THE REPORTS OF THE CONSTABULARY

INSPECTORS.

THE inspectors of constabulary for England and Wales have presented their reports for the twelve months end. ing at Michaelmas, 1879. It is satisfactory to find that both crime and drunkenness have decreased, though it is to be feared that in the latter case the improvement is attributable in a great degree to the depression of trade. In District No. 1 (Eastern and Midland counties and North Wales) Lieutenant-Colonel Cobbe reports a decrease in all classes of crime. The number of indictable offences, as reported to the police, has fallen from 8,106 to 7,590, and the number of apprehensions from 4,582 to 4,347, while the number of summary convictions has fallen from 102,151 to 96,980, and the number of convictions for drunkenness from 26,239 to 24,827 (the smallest total reported during five years); but the inspector observes that, "with the exception of the decrease in the number of drunken cases now shown as less than in the previous years, the general decrease is not remarkable; it is generally represented that the depression in trade has been the cause of fewer drunken cases and assaults on the police." 540 licensed convicts resided in the district during the year, and 232 remained there on the 29th of September, and during the twelve months 44 licensed convicts were re-committed to prison —namely, 13 for breaches of licence, and 31 for fresh 619 66 offences. persons under police supervision' resided during the year, at the end of which 373 remained, in the district. Captain Elgce, the inspector for No. 2 District (Northern) states that "indictable crime has varied but little in amount compared with the two preceding years," but he reports "in drunken cases a marked decrease," being nearly eleven per cent. indictable offences reported have risen from 21,065 to 21,206, but the actual apprehensions have fallen from 9,796 to 9,688, while summary convictions have fallen from 264,174 to 240,007, and convictions for drunkenness from 98,178 to 86,992. In this district the numbers of licensed convicts and persons under police supervision are not given in a tabulated form. In No. 3 District (South of England and South Wales) Captain Willis reports a decided improvement. The reported indictable offences have fallen from 6,354 to 6,162, and the apprehensions from 4,263 to 4,061, while summary convictions have decreased from 80,713 to 76,572, and convictions for drunkenness from 20,127 to 18,702, but the inspector points out that the summary convictions had greatly increased in 1878; and he adds that "it is possible that the bad state of trade may have had some effect in reducing offences, as fewer people also have been charged with drunken offences than in the previous year." There were 196 licensed convicts and 261 persons under police supervision in the district on the 29th of September, 431 of the former class and 497 of the latter class having been resident there during the year. Twenty-five licensed convicts were re-committed during the year, but the causes of commitment are not stated. It is pointed out that these statistics are so far defective, that persons who change their abode and report themselves to the police at their new place of residence will necessarily appear twice over in the returns.

The

Coming to particular localities, we find the county most free from crime was Radnorshire, where only 13 indictable offences were reported, whereas 230 were reported in Lancashire, being an increase of 181 upon the number reported in 1878. In the latter county no less than 38,425 persons were convicted summarily, and 6,778 for drunkenness. Eight boroughs were entirely free from indictable crime-namely, Maldon, Hythe, Tenterden, Chard, Penryn, Launceston, Helston, and Pwllheli. On the other hand, the most unfavourable statistics appear (as in former years) at Liverpool and Manchester. In the former borough the indictable offences (reported) have increased from 4,150 to 4,226, and the apprehensions from 1,630 to 1,639, the total of

summary convictions being 31,191, as against 34,856 in the preceding year. The convictions for drunkenness reached a total of 15,394, showing, however, a decrease of 3,244. At Manchester the reported indictable offences were 4,518, as against 4,625 in 1878, and the apprehensions 1,245, as against 1,139. There were 19,767 summary convictions, and 7,657 convictions for drunkenness. The discrepancy between the number of indictable offences reported to the police and the number of persons actually apprehended is again very startling, especially in the more populous boroughs.

The statistics for the respective districts may be thus summarized:-The number of indictable offences committed in England and Wales has fallen from 35,523 to 34,958, being a decrease of 565. Summary convictions have fallen from 447,038 to 413,559, a decrease of 33,479. There is also a diminution of, 4,023 in the convictions for drunkenness, the respective totals being 144,544 in 1878, and 130,521 in 1879.

DECISIONS BY COURTS OF SEVERAL

JUDGES.

