THE CHANCERY CAUSE LIST for the ensuing sittings is unusually heavy. There are no fewer than 459 causes in the books of the five chancery judges of first instance; while last Easter there were but 334. The Court of Appeal is also likely to be overburdened with work, the list containing 207 appeals in all, as compared with 133 last Easter. This latter increase is, however, due to the interference of the assizes with the attendance in the Court of Appeal of some of the Lords Justices. Last Easter there were but nine appeals from the Common Law Divisions, and now there are seventy.

THE PERMANENT STAFF to serve in the Central Office of the Supreme Court, established by the Act 42 & 43 Viet. c. 78, has now been formed, and the business of that office, as distributed among the several "departments" specified in the schedule to the Rules of Court, which

came into operation on the 22nd of December last, will now proceed without further interruption. It will be some little time, perhaps, before the several officers-chancery and common law-now brought together will have adapted themselves to their new duties, especially as many matters of daily practice are greatly affected by the new Rules of Court which are to come into operation on the 6th inst. Still, the concentration and amalgamation now effected will, no doubt, eventually prove both convenient to the profession and beneficial to the suitors.

THERE ARE INDICATIONS that progress is being made towards the removal to the Royal Courts of Justice of the business of the Chancery Paymaster. The rooms in the new building in which that business is to be conducted are already notified on the walls of the ground-floor corridor; four divisions only, however, being at present provided for. But we observe that blanks are left for notifying two more divisions, and from this we infer that the question of having six divisions instead of four is still pending between the paymaster and the Treasury. It is not likely that the removal into the new building will be accomplished in time to enable the April dividends to be paid there.

THE NEW PROVISIONS as to probate and administration duty call for the special attention of our readers. The Customs and Inland Revenue Act, in which they have been incorporated, is not yet in print, but there seems to have been no alteration in the Bill, and under its provisions (1) the new scale of probate duty will be payable in all cases where application is made for probate or letters of administration after the 1st of April, although the testator or intestate may have died before that date; and (2) upon all applications for probate or letters of administration after the 1st of April an account of the particulars of the personal estate in respect of which the probate or letters of administration is or are to be granted, and of the estimated value of such particulars, must be delivered. Forms for this account may be had, we believe, at the law stationers, and these forms will give a better idea of the kind of account than any explanation here. The bill also provides that where any legacy or succession duty is presumptively payable in respect of any interest in expectancy upon the determination of a life or other temporary interest in possession in a legacy, or residue, or in personal property comprised in a succession, and the duty (if any) payable upon the life or other temporary interest shall have been fully paid and satisfied, the Commissioners of Inland Revenue, upon the application of the executor or trustee or other person who would be accountable for the duty in respect of such interest in expectancy if it were then in possession, may commute the duty for a certain sum to be presently paid. And it is also provided that "when an executor, administrator, or trustee shall have given notice in writing to the Commissioners of Inland Revenue for any claim to legacy duty or succession duty in respect of any fund in his hands which he intends to distribute, and shall have delivered to the commissioners all particulars which they may require in order to ascertain the existence and extent of any such claim, he shall be at liberty to distribute the fund amongst the parties entitled thereto, after satisfaction of any claims to duty made by the commissioners, and shall be entitled to receive from them a certificate discharging him from his liability to any duty in respect of the fund.”

THE NEW RULES OF COURT, which we print elsewhere, put an end to the procedure under the Bills of Exchange Act; but the proposed rule abolishing administration summonses, to which we have before referred, has been struck out. Most of the rules have reference to arrange. ments rendered necessary by the constitution of the

Central Office. Thus it is provided that writs, instead of issuing out of the offices of the several divisions, shall now be issued out of the Central Office; and appearances are to be entered in the Central Office. The last clause of rule 7 extends to all cases the provision of order 12, rule 6b, requiring a defendant who appears elsewhere than where the writ is issued, to give notice of appearance to the plaintiff. This is, we suppose, intended to save plaintiffs the trouble of searching for appearances before they take proceedings in default of appearance. Rule 11 removes a doubt as to the jurisdiction of district registrars. The new rules as to evidence are mainly taken from the chancery procedure. It will be observed that the proposed rule, on which we have before commented, requiring affidavits to be filed before they are used, instead of afterwards, is adopted. The new rules as to applications at chambers embody the regulations made in 1878. Rule 34 provides a form of summons for use in all the divisions, based upon that in use in the chancery chambers. The new rule as to time (rule 28), allowing the time for delivering or amending any pleading to be enlarged by consent in writing of all parties, without application to the court, should be noticed; with regard to this it will be observed that by rule 65 it is provided that the costs of an application to extend the time for taking any proceeding shall, in the absence of an order by the court or a judge, be in the discretion of the taxing-master; the object being probably mainly to check applications to the court for time for delivering or amending pleadings. To some other matters in the rules, we propose to draw attention next week.

