Agger, Joseph Edward, Watcon, Norfolk, Chemist. Mar 21 at 2 at office of Gregson and Armor, John, Denbigh, Licensed Victualler. Mar 20 at 12 at office of Parry and Co, Ashworth, Henry, Stacksteals, nr Bacup, Grocer. Mar 24 at 3 at Dog and Partridge Inn, Fennel st, Manchester. March, Rochdale Audsley, John, Gawthorpe, York, Spinner. Mar 23 at 10.15 at office of Scholes and Son Wakefield rd, Dewsbury Banister, Albert, Newgate st, Butcher. Mar 20 at 3 at 145, Cheapside. Whittington and Son, Bishopsgate st Without Berry, Charles, Eastbourne, Fishmonger. Mar 23 at 3 at office of Champion and Co, Terminus rd, Eastbourne Bolton, George, Manningham, York, Timber Merchant. Mar 21 at 3 at office of Watson and Dickons, Cheapside, Bradford Boon, Nathaniel, Ashby, Lincoln, Chemist. Mar 20 at 2 at offices of Summers, Manor st, Kingston upon Hull Bottle, Henry Alexander, Pertenhall, Bedford, Farmer. Mar 16 at 11 at offices of WadeGery, St Neots Bull, Frederick, Harrow rd, Closed Upper Manufacturer. Mar 16 at 3 at Crown Tavern, Clerkenwell gn. Goatly, Long acre Butterfeld, Isaac, Bury, Draper. Mar 22 at 3 at offices of Grundy, Union st, Bury Cadman, Arthur, Nottingham, Commission Agent. Mar 20 at 3 at offices of Norman, Nottingham Calderwood, George, Peckham, Draper. Mar 21 at 2 at offices of Soppet, Newgate st. Webb and Son, Barbican Carr, William, Blackburn, Mineral Water Manufacturer. Mar 23 at 11 at offices of Wheeler and Fletcher, Blackburn Case, Robert, Hilgay, Norfolk, Farmer. Mar 22 at 12 at County Court House, Downham Market. Reed and Wayman, Downham Market Cash, Joseph Harper, Wilson st, Finsbury, Insurance Broker. Mar 27 at 2 at offices of Henry, Holborn Chadwell, Sarah Jane, Oxford, Cutler. Mar 23 at 12 at offices of Galpin, New Inn Hall st, Oxford Craner, Frederick, Welford-on-Avon, Gloucester, Oil Salesman. Mar 20 at 12 at offices of Sanderson, Church st, Warwick Day, Ezra, Wakefield, York, Shoe Dealer. Mar 20 at 3 at the George Hotel, Wakefield. Dryden, Wakefield Dearsley, Emma, Sloane st, Milliner, Mar 17 at 2 at the Guildhall Tavern, Gresham st. Marrable Dickinson, Joseph John, Ipswich, Boot Maker. Mar 18 at 11 at offices of Mills, Elm st, Ipswich Dixon, William, Knottingley, York, Grocer. Mar 20 at 3 at offices of Foster and Raper, Ropergate, Pontefract Down, William, Stoke Newington rd, Builder. Mar 20 at 3 at offices of Stewart, Fore st Edge, Mary Ann, Birkenhead, Butcher. Mar 21 at 3 at offices of Hannan and Pugh, Duncan st, Birkenhead Fisher, Thomas, Barrow in Furness, Dealer in Iron Ore. Mar 21 at 2 at the Victoria Hotel, Church st, Barrow in Furness. Barrow, Barrow in Furness Foden, William, Salford, Lancaster, Grocer. Mar 23 at 3 at the Mitre Hotel, Cathedral yd, Manchester. Creek and Co, Manchester Grey, Thomas, Bristol, Baker. Mar 21 at 12 at offices of Atchley, Clare st, Bristol Griffiths, David, Bridgend, Glamorgan, Licensed Victualler. Mar 22 at 12.30 at offices of Randall, Nolton st, Bridgend Hargreaves, Thomas, Lancaster, Game Dealer. Mar 20 at 11 at offices of Holden and Whelon, Church st, Lancaster Harper, Edwin, Prince Teck bldgs, Earl's crt rd, Greengrocer. Mar 24 at 3 at offices of Stokes, Chancery lane Harris, Charles, Birmingham, General Dealer. Harvey, David, Chesterton, Cambridge, Cook. Mar 17 at 11 at office s of Parry, Col Mar 20 at 11 at offices of Wayman, Haslett, Alfred, Canterbury Theatre of Varieties, Manager. Mar 20 at 3 at offices of Reader, Ely pl, Holborn Hebblethwaite, Jeremiah, Wakefield, Provision Dealer. Mar 18 at 11 at offices of Kemp, Barstow sq, Wakefield Henderson, Thomas. Newcastle-upon-Tyne, Poulterer. Mar 22 at 11 at offices of Scott, White House bldgs, Pilgrim st, Newcastle-upon-Tyne