THE rough and ready mode of expressing the opinions of the country by parliamentary representatives has exercised the ingenuity of theoretical politicians in sugges tions to provide a fairer average representation. A somewhat similar, though more simple, problem presents itself in considering which is the fairest mode of obtaining the decision of a court constituted of several judges upon a complicated case, where the question which side is right depends upon a number of subsidiary questions of law, or fact, or both. For it is obvious that in many cases there would be a difference of result if, instead of taking the opinion of the majority upon the result of all the questions in a lump, as is generally done, each question were to be decided separately upon the opinion of the majority. Our meaning may be iilustrated by a very simple case. Suppose the court that has to try an action to be constituted of three judges, Brown, Black, and White, and the question they have to decide to be whether the defendant has built so as to interfere with the plaintiff's ancient lights. Brown may think there is an interference with lights that are ancient; while Black thinks that, though there is an interference, the lights are not ancient, and White thinks there is no interference and the lights are ancient. According to the practice now, current judgment would be given in favour of the defendant, but if the decision of the court had been taken on each point separately, it would be found by the majority of Brown and Black against White that there has been an interference, and by the majority of Brown and White against Black that the interference was with ancient lights, and the plaintiff would win his case.

Whatever may be the most convenient and just mode of arriving at the determination of a trial depending on issues of fact, where a case depends on more than one question of law, there are good reasons why such questions of law should be determined separately. And we can only account for the fact that more practical inconvenience has not been felt from the present mode of determining such questions because such cases are not common, and when they do arise the judges do not often differ about more than one point of law. The vice of the mode of determining a question depending on two points of law in a lump lies in the fact that the opinion of a majority of judges, before whom a point of law comes for decision, makes the law. Consequently, if a suitor has, in order to win his cause, to establish two propositions of law, he may succeed in establishing both, and yet the opinion of the majority of the judges may be that both of the points are not established, and he may lose his cause. The inconvenience of this practice may be, perhaps, better illustrated by supposing there be three causes for trial before the same three

judges, in one of which one suitor has to establish two propositions of law (A. and B. say), one of which points arises in the second action, and the other in the third. Then it is obvious that if two of the judges only think that proposition A. is established, and different two judges only think proposition B. is established, the decision of the case depending on both propositions will fall one way or the other, according to the accident whether it is heard first or otherwise-not an inapt example of the uncertainty of law.

Reviews.

SELF-PREPARATION FOR THE INTERMEDIATE EXAMINATION, AS IT AT PRESENT EXISTS, ON STEPHEN'S COMMENTARIES ON THE LAW OF ENGLAND. By JOHN INDERMAUR, Solicitor. Stevens & Haynes.

Mr. Indermaur's long experience in legal education will secure for any work from his hand the favourable consideration of the profession. The book is arranged upon the same principles as the author's "Self-Preparation for the Final," and contains some valuable hints to students in getting up their "Stephen for the examiners. Like many examination manuals it is perhaps open to the reproach of unduly narrowing the range of the pupils' studies by "advice as to portions of the work which may be omitted." Mr. Indermaur suggests a general course of reading for about two years, to be followed by three or four months' more special study. His practical suggestions to students appear to be extremely good, and from the introduction to " 'Stephen" he gives some useful specimens of the form in which notes should be made. The work also contains a list of statutes with which the student should be familiar, though we are surprised to read Mr. Indermaur's suggestion that "some of the most important" ones should be committed to memory; and there is also a good selection of questions upon the work for the exercise of students, as well as a concise treatise on the practice of the High Court. The manual cannot fail to be of great service to candidates for the "intermediate," although (as we have already hinted) there may be some danger of their being tempted by some of the authors hints to reduce their work to a minimum.

PRINCIPLES OF TORTS AND CONTRACTS. By W. Edmund BALL, LL.B., of Gray's-inn, Barrister-at-Law. Stevens & Sons.

Mr. Ball modestly describes this work as "a short digest of the common law, chiefly founded upon the works of Addison, with illustrative cases, for the use of students." Each chapter contains a short statement of the law applicable to the particular subject. No authorities are referred to in the text or at the foot of the page, but ("to avoid encumbering the letterpress with that array of bracketed figures which renders the appearance of the ordinary law book so repulsive to the reader") the figures in the margin refer to the authorities for the respective propositions in the text. These authorities appear in the form of a digest of "illustrative cases" at the end of each chapter, and the result of the cases appears to be, in the majority of instances, neatly and accurately stated. We regret, however, to see that Mr. Ball, when referring in the text of the work to statutory provisions, almost invariably omits to give the sections of the particular Act where the provision is to be found, and we think that, in the citation of the cases, a few duplicate references might, with advantage, have been added.

