(4) All remittances, referred to in the first paragraph, made without payment of this tax will be considered as contraband. Parcel Post to United States. Parcel post packages, ordinary and registered, up to a weight limit of 22 pounds are now accepted for dispatch to Latvia at the postage rate of 12 cents a pound or fraction of a pound, subject to prohibitions appearing in section 187, on pages 184 and 185, of the July, 1920, U. S. Postal Guide. Packages will be dispatched to New York for onward transmission to destination. Packages mailed in Latvia which can not be delivered or are refused will be returned to New York at the expiration of 30 days from date of their receipt at the post offices of destination, for return to the post office of origin. MEXICO. Reorganization of the Comision De Henequen. On November 30, 1920, "El Diario Oficial" published the law of the newly elected State legislature of the State of Yucatan, by which the Comision Reguladora del Mercado de Henequen was reorganized as an official institution. NICARAGUA. Mail Rates in Americas. See "Bolivia" above. PARAGUAY. The General Moratorium Law. Article 1. The moratorium decreed by law No 444 for money obligations due or about to fall due before January II, 1921, is hereby extended for a period of three months. Art. 2. All money payments falling due between January 11, 1921 and April 11, 1921 are hereby suspended for three months. Art. 3. To receive the protection afforded by this moratorium or to benefit by the suspension of payments granted by this law, the debtor shall have to guarantee his obligations to the satisfaction of the creditor. In case of disagreement between debtor and creditor over the sufficiency of the guaranty, the question shall be submitted to the Commercial Court of Appeals, and it shall give judgment within 48 hours after the question had been submitted, without further appeal. Art. 4. During the moratorium and the suspension of payments established by this law, the obligations will bear the customary interest or else bank interest. Art. 5. Obligations, such as taxes, interest, board bills, wages, salaries, rents, remunerations arising from services, trusts, and fee in general, are excepted. Art. 6. The obligations of the Banco de Espana and Paraguay arising from the special moratorium law, as well as those contracted after January 11, 1921, are also excepted. Moratorium for Banco Mercantil. Article 1. The moratorium granted to the Banco Mercantil by article I of law No. 444 of November 11, 1920, is hereby extended till May 16, 1921. Art. 2 During this moratorium the bank shall be able to realize the following operations: (a) To receive deposits that shall not be subject to the moratorium and to accept checks against these funds; (b) to collect bills of exchange on commission and to remit the proceeds; (c) to accept drafts and letters of credit of foreign banks. Art. 3 The bank shall be able to realize operations different from those mentiened in the previous article only when first authorized by the President of the Republic and provided that such operations do not diminish the bank's assets. Circulation of Bank Notes. The President of Paraguay signed a decree on November 18, 1920 authorizing the "Oficina de Cambios" (Exchange Office) to put into circulation the notes acquired from "El Banco de La Republica", numbered from 1 to 10,000, with a value of 1,000 pesos Papaguayan paper currency for each note, except four which were canceled. The notes will beat a stamp of authorization which will read: "Emission of the State, Law No 432, September 8, 1920." and will be signed by the president and manager of the Exchange Office. PERU. Hunting of Chinchillas Prohibited. By a resolution recently passed by the Government of Peru, "the hunting of chinchillas in the territory of the No Fixed Price on Foreign Flour. A royal order has been issued through the Ministry of Public Works to the effect that the fixed price of 82 pesetas per 100 kilo on flour, as imposed by the royal order of September II last, is not to be applied to that obtained from abroad or to flour that has been manufactured from wheat purchased in the open foreign market. Increased Weight of Parcel Post. Orders have been issued authorizing the admission of parcel post packages in Spain up to 10 kilos (22 pounds) each, provided that total shipments from one consignor to one consignee by the same boat do not amount to more than 25 kilos (55 pounds). SWEDEN. Regulations for the Use of Artificial Leather. The new Swedish regulations regarding the uses of artificial leather in shoes become effective immediately. A new system of marking shoes is provided for by the new regulations, and it is provided that ordinary cardboard may no longer be used in shoes manufactured for the market. Artificial leather, cardboard or chemically prepared fiber