Mardell v. Curtis (34 L. J. 355) is an interesting case on the law of leases. There the lessor agreed to let a house to the defendant on the usual terms, adding that he agreed, "if the conditions be kept and rent paid," not to raise the rent "nor terminate the tenancy of Curtis or his wife." Curtis was in possession under this agreement, when the lessor sold the reversion to the plaintiff. The latter, treating the defendant as a yearly tenant, gave him the usual notice to quit, and on the latter claiming to be entitled under the agreement to a lease of the premises for the lives of himself and his wife, commenced an action for ejectment. CozensHardy, J., dismissed the action, and ordered a declaration on the counterclaim that the defendant was entitled to specific performance of the agreement. It might be argued that Duxbury v. Sandiford (78 L. T. 230) is opposed to the above decision, but there the letter was a mere personal agreement between the parties, and no estate passed. Here the agreement ran with the land. It is not uncommon for an agreement with a yearly tenant to provide that the latter may at his option have a lease for a specified term, but if no time be stipulated within which the option is to be exercised the landlord may at any time call on the tenant to exercise it, and in default may determine the tenancy. Until this is done the option continues, as was determined in Hersey v. Giblett (23 L. J. Ch. 818) and Moss v. Barton (L. R. 1 Eq. 474). Nevertheless, an option of this kind passes by an assignment of the tenant's interest, and even if he becomes bankrupt passes to his trustee, and to a purchaser from the trustee. There is a general consensus between ali these cases which entirely justifies the decision of Cozens-Hardy, J. A very similar case (Browne v. Warner, 14 Ves. 156) was decided by Lord Eldon in the same way.

SHERSTON BAKER.

Reviews.

[SHORT NOTICES DO NOT PRECLUDE REVIEWS AT GREATER
LENGTH IN SUBSEQUENT ISSUES.]

Modern Land Law. By EDWARD JENKS, M.A., of the Middle Temple, Barrister-at-Law, Reader in English Law, Tutor and Lecturer of Balliol College. Oxford at the Clarendon Press. London and New York: Henry Frowde. 1899.

This is a treatise quite worthy of the great University from which it comes. We should recommend every student preparing for examinations to read this book if he possibly can find time to do so. Of course it cannot be denied that it is a heavy task, but Mr. Jenks has done his best to lighten it. Not only does Mr. Jenks understand the mysteries of modern land law, but he has made a special study of the hardly less difficult problem of how to hold a young man's attention. Lawyers are inclined in their treatises to " go to the point" as speedily as may be, to make jettison of every passing thought which strikes them as a burden which is only embarrassing, and to give the greatest amount of information with the minimum of literary effort. This is the result partly of the training of the lawcourts and partly of professional haste. An Oxford tutor knows that he must not abandon any advantage which will enable him to secure a hearing, and he is comparatively a man of leisure. We think that he is therefore likely to succeed where others fail. At the same time it must not be imagined that the work of Mr. Jenks is a "popular" lecture. It is a closely reasoned treatise upon Modern Land Law. The result of numerous statutes and cases is accurately given, and a number of very difficult words, phrases, and doctrines is lucidly explained. Though the subject is not treated from an historical point. of view, it becomes obvious at every page that this is not from want of historical knowledge on the author's part. In fact, the great merit of the book is its vast amount of erudition which does not ostentatiously appear on its pages-arguing a great capacity for self-restraint and a considerable sense of proportion.

Local Government. By WILLIAM BLAKE ODGERS, M.A., LL.D., Q.C. London: Macmillan & Co., Limited.

1899.

This work contains the substance of six lectures delivered last year at the request of the Council of Legal Education. It is founded

on a book on the same subject written for the same series (The English Citizen Series) by Mr. M. D. Chalmers. The great change wrought in Local Government by the Acts of 1888 and 1894 has induced Mr. Blake Odgers to produce the subject of this notice. The book is not intended either as a legal guide or an antiquarian's manual, but for those who wish to have a clear and not too lengthy account of the past and present conditions of the Local Government under which they live, it will be most valuable. The history of the Parish and the Borough are traced, and the functions of the Union, the School Authority, and the Burial Boards are described. Even the mysterious and tangled subject of Highway Authorities is accurately dealt with. Mr. Blake Odgers is thoroughly in sympathy with all modern developments of representative government and with expenditure on sanitary and educational purposes, but he calls attention again and again to the alarming increase in local expenditure and local indebtedness. He recognizes, however, the difficulty of finding a remedy, and his suggestions, which will be found on page 259, are (1) that accounts of local bodies shall be audited by the District Auditors of the Local Government Board; (2) further restrictions on power of local authorities to apply to Parliament for borrowing powers; (3) local budgets.