In our list of lawyer candidates in our last week's issue we inadvertently omitted to print the name of Mr. Dodds in italics. It is scarcely necessary to say that Mr. Dodds has been in the House since 1868.

It is stated that at the recent Guildhall sittings, of the 439 cases in the list, 24 special jury and 46 common jury cases were tried, 23 special jury and 51 common jury cases were withdrawn and struck out, 118 special jury and 40 common jury cases were stayed, 32 special jury and 26 common jury cases were made remanets by order or consent, while 21 special jury and 58 common jury cases were not tried from want of time.

On the 25th ult. the following new Queen's Counsel were sworn in before the Lord Chancellor, in his private room in the House of Lords:-Mr. W. Shaw, Mr. F. Bailey, Mr. E. Rodwell, Mr. F. W. Gibbs, C.B., Mr. E. Swetenham, Mr. W. C. Beasley, Mr. J. J. Aston, Mr. F. C. J. Millar, Mr. Lumley Smith, Mr. W. Potter, Mr. J. Underhill, Mr. J. E. W. Addison, Mr. A. R. Jelf, Mr. Crossley, Mr. Edward Clarke, Sir W. Charley (Common Serjeant), and Mr. Petheram. Mr. Allen, and Mr. G. Browne, the other two new "silks," were absent.

A "Registrar of County Courts" writes to the Times with reference to the report of the remarks of Mr. Justice Grove on the subject of appeals from county courts under the Act of 1875, wherein rather a sweeping charge is made against the general body of county court judges. Although the provisions of the 6th section of the Act require a county court judge to make a "note of any question of law raised at a trial, and the facts in evidence in relation thereto and of his decision thereon," at the request of either party during the trial, the fault of their non-observance rests, not with the judge but with the parties themselves, who almost invariably ignore the section entirely. Advocates are generally too intent on arguing out a point of law with the judge, and omit to require the requisite note to be taken during the trial, but if the judgment be adverse application is made, after the trial is over, for a copy of the judge's notes of the whole trial, which contain a quantity of evidence quite useless for the purposes of appeal, and frequently none at all relating to the point to be raised. In some cases the judge may have made no note at all. It was with a view of obviating these two extremes that section 6 was enacted, and it is almost entirely owing to the parties themselves not complying with its provisions that any aifficulty arises in carrying them out.

THE ENFORCEMENT OF SECRET VOTING. "THERE is no doubt," said Mr. Justice Mellor in the Bolton case (2 O'M. & H. 138), "that the Legislature, when it passed the Ballot Act, did intend that there should be a perfectly secret mode of voting, as far as any instrumentality or machinery which it could provide could make it so.' "" large and increasing number of cases, either by the aid There is as little doubt that in a of canvassing or without it, the mode in which the vote been given, is divulged. First, there is the class of is about to be given, as well as the mode in which it has ardent politicans who loudly proclaim their leanings. Secondly, there is the class of easy-going voters who, falling in readily with the machinery of canvassers, post one letter to say that they are about to vote in a par ticular way, and another to say that they have voted in that way. That the promise of support is frequently broken is likely enough, and the breach of such promises is often highly justifiable, but it is absolutely impossible far false accounts are given of the performance of the to speak with anything but moral certainty as to how promise. We should be inclined to think that such false accounts are extremely rare, especially in the cases where the offer of 8 "railway pass has been accepted. Indeed, the system of railway passes issued, as they are, to voters who sign promises to vote for particular candidates, and requests for the pass accordingly, seem as much open to objection on the ground of infringement of secrecy as on the ground of corrupt practice. The substantial controversy in relation to the payment of travelling expenses is antecedent to the Ballot Act, and the statute of 1880, which has recently extended their legality, does not appear to legalize railway passes more than they were legalized before, inasmuch as the statute repeals the 36th section of the Representation of the People Act, 1867, "so far as regards the conveyance of voters within any borough." However, it may be useful at the present juncture to see exactly what it is which the Ballot Act prescribes as to infringement of secrecy.