board, however, may be used for filling in sole construction, for "bottom binding", for toe stiffening, and reinforcement of the insole under the heal. It is provided that shoes so manufactured must be furnishhed with the mark "A", which mark is also to be used on those in which no artificial leather has been used. Further, artificial leather and similar material may be used in the heels of all kinds of shoes provided that it is removed at 12 millimeters from the wearing surfaces of the men's shoes and 15 millimeters in women's shoes. It also may be used in the manufacture of turned shoes, even as heels without the above restriction, and in the manufacture of shoes with uppers or tops of textile materials, used for the strenghtening of the binding sole in its entirety. Shoes thus made, it is provided, are to be marked "B". UNITED STATES OF AMERICA. Control of Sugar Abolished. The President by a proclamation isued on November 4 1920 ordered that: "Licenses heretofore required for the importation, manufacture storage or distribution of certain necessaries are hereby cancelled, effective Nov. 15, 1920, with respect to the following: "All persons, firms, corporations or associations engaged in the business of importing, manufacturing, storing or distributing sugar, or any product or by-product of the foregoing named necessaries. "Regulations issued under the said act covering licenses so dealing in these commodities are hereby canceled, effective Nov. 15. 1920." Transactions in Russian Currency Permitted. "The Secretary of the Treasury and the Federal Reserve Board announce that with the approval of the Department of State and in order to give force and effect to the action of that department in removing restrictions in the way of trade and communication with Soviet Russia as announced by that department on July 7, 1920, all rules and regulations restricting the exportation of coin, bullion and currency to that part of Russia now under the control of the so-called Bolshevist Government or restricting dealings or exchange transactions in Russian rubles, or restricting transfers of credit or exchange transactions with that part of Russia now in the control of the so-called Bolshevist Government, have been suspended, effective Dec. 18, 1920, until further notice." Regulations for Alien Passports. 1. The aliens abroad should obtain passports from the foreign Government to which they owe allegiance. 2. They should present the passports in person to the American Commissioner or Consul in the district abroad where they now reside. At the office of the Commissioner or Consul they should make a declaration or application for a vise permitting them to proceed to the United States. They should take with them three small photographs. It is also desirable for them to present letters or affidavits from relatives or friends in this country setting forth details as to why they desire to come to the United States, what their occupation will be while in this country, with whom they will reside and a statement (if the aliens are to be supported by relatives already in the United States) as to the ability of the relatives to care for them properly on arrival. Copyright Protection to Danish Authors. The President signed proclamation granting to subjects of Denmark the protection of the American copyright law of March 4, 1909, and the acts amendatory thereof. The proclamation does not afford protection to works which have been republished in the United States since Aug. 1, 1914. It was issued under an act of Congress, approved Dec. 18, 1919, which authorized the President to grant protection to "all works made the subject of copyright by the laws of the United States first produced or published abroad after Aug. 14, 1914, and before the date of the President's proclamation of peace, of which the authors or proprietors are citizens or subjects of any foreign State or nation granting similar protection for works by citizens of the United States." Satisfactory official assurance has been given by the Government of Denmark that the royal decrees of Feb. 22, 1913, issued by virtue of the authority conferred by the Danish copyright law of April 1, 1921, extending to Ameircan authors the rights and privileges conferred by that law (including reproduction by mechanical instruments and cinematographic representation), were not canceled during the war and that, if protection is granted in the United States to works by Danish authors which have been published during the war, protection in Denmark for American authors would take effect automatically. Ship Mortgage Act 1920. Sections relating to aliens: Subsection J. (c) If any person enters into any contract secured by, or upon the credit of, a vessel of the United States covered by a preferred mortgage, and suffers pecuniary loss by reason of the failure of the collector