Limited. Edinburgh William Green and Sons. 1897.

This, the first volume, commences with Abandonment and ends in Bankruptcy. Not a happy omen certainly. The scheme, however, is a well considered one, and the publishers have acted wisely in securing the services of Mr. A. Wood Renton for their editor, a gentleman who has already had experience in literary supervision, being for some time editor of our contemporary, The Law Journal. The articles as a rule are not too lengthy, and thereby are the more serviceable. They are with some exceptions succinct enunciations of the law and trustworthy. The articles by Mr. W. F. Craies are especially good, although we notice from the title of his

second article, that he has been forced to deal with some unsavoury subjects. Sir Walter Phillimore has written an article on Affreightment, interesting in its character, but rather too verbose; the same may be said of an article on Absolute Privilege by Mr. W. Blake Odgers, Q.C., which is remarkable so far as the preliminary text is concerned for its omission of all the earlier authorities upon which it is founded, and for a rather full verbatim adoption of an extract from the judgment of Lopes, L.J., in a modern case decided in 1892 (The Royal Aquarium v. Parkinson), which, however, was not one of absolute privilege, but of qualified privilege, depending on the absence of malice. Further, we regret to notice that in his reference to Parliamentary proceedings, he puts forward, after a quotation from the Bill of Rights, as his leading authority, a case decided in 1887 in the Irish Courts (Dillon v. Balfour); whereas, privilege is founded on the Statute 4 Henry VIII., c. 8, reference to which is entirely omitted, as also the leading cases on the subject, viz.:-R. v. Lord Abingdon and R. v. Creecy. Mr. Barclay has written on Ambassador and Alliance in a fairly creditable manner; and the other writers have done their part as a rule well. The work should commend itself to the profession as a useful epitome of the Law of England, up to date, and for ready reference. Perhaps the most unfortunate step taken by the publishers was in asking Sir F. Pollock, Bart., to write what he terms a "General Introduction to this volume. Such an introduction was unneeded, for "good wine needs no bush." The so-called General Introduction is not calculated to bring additional credit on the work, and it would have been better to have omitted it.

Select Cases in Chancery. A.D. 1364 to 1471. Edited for the Selden Society by WILLIAM PALEY BAILDON. London: Bernard Quaritch.

1896.

The first part of this volume contains a selection of early Chancery petitions, while the second part deals with selected petitions, French petitions of various dates, or undated, and English petitions of various dates. The Petition or Bill varies little from those known in the Courts of Chancery before the Judicature Act, 1873. They are almost invariably in French until the reign of Henry V., when English forms became

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