It will be found that the statute is very precise and effectual as far as official persons and places are concerned. The crucial section is the 4th, which is a long and rather involved one. The opening paragraph, that 66 every officer, clerk, and agent in attendance at a polling station shall maintain and aid in maintaining the secrecy of the voting in such station" is very general, and would cover any form of offence, but its effect seems to be confined to the polling station. A second clause except for some purpose authorized by law, before the enacts that such officer, &c., "shall not communicate, poll is closed, to any person any information as to the name or number on the register of voters of any elector who has or who has not applied for a ballot paper or voted at that station." This clause also seems confined to the election itself. With regard to nonofficial persons, the enactment runs that " no person whosoever shall interfere with or attempt to interfere with a voter when marking his vote, or otherwise attempt to obtain in the polling station information as to the candidate for whom any voter in such station is about to vote or has voted, or communicate at any time to any person any information obtained in a polling station as to the candidate for whom any voter in such station is about to vote or has voted, or as to the number on the back of the ballot paper given to any voter at such station."

be

The polling station, therefore, is the only protected place, and this is because the voter is able to protect himself elsewhere by false statements, whereas at the polling station his statement could be verified. It is material to point out that by rule 21 the "presiding officer . . . shall regulate the number of electors to be admitted at a time, and shall exclude all other persons, except the clerks, the agents of the candidates, and the constables cn duty." This rule, however,

was held in Clementson v. Mason (L. R. 9 C. P. 209) not to have the effect of authorizing the exclusion of the candidate himself. With regard to the arrangement of the polling station, in the Drogheda case (2 O'M. & H. 203), the polling place consisted of two rooms with a landing between them. In one room the voter received his ballot-paper, and then passed through the landing to the other room, where he filled up the paper, and then returned across the landing to the first room with his ballot-paper. It is obvious that, although a policeman was stationed on the landing to prevent communication between the voters and other persons, the secrecy of the voting might have been interfered with; but there was no evidence that it was, in fact, interfered with. The election judge reserved a case as to the validity of the election on this point for the Irish Court of Common Pleas, but that court was equally divided.

THE CONTRACT TO PAY INTEREST ON PURCHASE-MONEY.

I.

We recently (ante, p. 287) endeavoured to ascertain the rule with regard to the payment of interest on purchasemoney on a sale of real estate when no time is fixed for completing the contract or for the purchaser taking possession, and when the contract is, therefore, naturally silent upon the question of interest. It may be worth while now to point out the principles regulating the matter when the contract is more explicit.

In the first place it is to be observed that, where there is a time specified for completion, the rule is clear that, although there be no express contract to pay interest, interest shall run, and the purchaser shall take the rents, from the day specified. But the modifications to which this rule is subject when completion is delayed make its application less easy than might appear. The cases in which the delay is due to the conduct of the purchaser may be dismissed with the observation that such delay does not affect the application of the rule-an observation important in this regard, that it indicates that the interest is always considered more valuable than the rents, otherwise we should hear as much in this case of a claim by the vendor to renounce the interest and retain the rents, as in the opposite case of delay by the vendor we hear of the purchaser's claim to renounce the rents and retain the interest. That in the latter case the purchaser has a right thus to postpone the day from which the account is to run is well settled; but it will be postponed only until the time when a good title was shown, and not until the day of actual completion (Jones v. Mudd, 1 Russ. 118; Binks v. Lord Rokeby, 2 Sw. 222), thus confirming the principle pointed out in our former article, that so soon as a good title is shown the change of interest is for all purposes, including the right to the fruits of the subject-matter of the contract, regarded as complete. But the purchaser's right thus to postpone the day from which the change of interest is to be regarded as thus operative must not be confounded with another right of equal importance to him in case of delay by the vendor. He may claim the rents from the time fixed by the contract, and may, nevertheless, discharge himself from his own liability to pay interest by giving the vendor notice that his money is appropriated to the purchase and lying idle. At least it is well settled (Kershaw v. Kershaw, L. R. 9 Eq. 56) that he has such a right where actual possession or receipt of the rents has been given to and accepted by him before completion, and although some doubt has been raised as to a purchaser's right to an account of rents when he remains out of possession, there is clear reason and sufficient authority in favour of the existence of such a right (Powell v. Martyr, 8 Ves. 145; Dyson v. Hornby, 4 De G. & S. 481).