of customs, or any officer, employee, or agent thereof, properly to perform any duty required of the collector under the provisions of this section, the collector of customs shall be liable to such person for damages in the amount of such loss. If any such person has caused any such loss by reason of the failure of the mortgagor, or master of the mortgaged vessel, or any officer, employee, or agent thereof, to comply with any provision of subsection E or F or to file an affidavit as required by subdivision (a) of subsection D, correct in each particular thereof, the mortgagor shall be liable to such person for damages in the amount of such loss. The district courts of the United States are given jurisdiction (but not to the exclusion of the courts of the several States, Territories, Districts or possessions) of suits for the recovery of such damages, irrespective of the amount involved in the suit or the citizenship of the parties thereto. Such suit shall be begun by personal service upon the defendants within the limits of the district. Upon judgment for the plaintiff in any such suit, the court shall include in the judgment an additional amount for costs of the action and a reasonable counsel's fee, to be fixed by the court. Subsection K. A preferred mortgage shall constitute a lien upon the mortgaged vessel in the amount of the outstanding mortgage indebtedness secured by such vessel. Upon the default of any term or condition of the mortgage, such lien may be enforced by the mortgagee by suit in rem in admiralty. Original jurisdiction of all such suits is granted to the district courts of the United States exclusively. In addition to any notice by publication, actual notice of the commencement of any such suit shall be given by the libellant, in such manner as the court shall direct, to (1) the master, other ranking officer, or caretaker of the vessel, and (2) any person who has recorded a notice of claim of an undischarged lien upon the vessel, as provided in subsection G, unless after search by the libellant satisfactory to the court, such mortgagor, master, other ranking officer, caretaker, or claimant is not found within the United States. Failure to give notice to any such person, as required by this subsection, shall not constitute a jurisdictional defect; but the libellant shall be liable to such person for damages in the amount of his interest in the vessel terminated by the suit. Suit in personam for the recovery of such damages may be brought in accordance with the provisions of subdivision (c) of section 10. Subsection O. (a) The documents of a vessel of the United States covered by a preferred mortgage may not be surrendered (except in the case of the forfeiture of the vessel or its sale by the order of any court of the United States or any foreign country) without the approval of the board. The board shall refuse such approval unless the mortgagee consents to such surrender. (b) The interest of the mortgagee in a vessel of the United States covered by a mortgage, shall not be terminated by the forfeiture of the vessel for a violation of any law of the United States unless the mortgagee authorized, consented, or conspired to effect the illegal act, failure, or omission which constituted such violation. (d) No right under a mortgage of a vessel of the United States shall be assigned to any person not a citizen of the United States without the approval of the board. Any assignment in violation of any provision of this section shall be void. (e) No vessel of the United States shall be sold by order of a district court of the United States in any suit in rem in admiralty to any person not a citizen of the United States. Mail Rates in Americas. See "Bolivia" above Modification of Parcel Post Convention with France. Parcel Post to Rumania Suspended. ALIENS. Art. 12, para. 1, of the Aliens Order, 1919, which empowers the Secretary of State "if he deems it to be conducive to the public good" to make a deportation order against an alien is not ultra vires. In acting under the article the Secretary of State is not a judicial, but is an executive, officer, and is therefore not bound to hold an inquiry or give the person against whom he proposes to make a deportation order the opportunity of being heard. Rex v. Leman Street Police Station (Inspector of). Ex parte Venicoff. Rex v. Secretary of State for Home Affairs. Ex parte Same-Div. Ct. (1920) 3 K. B. 72. 