Henrich, Johann George, Redesdale st, Chelsea, out of business. Mar 16 at 11 at offices of Dobson, Minories Hepper, Arthur, Launceston, Cornwall, Seedsman. Mar 17 at 12 at King's Arms Hotel, Launceston. Cowlard and Cowlard, Launceston Hillier, Henry, and Henry Hallett, Rochdale, Provision Dealers. Mar 21 at 3 at Dog and Partridge Inn, Fennel st, Manchester. Brierley, Rochdale Holt, Alfred, Gorton, Lancaster, Soap Manufacturer. Mar 20 at 3 at offices of Simpson. Manchester Howlett, James, Hedon, York, Boot Maker. Mar 20 at 3 at offices of Summers, King. ston upon Hull Humphreys, Edward, Aberystwith, Cardigan, Ship Owner. Mar 23 at 11 at offices of Hughes, Aberystwith Hurst, William Jeffrey, Bermondsey, Registrar of Births and Deaths. Mar 20 at 2 at offices of Simpson and Palmer, Southwark Hyslop, James, Blackburn, Travelling Draper. Mar 20 at 11 at offices of Wheeler and Fletcher, Blackburn Irvine, William, Sunderland, Tailor. Mar 21 at 3 at offices of Lawson, Villiers st, Sunderland Knight, George, Bloomsbury st, Auctioneer, Mar 23 at 3 at offices of Godfrey, Chancery lane. Hooper Knight, Henry, Kingsclere, Southampton, Carpenter. Mar 20 at 11 at offices of Lucas, Newbury Lawton, Frederick Alfred, Stoke upon Trent, Coal Merchant. Mar 18 at 11 at offices of Ashwell, Stoke upon Trent Leighton, Francis Henry, Oldbury, Worcester, Factors' Clerk. Mar 20 at 11 at offices of Peel, Birmingham Lomax, Benjamin Howarth, Manchester, Publisher. March 17 at 3 at offices of Nadin, King st, Manchester Longman, Albert Thurston, Brent st, Hendon, Builder. March 20 at 3 at the Jamaica Coffee house, St Michael's alley, Cornhill. Warburton and De Paula, West st, Fins. bury circus M allet, John, jun., Great Torrington, Devon, Dairyman. March 21 at 3.30 at offices of Thorne, Castle st, Barnstaple Marshall, Nathaniel, Lutton, Northampton, Farmer. March 18 at 12 at offices of Deacon and Wilkins, Cross st, Peterborough Mathew, Thomas Charles, Early mews, Camden Town, Lead Merchant. March 23 at 19 at offices of Ellen, Chancery lane Merrick, Robert, Berrington, Salop, Licensed Victualler. Mar 21 at 11 at offices of Morris, Swan Hill, Shrewsbury Millard, William Carey, Farnham, Surrey, Glass Dealer. Mar 20 at 2 at offices of Vandercom and Co, Bush lane Miller, Joseph, Blackburn, Shirt Maker. Mar 21 at 11 at the White Bull Hotel, Church st, Blackburn. Needham, Blackburn Miller, William Eaton, Howden, York, Draper. Mar 20 at 12 at offices of England and Monk, Albert James, Lower Edmonton, Builder. Moor, James Maitland Hoar, Birmingham, out of employment. Mar 17 at 3 at office of Fallows, Cherry st, Birmingham Ormerod, Edward, Atherton, Lancaster, Engineer. Mar 20 at 11 at office of Holmes and Parr, Thomas, Greetland, Halifax, York, Stone Merchant. Mar 20 at 11 at the Crown Peverley, William, Old Kent rd, Leather Dresser's Manager. Mar 15 at 10 at Finsbury sq bldgs, Chiswell st. Whitwell and Co Pierce, Sidney, Farington Gurney, Somerset, Blacksmith. Mar 22 at 2 at office of ton Pollington, Edward, Hastings, Builder. Mar 16 at 12 at 37, Southampton bldgs, Chancery lane. Meadows and Elliott, Hastings Price, John, Kingswinford, Stafford, Licensed Victualler. Mar 18 at 10.30 at offices of Price, Robert, Willenhall, Stafford, Stamper and Piercer. Pridham, Albert Edward, Llanelly, Carmarthen, Chemist. Mar 17 at 11 at offices of Mar 21 at 11 at offices of Reddan, James Henry, Birmingham, Gas Engineer. Mar 21 at 3 at offices of Johnson and Co, Waterloo st, Birmingham Rowland, William, Old Kent rd, Boot and Shoe Maker. Mar 23 at 3 at the offices of Kilvington and Stock, Walbrook Rumball, William Lewis, Richmond Surrey, Fine Art Dealer. Mar 20 at 3 at the