The difficulty, however, of determining the purchaser's liability to interest where it is thus left to the operation

of the law, is small as compared with that which exists in deciding what it is when, as under the condition now usually adopted, he expressly contracts to pay interest from the time fixed for completion, if from any cause whatever the purchase be not then completed. And this is a point well worth some consideration, because it appears that in practice the dicta in some modern decisions are treated as having placed the purchaser under a contract containing such a condition in a position which is plainly unreasonable and which the decisions themselves, if we look to the actual effect of them, do not compel him to accept. Lord Cottenham, in De Visme v. De Visme (1 MacN. & G. 336), laid down an intelligible principle, which was in effect this :-The purchaser cannot pay his purchase-money until the vendor has delivered an abstract showing a good title; and, as the vendor failed to fulfil this duty at the time appointed, the purchaser must in some way be relieved from the payment of interest. If this contract to pay interest was (as his lordship thought) to be regarded as a contract to pay conditionally on the performance by the vendor of the acts which he, on his part, had undertaken to perform, and the words "any cause whatever were not meant to bind the purchaser to pay interest in the event of a failure in the performance of those acts, but were only applicable in the event of completion being delayed by some unforeseen event not provided for by the contract, there was an end to the claim to interest. If, on the other hand, the purchaser's contract was to be regarded, not as conditional, but as an absolute contract to pay in any event, he must pay; but the vendor's obligation was equally absolute, and the purchaser must be compensated in respect of the breach of it, the amount of compensation being determinable with reference to the amount of interest payable.

It is impossible not to feel that this is, as far as it goes, a logical view of the position. But at this point the cogency of Lord Cottenham's reasoning ceases. Н. said that it was immaterial which of the alternative constructions was adopted, a proposition which it is impossible to maintain. The purchaser had, in that case, appropriated his purchase-money and given notice of the fact. Now, it is clear that if the first construction was the right one, and the contract to pay interest was conditional, so that no liability under it commenced until the vendor had shown a good title, the purchaser's appropriation (being a dealing with the money before the liability arose) was no concern of the vendor's. Consequently, the loss caused by appropriating the money fell upon the purchaser, a loss not made up to him by any benefit from rents and profits, because his right to these, being considered as the correlative of his liability to interest, was postponed, together with that liability, till the time the title was shown. And this is the position in which Lord Cottenham in express terms placed the purchaser. But it is equally clear, on the other hand, that if the second construction was the right one, and the contract was an absolute contract to pay interest from the day fixed, whatever might be the vendor's default, but subject to a right in the purchaser to be compensated for loss caused by that default, then the purchaser's position should be wholly different. Paying interest, he would also take the rents from the day fixed, and he would be entitled to compensation in respect of the difference between the interest produced by the appropriated money and the interest which he had to pay. The first view results in a mere postponement of the day for completion, regardless of the loss thereby caused to the purchaser; the second view is in effect that the contract shall be carried out as from the day fixed, but that the purchaser shall be compensated (or what is the same thing, relieved from his own liability) to the extent of the loss accruing to him through the vendor's default.

These observations upon De Visme v. De Visme have been made because, though the case has been much discussed, the text-books usually referred to do not appear

