The Bar of the Cour de Cassation is separately constituted. We have already said that, by the law of judicial organisation of 1832, the advocates of the Bar of Cassation are ministerial officers, who alone have the right of pleading before the Supreme Court. They can plead before all the Courts in the kingdom. They are named by the King on the commendation of the Court, and ought to be Doctors of Law of at least six years' standing. Their number (in fact twelve) is regulated by the Government on the advice of the Court. They are sworn in before the Court. A decree of 1836 contains the regulations for the Discipline of the Bar of Cassation. Each year the general assembly of the Order names a bâtonnier and a council of five, including the bâtonnier and the secretary. The Council prepares the roll of the Bar of Cassation. It is able to inflict the disciplinary punishments of warning, censures and reprimand, subject to appeal to the Court of Cassation.

The general rule is, that the advocates of any one of the three Courts of Appeal have audience in the Court of Cassation.

In order to be inscribed on the roll it is necessary to have taken a degree in law, and on the presentation of a senior advocate, to have sworn before the Court of Appeal an oath of fidelity to the king and the laws of the Belgian people, not to say or publish anything contrary to law or good conduct, the safety of the State or the public peace, to be never wanting in respect to the tribunal and to the public authorities, and not to counsel or defend a cause except that conscientiously believed to be just.

The applicant must, moreover, have completed three years of "stage," or what we should call pupillage. This course involves three legal obligations-diligent attention at the Courts, duly taking part in the proceedings in connection. with the office for the gratuitous assistance of poor persons, and a careful study of rules governing the practice of the

profession. The stagiaires for the time being are divided into four sections, each controlled by a member of the Order with the assistance of four colleagues, and in this way takes place the allocation of an adviser to any indigent person seeking legal assistance. It is the rule, with scarcely any exception, that each stagiaire is attached to a senior member of the Bar, and works under his direction. The actual number of cases in which gratuitous assistance is given in any one year at Brussels alone approaches 1,500, and regarding the gratuitous defence of necessitous persons at the same place and period, the figure is about 1,200.

Such being the history and such the constitution of the Bar in Belgium, it now remains to add something regarding the rules which govern the practice of the profession. It may generally be said that those rules range themselves under the following heads: the obligation of honour in the conduct of cases, which is a matter which affects the Court and the State as well as his client; of independence in dealing with them, which is a matter which affects the advocate himself; of disinterestedness in regard to their result, which is a matter which affects the client; and of confraternity in regard to the other members of the profession.

Under the first head come all matters with regard to the maintenance of the obligations which are the essential conditions of admission to the Roll of Advocates. Nothing ought to be done, or said, or published, contrary to the law, to public manners, to the safety of the State, to the preservation of public peace. There must be no absence of the respect due to the Courts and to public authorities. His independence is absolute. With the sole condition of respecting the laws and customs of the realm, he can think, say, or write, what he thinks best.

An advocate must respect the secret of the confidences reposed in him by his client; what comes to him as an advocate belongs only to him who consults him. We may

take it, that in this regard, the rule of the Bar of France obtains in Belgium, and that the advocate even freed by his client from professional secrecy, although able to give evidence regarding facts which he has known as an advocate, remains sole judge in his conscience, from the point of view of knowing to what extent and in what circumstances he ought to make any deposition.

It is obvious that the advocate ought not to intervene. in operations contrary to the dignity of the profession. It will be seen that this gives rise to questions of fact which under the circumstances raised in the controversy of 1854, to which we have before adverted, are not easy to settle; but the general sense of the profession in Belgium has known how to interpret this rule firmly and yet sufficiently stringently. It would, however, be considered as an exception to the rule against the acceptance of an agency, where the service in question is one which is undertaken in the interests of the family of the advocate, or even when he occupies himself gratuitously in the interests of a friend, of a confrère, or of a colleague.

An advocate ought to recommend himself only by his work, his knowledge, his pains and devotion to the business of his client. He is forbidden to seek to extend his clientèle, either by open advertisement, or by direct or indirect solicitation.

The rules regarding the professional remuneration of the advocate are founded on the bed-rock rule that the knowledge, eloquence, and reputation of an advocate are not the subject of a mercantile transaction. Any remuneration ought to be a free gift, the voluntary recognition of the gratitude of the client, although as we have said, Belgian jurisprudence recognises the right of the advocate to recover his fees by action at law. Gratuities dependent on the result of the process or based upon the amount recovered are not regarded as the proper subject of an

advocate's acceptance. It is regarded as having all the marks of an agreement de quota litis which has been severely forbidden to the Bar since the most early times, having for its baneful result the loss of the independence of an advocate by associating him with the chances of the litigation.

Confraternity is a professional duty, whether it is shown. in respect to seniority or the observances of the decisions of constituted professional authorities, the interchange of courtesies, the safeguarding of the interests of professional confrères, the frank disclosure of documents relating to litigation between advocates opposed to each other at the audience in chambers at every point of contact.

It will be obvious from the foregoing that the Bar in Belgium is an institution strong and increasing in strength. The successive steps by which it has gained the complete freedom which it now enjoys, have not been unaccompanied by strenuous internal effort for the promotion of the training of its members, and towards the formation of even wider organisations for the advancement of the welfare of the forensic profession.

The Conférences du Jeune Barreau are directed to the training and progress of the younger members of the order. We have adverted above to the efforts for the codification and the recognition of the principles of Public International law, which, considering the status of Belgium as a neutralised State (and therefore one in which International law can be pursued and perfected with comparatively little national bias), have done much to promote the perfection of that advancing science. In the direction of the general interests of advocates themselves, considering them as jointly pursuing in their different national spheres common objects towards the general advancement of juridical ideas, they have equally been active and in the right direction. In 1886 the administrative committee of the Council arrived at a resolution which had for its objects the convening at

Brussels of a congress of advocates of all the different portions of Belgium, for the purpose of taking into consideration a project for Belgian Federation. A congress at Brussels followed in that year. The project was adopted and the statutes of the Federation framed in the presence of over 100 representatives from different parts of the country. The principal objects were set forth as being the furthering of the interests of advocates, regarded as one body in many provinces, and the development of fraternal relations between the Orders of advocates and the individuals composing those Orders throughout the whole country; and in particular, excluding from all discussions any burning political or local questions which might distract the union for the general good, both for the profession and the general advantage of judicial administration. Successive general meetings were held at Brussels, Liège, Antwerp, Mons, Ghent, Charleroi and Louvain. Closer union between the members of each Order and the Orders themselves, registration of documents, the subject of legal process, the reform of tribunals of commerce, the evidence of children, the use of the Flemish language, the relations with the other branch of the profession, judicial assistance to poor persons, professional avocations and attendant occupations, the method of recovery of remuneration, rights of audience, illicit exercise of the profession of an advocate, assistance to distressed members, relations with the Bars of foreign countries, reform of the system of law teaching, the jury system of judicial reorganisation. These are amongst the many questions which were taken into consideration, and, of necessity, in many of these discussions, old prejudices had to be encountered and new ideas ventilated. To sum up its objects I refer to the pamphlet of M. Emile Laude of Brussels on La Fédération des Avocats Belges, in which he describes its objects as "participer ainsi à la défense des prérogatives du barreau dans