A DIGEST OF PARLIAMENTARY REGISTRATION CASES. By JOHN J. H. SAINT, Esq., B.A., Recorder of Newark. Shaw & Sons, Fetter-lane.

We observe that a supplement has just been published to this very useful work, bringing it down to the present time. A great want which every revising barrister, and every other person engaged in the business of the registration of voters, frequently feels is that of some means of ascertaining, during the revision, the state of the authorities as to the points that may arise. He cannot carry round with him the reports at large, and even those sets of reports which give registration cases only are somewhat cumbrous. On the other hand, the notes of cases given in the text. books, though perhaps accurate as far as they go, are often very meagre. A short abstract of the facts of each case, and a summary of what was decided, is often calculated to afford most invaluable assistance to the barrister in determining, or to the agent in arguing, a point of nicety. In the preface to this work the compiler points out that he has no intention of attempting to supersede the ordinary text-books on registration law, but that his object is to supply a useful companion to them in the shape of such a portable epitome of the cases as we have above pointed out the need for. It appears to us that he has been very successful in giving just so much of the circumstances of each case as is necessary to enable the reader to see what was really decided, and also in suggesting briefly in his account of what was in each case the ratio decidendi and the scope of the decisions. The cases are classified under separate headings, arranged in appropriate logical order. First come the cases that deal with the nature of the qualification in county and borough respectively, then the cases with regard to notices of claim and notices of objection, and so on, till all the various topics are exhausted. It would, of course, have been better that, instead of a supplement, the new cases should have been worked into the text, but it is impossible in the nature of things that there should be a new edition every year of a book for which there is necessarily only a limited sale. Mr. Saint may fairly be congratulated on having seen and satisfactorily occupied a vacant space in the literature on the subject of Parliamentary Registration.

The Institut de Droit International will hold its next meeting in September at Oxford. On the 8th prox. a convocation will be held to confer the honorary degree of D.C.L. upon certain distinguished foreigners connected with the institut. It is stated that the recipients of the degree will be MM. Mancini, late Minister of Justice for Italy, and Professor of International Law in the University of Rome; Bluntschli, Privy Councillor and Professor of International Law in the University of Heidelberg; De Parion, Senator of France, and late Minister-President of the Council of State, ex-president of the Institut de Droit International; and Rolin Jaequemyns, Minister of the Interior for Belgium, president of the Institut de Droit

International.

The first report of the Select Committee on the Office of the Clerk of the Parliaments and Office of Gentleman Usher of the Black Rod has been issued. The committee report that the Clerk of the Parliaments informed them that he had received a letter from Mr. John Fraser Macqueen, Q.C., resigning his office as Reporter of Scotch Appeals, Scotch Peerage Cases, and Divorce Cases in the House of Lords, and stating that Mr. Gerald J. Wheeler, barrister-at-law, had for nearly three years effectually assisted him in preparing his reports. The Clerk of the Parliaments had, with the approval of the late and the present Lord Chancellor, appointed Mr. Gerald J. Wheeler to the said office, Mr. Macqueen received £360 per annum, but the committee recommend that Mr. Wheeler should be remunerated in the same manner as Mr. Clark, the Reporter of English and Irish Cases-viz., by a payment of £100 per annum, and £5 és. for each day's attendance.

Cases of the Week.

BEFORE THE VACATION JUDGE.

AUGUST 25.

PETITION-APPOINTMENT OF NEW TRUSTEES-VACATION BUSINESS. In a case of In re Lawrence's Trusts, a petition was presented before the Vacation Judge for the appointment of new trustees of a will and settlement. An objection was taken that it was not vacation business, as no urgency for the application was shown. For the petitioner it was alleged that the surviving trustee was eighty-six years of age, and might die at any moment, and therefore that new trustees should be appointed, or at all events, if the petition stood over, the trustee should give an undertaking not to receive any income until the petition was heard. POLLOCK, B., considered that the petition was scarcely vacation business, and said that on the trustee giving an undertaking, he should direct it to stand over to November.-SOLICITORS, Meredith, Roberts, & Mills; White & Sons.