36 T. L. R. 67. BANKRUPTCY. By an order of the Supreme Court of the Union of South Africa, made under the Insolvency Act, 1916, of the Union of South Africa, the estate of an insolvent was sequestrated for the benefit of his creditors; subsequently a trustee of the estate was elected and was declared entitled to administer the estate in accordance with the said Act. The insolvent was entitled to certain freehold and leasehold property in Ireland. Under the law of the Union of South Africa the trustee was entitled to the immovable property of the insolvent situated in Ireland, so far as such right did not conflict with the law in Ireland. The Supreme Court of South Africa having requested the Irish Courts to act in its aid, the trustee applied for an (4) All remittances, referred to in the first paragraph, made without payment of this tax will be considered as contraband. Parcel Post to United States. Parcel post packages, ordinary and registered, up to a weight limit of 22 pounds are now accepted for dispatch to Latvia at the postage rate of 12 cents a pound or fraction of a pound, subject to prohibitions appearing in section 187, on pages 184 and 185, of the July, 1920, U. S. Postal Guide. Packages will be dispatched to New York for onward transmission to destination. Packages mailed in Latvia which can not be delivered or are refused will be returned to New York at the expiration of 30 days from date of their receipt at the post offices of destination, for return to the post office of origin. MEXICO. Reorganization of the Comision De Henequen. On November 30, 1920, "El Diario Oficial" published the law of the newly elected State legislature of the State of Yucatan, by which the Comision Reguladora del Mercado de Henequen was reorganized as an official institution. NICARAGUA. Mail Rates in Americas. See "Bolivia" above. PARAGUAY. The General Moratorium Law. Article 1. The moratorium decreed by law No 444 for money obligations due or about to fall due before January 11, 1921, is hereby extended for a period of three months. Art. 2. All money payments falling due between January 11, 1921 and April 11, 1921 are hereby suspended for three months. Art. 3. To receive the protection afforded by this moratorium or to benefit by the suspension of payments granted by this law, the debtor shall have to guarantee his obligations to the satisfaction of the creditor. In case of disagreement between debtor and creditor over the sufficiency of the guaranty, the question shall be submitted to the Commercial Court of Appeals, and it shall give judgment within 48 hours after the question had been submitted, without further appeal. Art. 4. During the moratorium and the suspension of payments established by this law, the obligations will bear the customary interest or else bank interest. Art. 5. Obligations, such as taxes, interest, board bills, wages, salaries, rents, remunerations arising from services, trusts, and fee in general, are excepted. Art. 6. The obligations of the Banco de Espana and Paraguay arising from the special moratorium law, as well as those contracted after January 11, 1921, are also excepted. Moratorium for Banco Mercantil. Article 1. The moratorium granted to the Banco Mercantil by article I of law No. 444 of November 11, 1920, is hereby extended till May 16, 1921. Art. 2 During this moratorium the bank shall be able to realize the following operations: (a) To receive deposits that shall not be subject to the moratorium and to accept checks against these funds; (b) to collect bills of exchange on commission and to remit the proceeds; (c) to accept drafts and letters of credit of foreign banks. Art. 3 The bank shall be able to realize operations different from those mentiened in the previous article only when first authorized by the President of the Republic and provided that such operations do not diminish the bank's assets. Circulation of Bank Notes. The President of Paraguay signed a decree on November 18, 1920 authorizing the "Oficina de Cambios" (Exchange Office) to put into circulation the notes acquired from "El Banco de La Republica", numbered from to 10,000, with a value of 1,000 pesos Papaguayan paper currency for each note, except four which were canceled. The notes will beat a stamp of authorization which will read: "Emission of the State, Law No 432, September 8, 1920." and will be signed by the president and manager of the Exchange Office. PERU. Hunting of Chinchillas Prohibited. By a resolution recently passed by the Government of Peru, "the hunting of chinchillas in the territory of the No Fixed Price on Foreign Flour. A royal order has been issued through the Ministry of Public Works to the effect that the fixed price of 82 pesetas per 100 kilo on flour, as imposed by the royal order of September II last, is not to be applied to that obtained from abroad or to flour that has been manufactured from wheat purchased in the open foreign market. Increased Weight of Parcel Post. Orders have been issued authorizing the admission of parcel post packages in Spain up to 10 kilos (22 pounds) each, provided that total shipments from one consignor to one consignee by the same boat do not amount to more than 25 kilos (55 pounds). 