offices of Durrant, Guildhall chmbrs, Basinghall st Skaife, Smith William, West Gorton, Manchester, Provision Dealer. Mar 20 at 3 at Blackfriars Hotel, Blackfriars st, Manchester. Hill, Manchester Smith, John Edward, Paternoster row, Solicitor. Mar 17 at 3 at offices of Butcher, Sommerville, Elizabeth Ann, Montague st, Russel sq, Lodging House Keeper. Mar 31 Stringer, Edwin Harper, Stourbridge, Boot Dealer. st, Stourbridge. Collis, Stourbridge Thaine, John, sen, Sea Palling, Norfolk, Farmer. Mar 20 at 3 at office of Sadd and Linay, Theatre st, Norwich Thompson, James, and Samuel Thompson, Farcet, Huntingdon, Farmers. Mar 21 at 11.30 at Angel Hotel, Peterborough. Cranfield, St Ives Thursfield, William, Mincing lane, Coffee Broker. Mar 27 at 2 at office of Plews and Co, Mark lane Town, Albert, Lennington rd, Fishmonger. Mar 17 at 3 at 214, Kennington pk rd. Brunskili, Gt james st, Bedford row Twamley, George William, Leeds, Grocer. Mar 20 at 3 at office of Craven, East parade, Walker, Tom, Cockermouth, Cumberland, Ironmonger. Mar 18 at 12.30 at Court house, Warwick, William Guy, Bishopstoke, Hants, Farmer. Mar 17 at 2 at office of Guy, Albion ter, Southampton Weaver, Henry Charles, Bath, Baker. Mar 20 at 12 at office of Simmons and Co, Edgar bldgs, Bath Wherrett, Henry, Croydon, Baker. Mar 17 at 11 at Green Dragon Hotel, High st, Croydon. Dennis, Croydon Whittingham, John, Nantwich, Miller. Mar 20 at 2 at offices of Lisle, Nantwich Wholey, Robert Jarvis, Kingston upon Hull, Licensed Victualler. Mar 20 at 11 at office of Summers, Kingston upon Hull Wood, James, Llandudno, Dealer in Fancy Goods. Mar 17 at 1 at Erskine Arms Hotel, Conway. Reece and Co, Birmingham Woodhead, George, Manchester, Printers. Mar 17 at 4.30 at offices of Addleshaw and Warburton, Manchester Wright, George, Sheffield, Plumber. Mar 17 at 3 at offices of Clegg and Sons, Victoria chmbrs, Sheffield Guaranteed Pure Soluble Cocoa of the Finest Quality, HEWETSON, THEXTON, & PEART, with the excess of fat extracted. The Faculty pronounce it "the most nutritious, perfectly digestible beverage for Breakfast, Luncheon, or Supper, and invaluable for Invalids and Children." Highly commended by the entire Medical Press. Being without ugar, spice, or other admixture, it suits all palates, keeps better in all climates, and is four times the strength of cocoas THICKENED yet WEAKENED with starch, &c., and IN REALITY CHEAPER than such Mixtures. Made instantaneously with boiling water, a teaspoonful to a Breakfast Cup, costing less than a halfpenny. COCOATINA A LA VANILLE is the most delicate, digestible, cheapest Manilla Chocolate, and may be taken when richer chocolate is prohibited. In tin packets at ls. 6d., 38., 5s. 6d., &c., by Chemists and Grocers. Charities on Special Terms by the Sole Proprietors, H. SCHWEITZER & CO 10, Adam-street, London, W.C. CLERICAL, MEDICAL, AND GENERAL ASSURANCE SOCIETY. AW UNION MANUFACTURERS AND HOUSE FURNISHERS, 200, 203, and 204, TOTTENHAM COURT ROAD, W. Estimates and Designs submitted free for entirely Furnishing Residences, Chambers, Offices, &c. -PAINTING, DECORATING, & HOUSE REPAIRS. Carved Oak Furniture, Reproductions from Ancient Designs, &c. Bedroom Furniture, including Bedstead and Bedding, from £7 10s. per set. THIRTY LARGE SHOW ROOMS. HEWETSON, THEXTON, & PEART, 200, 203, and 204, Tottenham Court-road, London, W. N.B.-Household Furniture Warehoused or Removed on reasonable terms. To Her Majesty, the Lord Chancellor, the Whole of the Judicial Bench, Corporation of London, &c. SOLICITORS' AND REGISTRARS' GOWNS BARRISTERS' AND QUEEN'S COUNSEL'S DITTO, CORPORATION ROBES, UNIVERSITY & CLERGY GOWNS. ESTABLISHED 1689. 