to point out clearly the principles involved in that decision. When we pass to the later cases, we find that they generally agree in considering the condition as an absolute contract to pay (in accordance with Lord Cottenham's second construction), and not as containing an implied proviso that a title must be previously shown. Vice-Chancellor Kindersley said in Bannerman v. Clarke (3 Dr. 635): "I must take the words (that is, the words if from any cause whatever) in their natural and primary signification, and, so taking them, the meaning is prima facie that, if from any circumstances whatever, let them be what they might (and the parties could not foresee what events might happen), and whether they were circumstances within or beyond the control of the parties, if the purchase. money was not paid on the day named, interest should be payable." But it is manifest that, to set against this liability there must be some right in the purchaser to be indemnified against default in the vendor. Lord Cottenham called it a right to compensation from the vendor for breach of his contract. Latterly it has been the custom to say that the vendor may disentitle himself by his conduct to enforce this absolute contract which he has got. 66 If," continued Vice-Chancellor Kindersley, in the case just cited, "the vendor, having obtained such a contract, wilfully delays the completion of the contract, equity will say it was not the intention of the parties that he should so get the benefit of the contract, and will not allow the fraud of one party to compel the other to pay interest." That the vendor may thus disqualify himself for the benefit of his absolute contract is, therefore, clear. But, before leaving De Visme v. De Visme and going on to consider by what conduct he may do this, it may be well to notice that since that case there appears to be no reported decision of the Court of Appeal as to the position of the purchaser where the vendor is thus disqualified. Is he to be deprived of the rent, as Lord Cottenham deprived him, until he begins to pay interest; or is he, according to what is certainly the more rational view, to be merely relieved from his own liability? Of the three reported cases in the inferior courts, where the vendor has been held disentitled to the benefit of interest, the report in Robertson v. Skelton (12 Beav. 363) does not state which course Lord Langdale adopted; the other two cases (Wallis v. Sarel, 5 De G. & S. 429, and Weddall v. Nixon, 17 Beav. 170) being sales of properties reversionary in their nature, throw no light upon the point. But in Rowley v. Adams (12 Beav. 476) Lord Langdale said that he should have given the purchaser the rents if he had held him to be relieved from paying interest.

THE JUDICIAL STATISTICS AS TO CRIME. II.

IN the number of persons for trial in England and Wales in 1878, there was an increase of 482, or 3.0 per cent. upon the number for 1877. The total number in 1878 was 16,372 against 15,890 in 1877, 20,091 in 1868, and 16,674 in 1859. In 1878 the trials at the various courts were as follows:-County quarter sessions, 6,892; Middlesex County Sessions, 2,046; borough sessions, 3,425; circuit assizes, 2,819; and Central Criminal Court, 1,190; and the proceedings resulted in 3,864 persons being acquitted or discharged, 35 detained as insane, and 12,473, or 761 per cent. of the number for trial, convicted. The various convictions weredeath, 20; penal servitude, 1,634; imprisonment, &c., 10,218; reformatories, &c., 210; fine, or discharge on sureties, 391. Of the sentences to penal servitude, 14 were for life, 25 for periods of above 15 years, 71 for periods of between 10 and 15 years, and 1,524 for periods of 10 years and under. In 1,730 cases, the offenders would become liable to police supervision on liberation, in accordance with the provisions of the Prevention of Crimes Act, 1871. To the number of

sentences to penal servitude in 1878 may be added 4 cases in which the capital sentence was commuted into penal servitude for life. The number of executions was 15; and one man who had been sentenced to death was respited on the ground of insanity, and sent to the Broadmoor Criminal Lunatic Asylum.

The Crown cases reserved for the consideration of the Court of Criminal Appeal in 1878 numbered 15, against 21 in 1877, and 10 in 1876. There were no appeals from the assizes, only 2 from the Central Crimi. nal Court, and 13 from quarter sessions. In 10 cases conviction was affirmed, and in 5, all of which were from quarter sessions, judgment was reversed.

The returns of the costs of criminal prosecutions are as usual one year in arrear, and deal with the year 1877. The number of cases on indictment was 14,501, and the total cost £129,519 11s., making the average cost of each case £8 18s. 7d. Under the Criminal Justice Act and the Juvenile Offenders Act the number of summary proceedings was 19,827, the total cost £18,468 0s. 2d., and the average cost of each case 18s. 7d. At the circuit assize courts the average cost of cases tried on indictment was as high as £16 4s., and at the Middlesex Quarter Sessions as low as £4 14s. 11d.

The total number of Mint cases prosecuted and concluded in 1878 was 184; and the total costs paid by the Treasury in these cases amounted to £1,416 28. The number of criminal cases, other than these, prose. cuted upon indictment or otherwise by the Solicitor of the Treasury and concluded in 1878 was 134; and the costs in respect of them amounted to £10,807 19s. 1d.