1 SWEDEN. Regulations for the Use of Artificial Leather. The new Swedish regulations regarding the uses of artificial leather in shoes become effective immediately. Arti A new system of marking shoes is provided for by the new regulations, and it is provided that ordinary cardboard may no longer be used in shoes manufactured for the market. ficial leather, cardboard or chemically prepared fiber board, however, may be used for filling in sole construction, for "bottom binding", for toe stiffening, and reinforcement of the insole under the heal. It is provided that shoes so manufactured must be furnishhed with the mark "A", which mark is also to be used on those in which no artificial leather has been used. Further, artificial leather and similar material may be used in the heels of all kinds of shoes provided that it is removed at 12 millimeters from the wearing surfaces of the men's shoes and 15 millimeters in women's shoes. It also may be used in the manufacture of turned shoes, even as heels without the above restriction, and in the manufacture of shoes with uppers or tops of textile materials, used for the strenghtening of the binding sole in its entirety. Shoes thus made, it is provided, are to be marked "B". UNITED STATES OF AMERICA. Control of Sugar Abolished. The President by a proclamation isued on November 4 1920 ordered that: "Licenses heretofore required for the importation, manufacture storage or distribution of certain necessaries are hereby cancelled, effective Nov. 15, 1920, with respect to the following: "All persons, firms, corporations or associations engaged in the business of importing, manufacturing, storing or distributing sugar, or any product or by-product of the foregoing named necessaries. "Regulations issued under the said act covering licenses so dealing in these commodities are hereby canceled, effective Nov. 15. 1920." Transactions in Russian Currency Permitted. "The Secretary of the Treasury and the Federal Reserve Board announce that with the approval of the Department of State and in order to give force and effect to the action of that department in removing restrictions in the way of trade and communication with Soviet Russia as announced by that department on July 7, 1920, all rules and regulations restricting the exportation of coin, bullion and currency to that part of Russia now under the control of the so-called Bolshevist Government or restricting dealings or exchange transactions in Russian rubles, or restricting transfers of credit or exchange transactions with that part of Russia now in the control of the so-called Bolshevist Government, have been suspended, effective Dec. 18, 1920, until further notice." Regulations for Alien Passports... 1. The aliens abroad should obtain passports from the foreign Government to which they owe allegiance. 2. They should present the passports in person to the American Commissioner or Consul in the district abroad where they now reside. At the office of the Commissioner or Consul they should make a declaration or application for a vise permitting them to proceed to the United States. They should take with them three small photographs. It is also desirable for them to present letters or affidavits from relatives or friends in this country setting forth details as to why they desire to come to the United States, what their Occupation will be while in this country, with whom they will reside and a statement (if the aliens are to be supported by relatives already in the United States) as to the ability of the relatives to care for them properly on arrival. Copyright Protection to Danish Authors. The President signed proclamation granting to subjects of Denmark the protection of the American copyright law of March 4, 1909, and the acts amendatory thereof. The proclamation does not afford protection to works which have been republished in the United States since Aug. I, 1914. It was issued under an act of Congress, approved Dec. 18, 1919, which authorized the President to grant protection to "all works made the subject of copyright by the laws of the United States first produced or published abroad after Aug. 14, 1914, and before the date of the President's proclamation of peace, of which the authors or proprietors are citizens or subjects of any foreign State or nation granting similar protection for works by citizens of the United States." Satisfactory official assurance has been given by the Government of Denmark that the royal decrees of Feb. 22, 1913, issued by virtue of the authority conferred by the Danish copyright law of April 1, 1921, extending to Ameircan authors the rights and privileges conferred by that law (including reproduction by mechanical instruments and cinematographic representation), were not canceled during the war and that, if protection is granted in the United States to works by Danish authors which have been published during the war, protection in Denmark