94, CHANCERY LANE. LONDON. AN IMPORTANT CONVENIENCE TO LAW WRITERS AND SOLICITORS. STEPHENS' SCARLET INK FOR STEEL PENS. This new Ink supplies the demand continually made but never before met, for a Red Ink which is uninjured by Steel or other Metallic Pens. Steel Pens left in this ink for months do not impair the beauty of its colour, nor are the Pens in the least corroded by it. The existing Red Inks rapidly destroy Steel Pens, and lose their red colour if used with other than Gold or Quill Pens. This new colour is a very rich scarlet red of great beauty. The colour of this ink is not affected by use upon parchment Draughtsmen." and is consequently of great value to Solicitors and Sold in stone bottles, retail at ls., 2s., 3s. ; and imperial quarts of 40 ounces at 68. each. Also in glass bottles at 6d, and 1s. each. SOLD BY ALL STATIONERS. LONDON GAZETTE (published by authority) and LONDON and COUNTRY ADVERTISEMENT OFFICE.-No. 117, CHANCERY LANE, FLEET STREET. HENRY GREEN, Advertisement Agent, to begs to direct the attention of the Legal Profession LANCE COIAFIRE and LIFE, INSU-thirty advantages of his long experience of upwards of ane, London, W.C. The Funds in hand and Capital subscribed amount to upwards of £1,600,000 sterling. Chairman-JAMES CUDDON, Esq., Barrister-at-Law, Goldsmith-building, Temple. Deputy-Chairman-C. PEMBERTON, Esq. (Lee & Pembertons), Solicitor, 44, Lincoln's-inn-fields. Every description of Fire and Life Insurance business transacted. Whole World and Unconditional Life Policies granted at a slightly increased rate of Premium. Policies of Insurance granted against the contingency of Issue at moderate rates of Premium. Advances made on Mortgage of Life Interest and Reversions, whether absolute or contingent. Prospectus, Copies of the Accounts as deposited with the Board of Trade, and every information sent on application to Current Accounts opened according to the usual practice of other Bankers, and Interest allowed on the minimum monthly balances when not drawn below £25. No commission charged for keeping Accounts. The Bank also notices, &c., and hereby solicits their continued support. N.B. One copy of advertisement only required, and the strictest care and promptitude assured. Official stamped kept. By appointment. forms for advertisement and file of "London Gazette PARTRIDGE & COOPER, LAW AND GENERAL STATIONERS, 1 & 2, CHANCERY LANE, LONDON, E.C. Law Copying and Engrossing. Deeds and Writings engrossed and copied on the Premises, with punctuality and dispatch, at the lowest scale of charges. A good Discount allowed on agreed accounts. LAW PRINTING. STATEMENTS OF CLAIM AND DEFENCE, AFFI. Discount allowed for cash on agreed accounts. receives money on Deposit at Three per Cent. Interest, STYLOGRAPHIC PENS. repayable on demand. The Bank undertakes for its Customers, free of charge, the custody of Deeds, Writings, and other Securities and Valuables; the collection of Bills of Exchange, Dividends, and Coupons; and the purchase and sale of Stocks and Shares. Credit and Circular Notes issued. A Pamphlet, with full particulars, on application. FRANCIS RAVENSCROFT, Manager. 31st March, 1880. Letters of Supersede in one Instrument Pencil, Pen, and Ink. Prices, 1s. to 7s. 6d. SEND FOR LIST AND PARTICULARS TO C. H. GRIFFITHS & SONS. THE SIX GUINEA LEGAL NEST SHOULD BE USED BY ALL SOLICITORS, ACCOUNTANTS, &c. It is the most convenient and durable yet offered to the Profession. CAUTION:-BEWARE OF IMITATIONS. 1, LITTLE STANHOPE STREET, MAYFAIR, KINAHAN'S LL WHISKY. KINAHAN'S LL WHISKY, Pure, Mild and Mellow, Delicious and very Wholesome. Universally recommended by the Profession. KINAHAN'S LL WHISKY. The Cream of Old Irish Whiskies. KINAHAN'S LL WHISKY, Gold Medal, Paris Exhibition, 1878; Dublin Exhibition, 1865, the Gold Medal. 