by 2 than in 1909; 14 were disposed of without a hearing, and the result on the list was to leave 164 appeals pending at the end of the year as against 100 at the commencement, whilst of the Judgments appealed against, 43 were affirmed and 21 reversed. The Court sat 76 days in 1910, and 91 in 1909. But if there was an increase in cases before the Judicial Committee, on the other hand there was a considerable reduction in the House of Lords cases; the proceedings begun falling from 108 to 89; but curiously enough, there is a considerable increase in the number of cases heard and determined, which rise from 60 to 74. The business of the two supreme Courts of Appeal is reviewed in two tables, of which the first gives the number of petitions to the Judicial Committee and the appeals to the House of Lords for the last ten years, and the second gives the numbers for matters heard during the same period. No connection between the number of cases entered and those determined can be traced. It could hardly be expected that there would be any, as the number of matters determined must depend more on the length of the cases, the possibility of fixing Courts, etc., than on the amount of business to be done.

The average costs per case in the House of Lords are about £100 higher than in the Judicial Committee. An elaborate examination has been made of 51 cases in the House of Lords, reported in the Law Reports for 1910, with the object of ascertaining the per-centage of dissentient judgments both in that Court and in the Court of Appeal and High Court. It is difficult to discuss it without setting out the tables, but the short result is that "in the Court of Appeal, there had been dissentients to 27 per cent. of the judgments which were the subjects of appeal; in the House of Lords there were dissentients in only 10 per cent. of the final decisions." Another table gives the average numbers per case of the

judges for and against the final decisions, which range from 95 per cent. for, and 5 per cent. against, in cases where the House of Lords affirms the Court of Appeal which affirmed the High Court, to 55 per cent. for, and 45 per cent. against, in cases where the House of Lords reverses the Court of Appeal which has confirmed a judgment of the High Court. There is a slight decrease in the number of appeals set down in the Court of Appeal (814 against 826); this is more than accounted for by the smaller number of appeals from interlocutory orders (208 against 224). The decline would have been more marked if it had not been for the increase in the appeals under the Workmen's Compensation Act which rose to 134, which is the largest number yet recorded. It is interesting to note the statement in Sir John Macdonell's introduction, that "out of 100 cases in which the point in the Act on which the appeal rose is known, no fewer than 25 turned on the words of the statute, 'accident arising out of and in the course of the employment.'

There is a slight decline in the appeals disposed of (827 against 867), though this is more than the whole number set down. This is rather more often the case than not, as in the figures given here for 10 years it occurs six times out of ten, and in 1903 only 801 appeals were set down, and 948 were disposed of, and yet 260 were pending at the end of the year. The number pending at the end of 1910, viz., 152, is the smallest number for the whole ten years.

The business in the Chancery Division has again declined, and the figures would seem to show that this decline is becoming "more accentuated." The Editor has calculated the quinquennial averages since 1886, and it gives, with the exception of one period, an increasing average decline in proceedings begun. In 1886-90, the average decline was 2.21 per cent.; 1891-5, 3'92 per cent.; 1896-1900, an increase of 3.75 per cent.; 1901-5, decline of 6.79 per cent.; and from 1906-10, the large decline of 1164 per cent.

The Editor, in his Introduction, gives the number of proceedings begun in one place as 6,432, and in another as 6,006, the latter figure corresponding with the Summary of Proceedings in the Comparative Table B. When this last figure is compared with the Annual Average, 1886–90, given in the same Table, which is 7,523.8, it becomes apparent how the business of the Chancery Courts has fallen off. The actual number of writs issued was rather larger (3,101 against 2,850); but there is a substantial reduction alike in the orders made, the actions disposed of, the number of taxations, the amount of costs brought in, and the amount allowed. Last but not least, as showing the state of business, the fees were £42,847 against £43,999. The average amount for 1886-90 was £62,628. A rather interesting Table the Editor has prepared gives the amount of work gone through per judge from 1890, and it shows that on paper it has much diminished. The annual average of 1890-94, when there were only five judges, was per judge:-proceedings commenced, 1,4583; actions set down, 1533; actions tried, 106. For 1910, the corresponding figures were:proceedings commenced, 1,001; actions set down, 96; actions tried, 748. The number of days the judges sat was 1,151, slightly less than in 1909, when they sat for 1,221 days. All this time was not occupied with Chancery business proper, as sittings in the Court of Appeal and as additional judges of the King's Bench Division are also included. The Editor's summing up is: "On the whole, the returns tell of a steadily declining business in this Division; it is one of the most striking facts in the returns of recent years."