for American authors would take effect automatically. Ship Mortgage Act 1920. Sections relating to aliens: Subsection J. (c) If any person enters into any contract secured by, or upon the credit of, a vessel of the United States covered by a preferred mortgage, and suffers pecuniary loss by reason of the failure of the collector of customs, or any officer, employee, or agent thereof, properly to perform any duty required of the collector under the provisions of this section, the collector of customs shall be liable to such person for damages in the amount of such loss. If any such person has caused any such loss by reason of the failure of the mortgagor, or master of the mortgaged vessel, or any officer, employee, or agent thereof, to comply with any provision of subsection E or F or to file an affidavit as required by subdivision (a) of subsection D, correct in each particular thereof, the mortgagor shall be liable to such person for damages in the amount of such loss. The district courts of the United States are given jurisdiction (but not to the exclusion of the courts of the several States, Territories, Districts or possessions) of suits for the recovery of such damages, irrespective of the amount involved in the suit or the citizenship of the parties thereto. Such suit shall be begun by personal service upon the defendants within the limits of the district. Upon judgment for the plaintiff in any such suit, the court shall include in the judgment an additional amount for costs of the action and a reasonable counsel's fee, to be fixed by the court. Subsection K. A preferred mortgage shall constitute a lien upon the mortgaged vessel in the amount of the outstanding mortgage indebtedness secured by such vessel. Upon the default of any term or condition of the mortgage, such lien may be enforced by the mortgagee by suit in rem in admiralty. Original jurisdiction of all such suits is granted to the district courts of the United States exclusively. In addition to any notice by publication, actual notice of the commencement of any such suit shall be given by the libellant, in such manner as the court shall direct, to (1) the master, other ranking officer, or caretaker of the vessel, and (2) any person who has recorded a notice of claim of an undischarged lien upon the vessel, as provided in subsection G, unless after search by the libellant satisfactory to the court, such mortgagor, master, other ranking officer, caretaker, or claimant is not found within the United States. Failure to give notice to any such person, as required by this subsection, shall not constitute a jurisdictional defect; but the libellant shall be liable to such person for damages in the amount of his interest in the vessel terminated by the suit. Suit in personam for the recovery of such damages may be brought in accordance with the provisions of subdivision (c) of section 10. Subsection O. (a) The documents of a vessel of the United States covered by a preferred mortgage may not be surrendered (except in the case of the forfeiture of the vessel or its sale by the order of any court of the United States or any foreign country) without the approval of the board. The board shall refuse such approval unless the mortgagee consents to such surrender. (b) The interest of the mortgagee in a vessel of the United States covered by a mortgage, shall not be terminated by the forfeiture of the vessel for a violation of any law of the United States unless the mortgagee authorized, consented, or conspired to effect the illegal act, failure, or omission which constituted such violation. (d) No right under a mortgage of a vessel of the United States shall be assigned to any person not a citizen of the United States without the approval of the board. Any assignment in violation of any provision of this section shall be void. (e) No vessel of the United States shall be sold by order of a district court of the United States in any suit in rem in admiralty to any person not a citizen of the United States. ALIENS. Art. 12, para. 1, of the Aliens Order, 1919, which empowers the Secretary of State "if he deems it to be conducive to the public good" to make a deportation order against an alien is not ultra vires. In acting under the article the Secretary of State is not a judicial, but is an executive, officer, and is therefore not bound to hold an inquiry or give the person against whom he proposes to make a deportation order the opportunity of being heard. Rex v. Leman Street Police Station (Inspector of). Ex parte Venicoff. Rex v. Secretary of State for Home Affairs. Ex parte Same-Div. Ct. (1920) 3 K. B. 72. 