METROPOLITAN BUILDING ACT (18 & 19 VICT. c. 122), ss. 3, 85-TENANT FROM YEAR TO YEAR-OWNER-PARTY WALL-INJUNCTION.-In a case of Max v. Hains, a motion was made to discharge an ex parte injunction, obtained under the following circumstances :-The plaintiff was the tenant of adjoining premises to the defendant, and the latter being desirous of altering his house, had pulled down a party wall without giving the notice prescribed to be given to all 66 owners " of adjoining property under the Metropolitan Building Act, s. 85. The plaintiff claimed to have some agreement for a lease, and considering himself entitled to notice before the works were commenced, obtained an injunction restraining the defendant from proceeding. The defendant now contended that the injunction was wrong, on the ground that no notice was required to be given to the defendant, as he was not, according to section 3, an "owner at all, being only a tenant from year to year. The defendant relied on Wheeler v. Gray (4 C. B. N. S. 584). POLLOCK, B. was of opinion, on the affidavits, that the plaintiff had no status to apply for the injunction. The interpretation section of the Metropolitan Building Act did not apply to a tenant from year to year, and Wheeler v. Gray was conclusive that the owner of a party wall was not under any obligation to give notice to such a tenant. The result of the plaintiff's affidavits was that he had no enforceable agreement for a lease, and was merely tenant from year to year, and not within section 85. The result was that the injunction must be dissolved with costs, and there must be an inquiry as to any damages sustained by the defendant.— SOLICITORS, Hardisty & Rhodes; G. B. Öliver.

VIBRATION OF ENGINE-NUISANCE-SUFFICIENCY OF IN. JURY INJUNCTION.-In a case of McKenzie v. Yabsley, a motion was made to restrain the defendant from working a steam-engine so as to be a nuisance to the plaintiff. The plaintiff and defendant occupied adjoining houses in a street in Bristol, in a neighbourhood where much manufacturing went on, and the defendant had erected in May last a fourhorse engine in an outbuilding at the back of his house, immediately over certain arches whereon both the houses were built. The plaintiff occupied his house and the defendant used his for the purposes of his business. It was contended on behalf of the defendant that a very strong case was required to be made out to cause the court to interfere and stop a business, and he referred to Gaunt v. Fynney (L.R. 8 Ch. 8), and Sabine v. North Brancepeth Company (L. R. 9 Ch. 705). It was also submitted that there was here no sufficient evidence of irreparable injury, and that the motion should, at all events, stand to the trial. POLLOCK, B., said it was proved that the district where the defendant lived was a manufacturing neighbourhood, that he was entitled to use some steam-engine, and that it was a nere question of difference as to whether a sufficient nuisance was caused. It was not established that the working of the engine was detrimental to the health of the plaintiff's family, although, no doubt, his occupation was not so agreeable as formerly. In his opinion no sufficient case had been made out for granting an interlocutory injunction, and therefore the motion must stand to the trial, and the costs would then be dealt with. To some extent he was influenced by the fact that no steps

to obtain the injunction had been taken by the plaintiff since May last.-SOLICITORS, Darley & Cumberland; Torr & Co.

LANDLORD AND TENANT-OUTGOING TENANT REMOVING HAY AND STRAW-CUSTOM OF THE COUNTRY-INJUNCTION.In a case of Carlyon v. Hayward, also before the Vacation Judge on the 25th inst., a motion was made to restrain an outgoing tenant of a farm in Devonshire from selling the hay and straw off his farm. It was contended that he held under a lease prohibiting the same, or otherwise that he held as a yearly tenant, and was prevented by the custom of the country from removing the hay and straw. The tenant had been offered a lease, but had refused to execute the same, and therefore the question depended on the custom of the country. For the defendant two surveyors and auctioneers of this class of crops stated they knew of no such custom, but for the plaintiff seven farmers stated it was a well-known custom where the property was not held under any agreement. The plaintiff offered to give an undertaking in damages if the injunction were granted. The defendant submitted that the evidence of his witnesses was more trustworthy than that of the plaintiff's, but if the judge did not believe his evidence, then he asked that the motion might stand over to enable him to get further affidavits from farmers in the neighbourhood. POLLOCK, B., said, in mercy to the parties he should not allow any further affidavits to be filed. It was clear in that part of the country if the defendant had held under a lease, he could not have taken the hay and straw; but as he did not hold under any agreement, the question depended on the custom of the country. As to such a custom, in his experience, you could always get evidence on both sides, but what pressed with him was the fact that the defendant had had the benefit of the hay and straw in coming upon the farm. He thought the existence of the custom sufficiently proved, and as the plaintiff offered an undertaking in damages, he should grant the injunction asked for until the trial.-SOLICITORS, Coode, Kingdon, & Cotton; Walker & Martineau.