The business of the King's Bench Division has also diminished, though not to a great extent. The number of originating and interlocutory writs, etc., was 61,899, the lowest number on record, being 1,079 less than in 1909, and over 3,300 than the annual average 1906-10. Sum

monses also show a falling off, being 34,796 against 36,105; but curiously enough, the number of orders drawn up has increased (37,436, against 36,595). On examining the figures as to appeals to a Judge from Masters and District Registrars, the comparison is rather in favour of the Masters, who, out of 1,100 appeals, had 606 affirmed, 163 varied, and 211 reversed. The Registrars, on the other hand, out of 76 appeals, had 31 affirmed, 19 varied, and 26 reversed. The number of cases set down was 3,271 against 3,493, but on the other hand there was an increase in the number of actions tried, that rising from 2,126 to 2,234. This last, Sir John attributes to the increase in the number of judges of that division, which took place in the latter part of the year. A remarkable feature of the year's statistics is the increase in the cases tried by a jury. The numbers were 1,303 against 771 tried by a judge only; this is an increase of 8 per cent. on the previous, and about 51 per cent. on the annual average 1906-10. Sir John has taken much trouble to discover whether the allegations that the damages awarded by juries has tended of late to increase, and particularly in actions for libel and slander, is correct. With this object he has tabulated the amounts recovered in all actions generally for the last ten years, and the damages recovered in libel actions during the same period. In the first table the figures vary so that it seems impossible to come to any conclusion. In the first year, 1901, the amount given as recovered is £679,955 in 950 actions, or an average of £716 per action. The very next year, 1902, the total falls to £486,107 recovered in 1,110 actions, or £438 per action. The next year the average amount recovered per action falls lower still, to £379; but if we look up the table a few years we find that in 1907 the enormous amount of £1,179,420 was received in only 772 actions, or £1,528 per action. In 1910 there was £399,236 in 836 actions, or £478 per action. Sir John considers that in actions for libel and slander there

is a tendency indicated to give large damages, as shown by the figures for 1908, when there were two verdicts for amounts exceeding £5,000. The figures in that year were however very exceptional, as no less than £40,964 was recovered in 33 actions, whereas only three years before, in 1905, the amount was only £2,020 in 16 actions; but a few years before that, in 1902, £13,424 was recovered in 32 actions. In 1910 there were an exceptional number of libel actions tried, namely, 43, and the amount recovered, £23,793, was substantial. The result of trials generally would seem to show that the plaintiff was in the right in three cases out of four. The circuit figures show a considerable falling off, the cases set down being 822 and those tried 646, against 935 and 699 respectively. The quinquennial averages show that the average entered in the period 1886-90 was 1,226, and tried 1,200; while for 1906-10 the figures had sunk to 855 and 640. The amount recovered on circuit was £104,819. If we look at the nature of the actions tried on circuit, we may note that the most frequent form of action is for compensation for personal injuries. In 1910, 127 actions were brought for this cause, of which 89 were disposed of in Court, and the amount recovered was £8,925. The next largest number of actions was brought for slander; the number was 98 and the amount recovered £1,083. Claims for libel, and money paid, etc., have produced almost the same number of actions, namely, 75 and 72, but the amounts recovered are very different. The actions for libel resulted in the recovery of £2,542, while the amount recovered for money paid, etc., is the highest item in the summary, and is no less than £24,106; the previous year it had been £30,174. An unusually large amount was recovered for fraudulent representations, namely, £8,925. The amounts recovered at different Assize towns vary curiously. At the Winter Assize £20,133 was recovered at Manchester against only