36 T. L. R. 67. BANKRUPTCY. By an order of the Supreme Court of the Union of South Africa, made under the Insolvency Act, 1916, of the Union of South Africa, the estate of an insolvent was sequestrated for the benefit of his creditors; subsequently a trustee of the estate was elected and was declared entitled to administer the estate in accordance with the said Act. The insolvent was entitled to certain freehold and leasehold property in Ireland. Under the law of the Union of South Africa the trustee was entitled to the immovable property of the insolvent situated in Ireland, so far as such right did not conflict with the law in Ireland. The Supreme Court of South Africa having requested the Irish Courts to act in its aid, the trustee applied for an 14 order vesting the said property in him. Held, that he was entitled to such order. In re Bolton, (Ir). 1920 2 I. R. 324. CONTRACT. An agreement made in British Territory to allow rebates upon freights paid for the carriage of goods by sea to a foreign country cannot be repudiated, after the goods have been carried and the freights paid, on the ground that payment of rebates would subject the shipowners to penalties under legislation of the foreign country. Judgment of the Supreme Court of Trinidad affirmed. Trinidad Shipping and Trading Co. v. Alston (G. R.) & Co., J. C. 1920 A. C. 888. DAMAGES. The defts contracted to carry goods for the plt. from England to Italy and deliver them there on Feb 10, 1919, but in breach of their contract failed to do so, and converted the goods. In an action by the plt. the Court fixed the damages as the value of the goods in Italy on Feb. 10 aforesaid-namely, 190 lire per 100 lb: Held that in arriving at the proper equivalent in British currency for the purposes of assessing these damages, the rate of exchange prevailing between the two countries on Feb. 10, 1919, when the breach was committed, and not that prevailing at the date of the judgment, should be adopted. Di Ferdinando v. Simon, Smits & Co., 1920 2 K. B. 704; Affirmed on appealC. A. 1920 W. N. 273. Where, upon the breach of a contract the person in default -whether seller or buyer-becomes liable for the payment of a sum of money in a foreign currency, the damages, for the purposes of an English judgment, must be assessed as at the date of the default, and the sum payable must be converted into English currency accordincg to the rate of exchanges prevailing at that date. Barry v. Van den Hurk-1920 2 K. B. 709; 36 T. I. R. 663. The respondents sold to the claimant sodium sulphide in drums. The drums were delivered to the claimant in Manchester, but the respondents knew that they were intended for export. Owing to the difficulty of opening and reclosing the drums it is impracticable to open them until the contents are actually required for use. The drums were resold by the claimant and owing to congestion on the French rys. and other causes they did not reach the ultimate consignees at Lyons and On the drums beGenoa respectively till some months later. ing opened by those consignees the contetns were found to be not sodium sulphide but caustic soda of inferior quality. The drums were thereupon rejected. On a claim for damages by the claimant against the respondents: Held, that the damages were to be assessed according to the prices ruling, not at the date of delivery in Manchester, but at the date when the drums were opened by the ultimate consignees at Lyons and Genoa. Van den Hurk v. R. Martens & Co., (1920) 1 K. B. 850; 89 L. J. K. B. 545; 123 L T 110 INSURANCE. The appellants, a Dutch Co., insured a steamer and freight On against a total loss with the respondent insurance Co. Aug. 18. 1914, the ship left Petrograd on a voyage to Helsingfors. She was escorted by Russian warships until she was outside the Russian minefield, when the escort left her. After she proceeded another fifty-seven miles she struck three mines in succession, and was totally lost. The mines were assumed to be fixed mines which had been placed by the Russians to protect the northern coasts of the Gulf of Finland and had broken adrilft. Each of the policies contained the clause "Warranted free from capture, seizure, dentention, and all other consequences of hostilities (piracy, riots, civil commotions and barratry excepted)" and also a clause providing that the insurance was specially to cover loss through explosions. In an action on the policies the appellants contended that the ship was lost by marine and not war risks, and that the clause warranted free from capture, etc., referred to hostile acts which amounted to taking possession of the ship insured and did not include consequences of hositilities which were not eiusdem generis with capture, seizure, and detention such as the destruction of the ship by drifting mines: Held, that the loss of the vessel was the direct consequences of hostilities, and the respondents were not liable therefore under the policies. Decision of the C. A. affirmed. Stoomvaart Maatschappij Sophie H. v. Merchants' Marine Insurance Co. H. L. (E.) 122 L T. 295; 36 T. L. R. 73. MARRIAGE. A marriage celebrated in a British colony according to Church of England usage may be proved by the production of a certificate of an entry in an ecclesiastical register without 'expert evidence of the validity of the marriage according to the local law Perry v. Perry 89 L. J. (P). 