PRACTICE-PRESENTATION OF PETITION-INFANTS SETTLEMENT ACT. In a case of Re Lightfoot, before Pollock, B., Vacation Judge, on the 18th inst., an application was made that a petition under the Infants Settlement Act might be presented that day in order that the consideration of it might be at once referred into chambers. His LORDSHIP allowed the petition to be at once presented, on the ground that the intended husband was ordered on foreign service.-SOLICITOR, Smallpeice.

COMPANY-APPLICATION TO REDUCE CAPITAL-VACATION BUSINESS. In a case of Re John Harvey Yacht and Ship Building Company, also before the Vacation Judge on the 18th inst., an application was made to reduce the capital of the company. It was stated that the resolution had been passed on the 18th of July, and an objection was taken by the judge that the application should have been made earlier. To this it was answered that the resolution took some time to carry through, and that it would have been difficult to get the petition presented for the last petition day in the sittings. Eventually his LORDSHIP said to prevent another application he would now make the order.-SOLICITORS, Philbrick & Corpe.

PARLIAMENTARY DEPOSIT ACT- VACATION BUSINESS GENERAL ORDER. -An order for the payment out of a parliamentary deposit was made by the Vacation Judge, and a request at the same time made to his lordship that he would lay down a general rule that such applications should be treated as vacation business, and be placed in the paper as a matter of course. His LORDSHIP said that this would be a useful rule, and he accordingly directed that petitions for the payment out of parliamentary deposits, where the Acts had been passed or the Bills thrown out after the last petition day in the Trinity Sittings, should be placed in the paper for hearing without special leave.

SALE OF GOODS-GOODS IN HANDS OF CONSIGNEE-SPECIFIC PERFORMANCE INJUNCTION.-In a case of Rowney v. Alder,

also before the Vacation Judge, on the 18th inst., a motion was made to restrain the defendant from parting or dealing with certain goods in their hands, under the following circumstances. The defendants, the vendors, resided in Hamburgh, and the goods were sold to the plaintiffs purchasers in England on the terms of payment by bill at three months. The goods were shipped to consignees in England, who were made defendants, and on the instructions of the vendors they refused to deliver except for cash. An interim order over to-day had been made, restraining the defendants the consignees from parting with the goods, and the motion was now made to continue that order. The plaintiffs contended that the court had under the Judicature Acts power to grant an injunction in every case in which it is just and convenient, and that in a case like this, where damages would be no remedy, as the vendees were abroad, the court had jurisdiction to interfere, and reference was made to the case of Hart v. Hering (L. R. 8 Ch. 860), the case of a ship. POLLOCK, B., said this was one of those cases where he should have been glad if some arrangement could have been made between the parties for a termination of the dispute on some security being given. On the merits, however, he could see no ground for the motion. The case was one of an ordinary contract for the delivery of goods which would be satisfied by the delivery of any goods similar to those held by the consignees, and not only by the specific goods in their bands. In that respect the case differed entirely from the case of a ship, like the case of Hart v. Hering. He was, in effect, asked to restrain the defendants from dealing with goods in which no property had passed to the plaintiff's, and he was unaware of any authority for such a proposition, or for a specific performance of the contract, which came to the same thing. It was said the plaintiffs were prejudiced by the foreign contract, and that they would have to go to Hamburgh for their damages; that was, no doubt, an element in a case of this kind, but not sufficient to support the motion. He should, if he acceded to the motion, be going beyond any decided case, and he should therefore dismiss the same with costs. There would be a reference to chambers as to any damages occasioned by the interim order.— SOLICITORS, Wild, Browne, & Wild; Hollams, Son, & Coward.