A Compendium of Modern Equity. By ANDREW THOMSON, B.A., LL.D. London: William Clowes & Sons, Limited. 1899.

It is difficult to estimate the labour that must have been bestowed on this book by the learned author, who, unfortunately, did not live to complete it. Part of the work, the preface states, may be taken as a second edition of the author's former work, The principles of Equity and the Equity Practice of the County Court, but there is a vast deal more. The book is intended for the practitioner, and with that view has been as much condensed as is consistent with accuracy. To accomplish this last is only possible to an author who is thoroughly master of his subject, and to have compressed such a subject into seven hundred pages without brevity leading to obscurity is a great achievement, as the work possesses the merits both of clearness and completeness. In consequence of the death of the author in November, the chapters on Specific performance, Rescission, Fraud, and Mistake have been revised, and the Index, etc., completed by Mr. W. M. Crowdy.

Companies in France. The law relating to British Companies and securities in France and the formation of French Companies. By THOMAS BARCLAY, LL.B. London: Sweet & Maxwell, Limited. 1899.

Mr. Barclay is well known as an authority on the law of France, and he has produced a most useful little book "intended to afford the information required by all who are directly or indirectly connected with companies and securities in France." Mr. Barclay clearly shows that Foreign Companies are subject to considerable disadvantages if they try to carry on business in France, and severely criticizes the manner in which the Court of Cassation has construed the Convention between France and England. There is much useful information given as to the formation of Companies and the liabilities of the promoters, etc., which would be useful to anybody who contemplated taking an interest in a company to be formed in France.

1899.

First Steps in International Law. By SIR SHERSTON BAKER, BART. London Kegan Paul, Trench, Trübner & Co., Limited. Price 125.

For the last few years questions of International Law have been more frequent and more important; the result is an increased interest in the subject, which ought to lead to an increased study of the science. To meet this demand Sir Sherston Baker has brought out his modestly named work, which we think is likely to reach a larger circle than the students for whom it was prepared. Very great pains and knowledge have obviously been devoted to its preparation, and although the reader will not find in it a solution of all the mooted points at present before the public, he will find sound principles laid down which will help him to form opinions of his own. The only fault we have to find is with the Index, which is perhaps not quite full enough for ready reference in a book of this importance.

International Courts of Arbitration. By THOMAS BALCH. Phila delphia Henry S. Coates & Co. 1899.

This is a reprint of an article which appeared in the Law Magazine and Review for November, 1874, with the addition of explanatory notes by Mr. Thomas Willing Balch, the author's son. Its republication in a separate form comes at an opportune time when the Peace Conference at the Hague is completing its scheme of a Permanent Court of Arbitration; and it is interesting as evidence of

the growth of the idea of arbitration as a system available in most cases of international disputes between civilized peoples, and for the account which it gives of the sympathy of President Lincoln, Mr. Cobden, and Professor Lorimer with the views of the author.

A Digest of Cases relating to Shipping, Admiralty, and Insurance Law from the Reign of Elizabeth to the end of 1897. By R. G. MARSDEN, Barrister-at-Law. London: Sweet & Maxwell, Limited,

and Stevens & Sons, Limited. 1899.

There is practically nothing to say about this work except that the laborious task of collecting all the cases bearing upon Shipping Law has been admirably performed by the well-known author of the standard work on the Law of Collisions, and that the writer has earned thereby the gratitude of all those who are interested in Shipping or Maritime Law, for a more handy or useful work of reference could hardly be imagined.

The Specific Performance of Contracts. By WILLIAM DONALDSON RAWLINS, Q.C., M.A. London: Sweet & Maxwell, Limited. 1899.

This work is stated, on the title page, to be an expansion of an article on The Encyclopædia of the Laws of England, and in his preface the author only claims for it the modest position of "a concise text-book," which aims at discharging the modest function of a finger post. We think he has underrated the value of his work; it is an admirable treatise on the main principles of Specific performance. The good arrangement, lucid style, and "rigorous selection" of authorities should render it invaluable to students, and of great assistance to practitioners.

London Water Supply. By H. C. RICHARDS, Q.C., M.P., W. H. C. PAYNE, L.C.C., and J. P. H. SOPER, B.A., LL.B. London: P. S. King & Son. 1899.

The water supply of London is a very important question, and all those who wish to have a clear idea of the history of the numerous inquiries that have taken place, and of all the schemes suggested with relation to it, will find the same in this book with the facts and arguments on both sides lucidly and impartially set out, and with chapters on the difficult and complicated law by means of which the Water Companies rule us.