192. A marriage celebrated in a British colony may be established without further evidence by a certificate of its celebration, prescribed by a colonial ctatute and made admissible by that statute. Bonhote v. Bonhote 89 L. J. (P.) 140: 123 L. T. 174. SHIPPING. A chater party dated May 18, 1917, provided that a steamer should proceed to Norfolk, Virginia, and there load a cargo of coal for delivery at Bilbao. On Jul. 9, 1917, the President of the United States issued a Proclamation, which came into force on Jul. 15, prohibiting the export of coal to Spain except under license from the American Government. On Jul. 11 a co. which had acted as agents at Norfolk for the charterer and also for the shipowners, applied for a license for the export of the cargo of coal. The steamer arrived at Norfolk on Jul. 14. The cargo was duly loaded, but the steamer was detained at Norfolk while waiting for the license which, without default on the part of the agents, was not obtained until Aug. 1. The owners claimed damages from the charterers for the detention of the steamer : Held, that as the owners had, through their agents, knowledge at the time the cargo was loaded that it was necessary to obtain an export license, which might involve delay, the charterer was not liable for the detention of the steamer. Sebastian S. S. (Owners) v. De Vizcaya― 1920. 1. K. B. 332; 89 L. J. (K. B.) 385; 122 L. T. 541. TREATIES. By a policy of insurance effected on Nov. 2, 1918, during the European War, the deft. agreed to pay to the plt. a certain sum "in the event of peace between Great Britain and Germany not being concluded on or before Ju. 30, 1919.” On Jun. 28, 1919, these Powers signed a Treaty of Peace, but they did not exchange and deposit ratifications of the Treaty until Jan. 1920. In an action brought by the plt. against the deft. upon the policy in Aug. 1919:- Held, that peace had not been concluded between these Powers on or before Jun. 30, 1919, within the meaning of the policy, and that the plt. was therefore entitled to succeed in the action. Kotzias v. Tyser(1920) 2 K. B. 69; 122 L. T. 795; Before the outbreak of war, the dfts. the German owners of the steamship M. G., recovered judgment against the British owners of the steamship K. for the amount of the damage arising out a collision between the two vessels, and the damages were referred to the Registrar and merchants for assessment. Before the defts. had filed their claim in the registry the war had broken out. A few days before the Peace Treaty was ratified (Jan. 10, 1920) the claim and vouchers were filed, but by consent they were treated as having been filed after the ratification. Thereupon the plts. took out a summons for an order to set aside the filing and service of the claim and vouchers on the ground that under arts. 296 and 297 of the Treaty and s. 1, sub-ss. 16 and 17, of the Treaty of Peace Order, 1919, the parties had no right to litigate the claim in registry, inasmuch as, being a debt owing to German nationals, it had to be settled through the intervention of clearing houses: Held, that the deft's claim was not a debt but a right which by art. 297 of the Peace Treaty was subject to the right to be retained and liquidated "in accordance with the law of the allied state concerned"—namely, Great Britain that, not being in debt, art. 296 did not apply and that, although the defts. would not be able to handle the sum awarded, there was nothing in art. 297 or in s. I, sub-s 17, of the Treaty of Peace Order (which makes provisions with a view to making effective and enforcing (inter alia) rights belonging to German nationals) to deprive the defts. of their right to proceed to a reference, or to prevent the plts. paying money into Court with a notice that it was in satisfaction of the claim of German subjects. The Marie Gartz (1920) P. 172; 36 T. L. R. 446 TRUST. A testator by his trust disposition and settlement left the residue of his property in trust to be divided amongst his seven children, and directed that this provision was to be accepted in full of legitim, and that if any of the children should repudiate the settlement and claim their legal rights they were to forfeit all title to any share of his estate which he could dispose of by law. By a codicil the testator directed his trustees, instead of paying over to his daughter Mrs. G. her share of the residue, to hold it for her in life rent and after her death to divide it among her children. Part of the testator's residuary estate consisted of land in Argentina. By the law of that |