INJUNCTION

BREACH-MOTION TO COMMIT-HOLDING OUT AS AGENT. In a case of Ruston v. Loader, also before the Vacation Judge on the 18th inst., a motion was made to commit the defendant for a breach of an injunction granted by the Master of the Rolls on the 16th ult., restraining the defendant from holding himself out as a partner with the plaintiffs, or as their general agent. The ground of the motion was that the defendant had recently sent a notice to the plaintiffs, signed at the foot by him as agent for and on behalf of the plaintiffs' firm. The defendant did not appear. POLLOCK, B., wag of opinion that a breach of the injunction had been committed, but did not wish to commit the defendant in his absence. He, therefore, made an order for his committal, but such order was not to be passed for a week, so as to allow the defendant, if possible, to come to terms with the plaintiffs, and so avoid his being sent to prison. The defendant was ordered to pay the costs of the motion.-SOLICITORS, Swann & Co.

PRACTICE

-MOTION TO RESTRAIN INFRINGEMENT OF PATENT-INSPECTION-DELAY-VACATION BUSINESS.-In a case of Gandy v. Reddaway, also before the Vacation Judge on the 18th inst., a motion was made by the plaintiff to restrain the infringement of a patent. It appeared that the writ was issued in June, and the motion was originally made to the Master of the Rolls on the 23rd of July. On that day an order was made that the motion should stand over until November, with liberty to the plaintiff to renew it in the vacation. The motion also went to restrain the publication of a circular issued in January last, and also for inspection. No fresh ground for the renewal of the motion was stated to have arisen since the order of the Master of the Rolls except as to the inspection, which it was stated was necessary to enable the plaintiff to prepare his statement of claim, which he was under terms to deliver at the end of the vacation. The objection was taken that there was no reason why the motion should be renewed in vacation. POLLOCK, B., adopted this view, and refused to make any order on the motion. The motion, therefore, stood

over until November, the costs being reserved, and the term for the delivery of the statement of claim was extended until a week after the first motion day in the Michaelmas Sittings.-SOLICITORS, W. R. Francis; Shaw & Tremellen.

PRACTICE-MOTION TO STAY PROCEEDINGS-PENDING APPEAL-DELAY-VACATION BUSINESS.-In a case of Hyam v. Terry, also before the Vacation Judge on the 18th inst., a motion was made to stay proceedings under an order made by Fry, J., in November, 1879, on the ground that if the order in the meantime were proceeded with grest unnecessary expense would be incurred in obtaining evidence on one of the inquiries which was appealed against. The motion was opposed as not being vacation business, owing to the delay that had occurred in making the motion. It was also alleged that the notice of appeal was given after the present notice of motion. One excuse alleged for the delay was that the defendants had proceeded to draw up the order in July, and that the order to proceed had only been made by the chief clerk on the 2nd of August. POLLOCK, B., was of opinion that the motion was not vacstion business, and he, therefore ordered it to stand over to November, the costs to be then dealt with. He said the motion would be no stay to the plaintiffs proceeding with their order.-SOLICITORS, Abbott & Co; Lewis & Lewis.

COUNTY COURT STATISTICS FOR 1879. THE annual return as to county court plaints, shows that during the year 1879 there was a steady and progressive increase in the number of entries, since, including the statistics of the City of London Court, there were 1,044,458 plaints entered in 1877, 1,051,912 in 1878, and 1,067,136 in 1879. Out of the last-mentioned total 1,050,791 plaints were entered for sums not exceeding £20, 15,934 were entered for sums exceeding £20 and not exceeding £50, while 411 plaints were (by agreement) for sums over £50. The plaints under £20 showed a considerable increase as com. pared with the year 1878, but there was a slight falling of in those for higher amounts. Circuit No. 21 (comprising Birmingham, Tamworth, and Atherstone) again takes the lead with the total of 42,973 plaints (being an increase of about 2,000), while Circuit 49 (East Kent) shows a return of only 7,867. In the Birmingham County Court no less than 41,882 plaints were entered, while Bellingham and Belford (which are included in Circuit No. 1) each show a total of only 31. The number of actions determined during the year was 624,801, being a decrease of 127 from the aggregate number for 1868. Of these actions 1,138 were beard with juries, and 623,663 without. There appears to have been more difficulty in enforcing judgments, since 136,724 judgment summonses were issued during the year, and, as compared with 123,275 issued in the previous year, the number of judgment summonses actually heard also rising from 69,873 to 77,577. Again, 31,418 warrants of commitment were issued, being an increase of 2,631, while the number of imprisonments rose from 5,687 to 7,927. In many of the country districts no warrants of commitment were issued during the year, but in the Leeds Court alone there were no less than 1,942 warrants, and 480 imprisonments; plaints were entered for £3,513,301, but only £210,474 was recovered, the costs amounting to £134,542, and the fees to £458,586. The amount of fees varied from £15 at Belford and Soham respectively to £18,230 in the Birmingham Court. The total of equitable actions fell from 639 to 563, and that of Admiralty proceedings from 462 to 402, which included 168 in the City of London Court. There were 1,407 debtors' summonses, 196 declarations filed by debtors, 1, 108 petitions for adjudication of bankruptcy, and 12,682 petitions (an increase of 1,717) for liquidation or composition. There were 41 appeals to the High Court by special case, and 60 by motion, and 40 writs of certiorari for the removal of proceedings; 883 actions were remitted from the High Court (136 being actions of tort), the Westminster Court having again the largest share of this class of business. The judges sat upon 8,283 days during the year (a decrease of 109 days), the minimum of 107 days being represented by the judge of Circuit No. 31 (South-West Wales), and the maximum of 340 by the two judges of Circuit No. 6, and out of this number 282 days were occupied at Liverpool alone.