The Prison Act, 1877, having come into operation on the 1st of April, 1878, returns for 113 local prisons have been rendered under the old system for the halfyear ending March 31, 1878. Returns have also been furnished by the Prison Commissioners for those local prisons which still exist; and have been drawn up for the year ending March 31, 1879. Henceforward, all the prison returns will deal with the years ending respectively on the 31st of March. Of the 113 local prisons comprised in the list, 79 were county and liberty pri sons, including 2 for the Isle of Ely, and 1 each for the liberties of Peterborough and Ripon; and 34 city, town, and borough prisons, inclusive of Newgate for the city of London and county of Middlesex. mitments to these during the half-year named numbered 96,282, 71,137 of the offenders being males, and 25,145 females. The number of the prison officers was

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follows:-Governors and deputy-governors, 146; chaplains, 133; surgeons, 114; clerks, schoolmasters, and schoolmistresses, 186; matrons, 109; warders, 1,413; and other subordinate officers, 439; making a total of 2,540. The total costs of the 113 prisons for the half-year amounted to £295,747 1s. 8d., including extraordinary building and establishment charges, £19,782 6s. 6d.; ordinary annual charges. £61,627 13s.; cost of officers, £131,723 8s. 8d.; and cost of prisoners, £82,613 13s. 6d. The sources from which the prison expenses were defrayed, and the amount received from each, were as follows:-From prison receipts, inclusive of profits of prisoners' labour, £36,469; from local rates and funds, £192,554; and from public revenues, £66,723.

By the Prison Act, 1877, the Government local prisons are now vested in the Secretary of State, who is thereby authorized to appoint commissioners, not exceeding five in number, to aid him in carrying its provisions into effect. The total commitments to these prisons during the year ended March 31, 1879, numbered 172,653. As compared with the numbers for 1876-77, the total commitments for 1878-79 show a decrease of 1,352, or 07 per cent.; and in the number of re-committed prisoners there is a decrease of 3,529, or 4.8 per cent. As many as 24,787 had been previously committed once; 11,251 twice; 6,904 thrice; 4,854 four times; and 3,525 five

times; while 9,379 had been previously committed above ten times. As usual, the higher proportionate number of females frequently re-committed is remarkable. Of the prisoners, 720 were under twelve years of age; 6,090 between the ages of twelve and sixteen; and 27,285 between the ages of sixteen and twenty-one. As regards nationality, 136,993 were English; 5,392 Welsh; 3,969 Scotch; 22,593 Irish; 666 Colonial and East Indian; 2,215 foreigners; and 825 of unascertained birthplace. Their state of instruction was as follows: -56,975 could neither read nor write; 109,469 could read or read and write imperfectly; 5,529 could read and write well; 185 possessed superior education; and the intellectual culture of 495 was not ascertained. At the end of the year 19,168 offenders remained in prison, 17,625 being criminals, 355 debtors, and 1,188 military and naval offenders; and the total shows a decrease of 1,068 as compared with the number remaining at the end of the previous year. The aggregate number of separate sleeping cells in the whole of the 68 local prisons of England and Wales now in operation, was, in 1878-9, 26,126, of which 23,009 were certified under the Prison Acts of 1865 and 1877. The number of punishment cells was 449. Apparently, the accommodation has at times been barely sufficient, for upon one day during the year there have been as many as 24,107 prisoners under confinement, though the daily average was only 19,818. During the year, there were in the prisons 167 deaths, 4,287 cases of sickness, and 104,840 cases of slight indisposition, together with 200 cases of insanity; and the greatest number of sick at one time was 1,685. Prison punishments were inflicted in 59,312 cases, as follows, viz. :-Whipping, 115; cells, 5,429; dietary correction, 36,830; and loss of stage or privilege, 16,908. The prison officers numbered 2,205, or one to 8.9 of the daily average number of prisoners, and the total ordinary costs of the prisons amounted to £428,712, giving £21 12s. 7d. as the average cost per prisoner. This sum does not, however, include any charge on account of pensions to prison officers which, under section 36 of the Act of 1877, are payable, partly by former prison authorities and partly by the Treasury. Owing to the state of transition of the prisons during the year, precise information on this and other points was unobtainable, and for this reason it is, perhaps, unadvisable to institute any comparison with the statistics for previous years.

In the 12 convict prisons, for which returns are furnished dealing with the year ending March 31, 1879, there were 12,040 prisoners undergoing sentence in the twelve months, of which number 1,818 were received during that period from county and borough prisons, &c. In the course of the year 1,875 were disposed of, either by removal, discharge, or death, leaving 10,358 in prison at the end of the year. There were as many as 175 cases of insanity among prisoners during the year, against 171 in 1877-8, 133 in 1876-7, 128 in 1875-6, and but 28 in 1874-5. There were only 111 deaths, and 2 cases of suicide. The total staff of the various convict prisons numbered 1,724; and the costs amounted to £350,486 14s. 4d., giving £32 9s. 8d. as the gross annual cost per convict. Deducting the value of labour (measured), exclusive of employment in the service of the prisons-viz., £214,282 18s.—and the incidental receipta-viz., £985 4s. 5d.-the net cost of of the prisons was £135,218 11s. 11d., and the annual average charge per prisoner £12 10s. 8d. In the case of Chatham Prison the annual earnings per prisoner exceeded the cost of maintenance by £2 2s. 4d., and in Portland Prison by 7s. 5d.