Obituary.

MR. JOHN DAVID BELL.

Mr. John David Bell, barrister, standing counsel to the Government of India, died at Calcutta, on the inst. Mr. Bell was the youngest son of Mr. George Joseph Bell, advocate, professor of law at the University of Aberdeen, and he was born in 1824. He was called to the bar at the Middle Temple in Easter Term, 1848, when he joined the Home Circuit, but a year or two later he proceeded to Calcutta, where he practised with much success. He came back to this country about ten years afterwards, and enjoyed for some time a lucrative practice in Indian appeals before the Privy Council, and for a few months he held the office of professor of Indian jurisp rudence at King's College, London. Mr. Bell was one of the founders of the Positive Life Assurance Company, and he was the first chairman of that body. Three or four years ago he returned to Calcutta and very soon after his arrival he was appointed standing counsel to the Government, which office he held until his death.

MR. CHARLES JAMES GARBUTT.

Mr. Charles James Garbutt, solicitor, of Newcastleupon-Tyne, Morpeth, and Rothbury, died at Grove House, Gosforth, Northumberland, on the 11th inst., after a short illness. Mr. Garbutt was born in 1844. He served his articles with Mr. John Alderton Busb, of Newcastle, and Mr. John Scott, of 60, King William-street, and he was admitted a solicitor in Easter Term, 1869, when he obtained the prize of the Honourable Society of Clifford's-inn. He had practised for over ten years at Newcastle and Morpeth, and he had been for some time registrar of the Rothbury County Court (Circuit No. 1). Mr. Garbutt had been for about two years a member of the Newcastle Town Council. He leaves a widow and two children.

MR. ALFRED TENNANT.

Mr. Alfred Tennant, solicitor, of Hanley, Leek, and Stone, died at his residence, Fern Lea, Sidmouth-road, Newcastle-under-Lyme, on the 14th inst. Mr. Tennant was born in 1835, and was admitted a solicitor in 1861, having been articled to his elder brother, Mr. Edmund Tennant, with whom he was originally in partnership, although for the last few years he had carried on business alone. He had offices at Hanley, Leek, and Stone, and he had at one time a large petty sessions and county court practice, being a ready speaker and possessed of great tact in the management of cases. In 1875 he was appointed by the late Mr. William Spooner, judge of county courts, to be registrar of the Hanley, Burslem, and Tunstall County Courts (Circuit No. 26), and he was also district registrar at Hanley under the Judicature Acts. Mr. Tennant leaves a widow and several children. At the sitting of the Hanley County Court, on the 20th inst., the judge, Mr. Henry Holroyd, paid a high tribute to Mr. Tennant's personal character, and testified to the ability with which he had discharged his duties as registrar of the court. was buried at Endon Church on the 17th inst., a large number of professional and other friends being present at the funeral.

MR. ROBERT WILLIAM WHITELOCK.

He

Mr. Robert William Whitelock, solicitor, of Workington, died at that place, on the 17th inst., from congestion of the brain, after a few hours' illness. Mr. Whitelock was born in 1841. He served his articles with Mr. William Paitson, of Whitehaven, and he was admitted a solicitor in 1864. He formerly practised at Whitehaven, but a few years ago be removed to Workingtou, being about the same time appointed clerk and solicitor to the Workington Local Board of Health and Urban Sanitary Authority, and he resided and practised at the latter place until his death. He was a perpetual commissioner for the county of Camberland, and although comparatively a young man he had succeeded in acquiring a lucrative practice. Mr. Whitelock's premature death has caused a general feeling of sorrow in the district. He was buried at Gilcrux on the 20th inst.

Appointments, Etc.

Mr. GEORGE ARTHUR FLOWERS, solicitor, of Steyning, has been appointed Clerk to the County Magistrates at that place. Mr. Flowers was admitted a solicitor in 1875, and is also clerk to the Bramber Sewers Commissioners, and to the River Adar Navigation Commissioners.

Mr. JOHN EDWARD HALL, who has been appointed one of the Revising Barristers for Nottinghamshire, in succession to Mr. William Cole Beasley, Q.C., is a graduate of Queen's College, Oxford. He was called to the bar at Lincoln'sinn in Trinity Term, 1862, and he practises on the Midland Circuit, and at the Leicestershire and Northamptonshire Sessions. He was formerly one of the staff of the WEEKLY REPORTER, and he now reports for the Law Reports in the Court of Appeal. Mr. Hall is the author of a work on "Profits à prendre and Rights of Common."

Mr. RICHARD HARRIS, who has been appointed one of the Revising Barristers for Lincolnshire, in succession to the Hon. Edward Chandos Leigh, resigned, was called to the bar at the Middle Temple in Michaelmas Term, 1864, and he practises on the Midland Circuit, and at the Central Criminal Court, and the Middlesex and Birmingham Sessions. He is author of "Hints on Advocacy."

Mr. WILLIAM JOHN IRVING, solicitor and notary, of New Windsor, has been appointed a Commissioner to administer Oaths in the Supreme Court of Judicature.

Companies.

WINDING-UP NOTICES. JOINT STOCK COMPANIES.

LIMITED IN CHANCERY.

COMMERCIAL DISCOUNT COMPANY, LIMITED.-The M.R. has, by an order dated Aug 7, appointed Joseph John Saffery, Old Jewry chambers, to be official liquidator in the place of Henry Croysdill,

deceased

PATENT LIONITE MANUFACTURING COMPANY, LIMITED. - Petition for winding up presented Aug 18, directed to be heard before Baron Pollock, in the court of V.C. Malins, on Sept 1. Lumley and Lumley, Old Jewry chambers, solicitors for the petitioner [Gazette, Aug. 20.] COCKSHEAD COLLIERY COMPANY, LIMITED.-By an order made by V.C. Hall, dated Aug 3, it was ordered that the company be wound up. Carritt and Son, Fenchurch st, solicitors for the petitioner OSSEIN TANNING COMPANY, LIMITED.--Petition for winding up, presented Aug 19, directed to be heard before Pollock, B., on Sept 1. Abrahams and Co, Old Jewry, solicitors for the petitioner NORTH BUCKLEY COLLIERY AND FIREBRICK COMPANY, LIMITED.Petition for winding up, presented Aug 21, directed to be heard before Pollock, B, on Sept 1. Layton and Jaques, Ely pl, Holborn, for Lancaster and Wright, Bradford, solicitors for the petitioner [Gazette, Aug. 24.]

FRIENDLY SOCIETIES DISSOLVED. COURT PRIDE OF THE CROWN, No. 1447, ANCIENT ORDER OF FORESTERS' FRIENDLY SOCIETY, George Inn, Winslow, Bucks. Aug 17 PRUSSIAN HERMITS' FRIENDLY AND BENEFIT SOCIETY, Duke of Wellington, Wood st, Old Brompton, Kent. Aug 17

[Gazette, Aug 20.]

County Courts.

WAKEFIELD.

(Before Mr. Serjeant TINDAL ATKINSON, Judge.)

Tuesday, Aug. 17.-Dawson v. Worth.

Trade Union Society, 1871, s. 4-Right to recover subscriptions and contributions from members.

In this case, in which judgment had been reserved, his HONOUR said:-This is an action brought by Henry Dawson and another, trustees of the No. 9 Lodge of the West Yorkshire Colliery Engineers' Mutual Protection Associa tion, to recover from Christopher Worth the sum of 138., for twelve weeks' contributions to the funds of the society. The defendant had been for some time a member of the society, which is registered under the provisions of the Trades Union Act (34 & 35 Vict. c. 31), and may be taken in the fullest meaning of the term to be