It may be added, before closing this branch of the subject, that the total number of inquests held by the coroners in 1878 was 27,628, against 26,287 in 1877. The number of verdicts of murder was 176, against 199 in 1877; and of these 92 and 104 respectively were in the cases of infants of one year old and under. The difference observable between the number of verdicts of murders,

and the number of murders reported by the police (159 for 1878), arises from the occurrence of cases of supposed infanticide, in which verdicts of murder are returned, while, if the offenders are brought to trial, the result is conviction for concealment of birth. In 1878, the other verdicts were as follows:-Manslaughter, 177; justifiable homicide, 5; suicide, 1,709; accidental death, 12,108; injuries, causes unknown, 270; found dead, 2,922; executed, 23; natural death, from excessive drinking, 500; disease aggravated by neglect, 202; want, cold, exposure, &c., 299; other causes 9,237. In 1877 the numbers were:-Manslaughter, 166; justifiable homicide, 4; suicide, 1,636; accidental death, 11,194; injuries, causes unknown, 308; found dead, 3,100; executed, 25; from excessive drinking, 457; disease aggravated by neglect, 164; want, cold, exposure, &c., 273; other causes, 8,761. Of the inquests, 8,290 were held on infants of seven years old and under; 1,678 on children of ages varying from seven to sixteen; 12,783 on adults of between sixteen and sixty; 4,562 on aged and infirm persons of more than sixty years of age; and 315 on persons whose ages were not ascertained. The inquests on males were in the proportion of 67.5 per cent. to the whole number. The total costs, including the coroners' salaries and travelling allowances, amounted, in 1878, to £89,290 15s. 9d., and in 1877 to £85,846 13s. 9d., and the average cost of each inquest in 1878 was £3 4s. 7d., and in 1877 £3 5s. 3d.

Reviews.

ELECTION BOOKS.

A GUIDE TO ELECTION LAW AND THE LAW AND PRACTICE OF ELECTION PETITIONS. By the Hon. CHANDOS LEIGH, and Sir H. LE MARCHANT, Barristers-at-Law. THIRD EDITION. By the Hon. CHANDOS LEIGH and YARBOROUGH ANDERSON, Barristers-at-Law. Davis & Son.

The first edition of this work was published in 1868, the aim of the authors being "to enable the reader to see at a glance how proceedings connected with an elec. tion to which the Corrupt Practices Prevention Acts apply, should be conducted." The second edition came out in 1874. The third appears just in time for the election of 1880, and contains, as additional attractions, a chapter on Municipal Elections; the Municipal Elections Act, 1875; the Parliamentary Elections (Returning Officers) Act, 1875; and also, in the addenda, the Corrupt Practices Act, 1880, and the Town Councils and Local Boards Act, 1880. Cavillers might perhaps ask how these statutes came to be printed before receiving the Royal assent; but the sight of the Royal Arms on the cover will perhaps reassure them. The cases, both old and new, are very fully and clearly dealt with, and copious and well-selected extracts are given from the more important judgments. In dealing with the Bolton case, at p. 147, a little more precision might have been used. On the whole, however, the book appears to have been kept up (to the mark, although it should be pointed out that, as the law of registration and franchise is wholly omitted, to call it a guide to election law" is somewhat of a misnomer.

ROGERS ON ELECTIONS, REGISTRATION, AND ELECTION AGENCY. THIRTEENTH EDITION. INCLUDING PETITIONS AND MUNICIPAL ELECTIONS AND REGISTRATION, WITH AN APPENDIX OF STATUTES AND FORMS. By Jous CORRIE CARTER, Esq., Barrister-at-Law. Stevens & Sons.

This has for many years been known as the standard work upon election law in the widest sense, and we gladly welcome a new edition at the present juncture. The last edition bears date 1876, so that it did not include the Parliamentary and Municipal