20, Great Titchfield-street, London, W. DINNEFORD'S MAGNESIA The Medical Profession for over Forty Years have ap. proved of this pure solution as the best remedy for ACIDITY of the STOMACH, HEARTBURN, HEADACHE, GOUT and INDIGESTION, And as the safest Aperient for Delicate Constitutions, Ladies, Children, and Infants. LETTS (LIMITED), LONDON BRIDGE. DINNEFORD'S MAGNESIA. CURRENT TOPICS. LONDON, MARCH 18, 1882. THE OPENING CEREMONY of the Royal Courts of Justice has been fixed provisionally for the first day of next Trinity Sittings. MR. FRANCIS SAVAGE REILLY has been appointed Counsel to the Speaker of the House of Commons, in succession to Mr. G. K. RICKARDS, resigned. Mr. REILLY was called to the bar at Lincoln's-inn in Easter Term, 1851. He acted as arbitrator under the European Assurance Company's Arbitration Act. GREAT PRESSURE is being applied to urge on the completion of the Royal Courts of Justice by the date suggested by Mr. SHAW LEFEVRE last week in the House of Commons. Large numbers of workmen have been employed in completing the details of the central hall and other unfinished portions of the building, and the fittings of the courts will shortly be placed in position. THE HOUSE OF COMMONS has called for a return "showing the number of registrars, masters, and chief clerks attached to the Supreme Court of Judicature, and the salaries or fees received by, and the number and length of the days of actual attendance of, each registrar, master, and chief clerk during the year ending the 31st of October, 1881." THE COMPLAINT of a correspondent in a recent number of this journal that deeds or documents cannot be stamped at the Royal Courts of Justice for either 2s. 6d. or 6d., although they can be stamped for various other amounts between 1s. and £5, deserves the attention of the authorities. The tell-tale stamping machines are somewhat expensive, but it would be worth while to incur the cost of two new machines to obviate the inconvenience caused to practitioners who have to go to Somerset House. THE DIFFICULTIES which have from time to time arisen in the Court of Appeal with respect to the costs of shorthand notes of what took place in the court below have as to notes of the evidence, been settled by several cases, but as to shorthand notes of the judgment there appears to remain some uncertainty. In the case of The London and South-Western Railway Company v. Gomm (ante, p. 296), the Master of the Rolls is reported to have said that the court had read the report of the judgment of KAY, J., in a current series of reports, which had only been recently published, "but if the printed report had been published some time before the hearing of the appeal, the costs of the written copies of the judgment would not have been allowed." It is hard to understand the precise drift of this ruling if it extends to the costs of the transcript. Some reports are published weekly, others monthly, but no reports, whenever published, invariably contain all the cases reportable which have been decided since the last previous date of publication. It is impossible for solicitors to know whether a case which is going to the Court of Appeal will be reported at any given time. It will be asked, after what the Master of the Rolls has said, how long an appellant is to wait after his appeal is set down before he takes a transcript of the shorthand notes of the judgment? Some explanation of the rule laid down by the Master of the Rolls appears to be necessary. IN REFERENCE to the convict LAMSON, it may be well to point out that, by the present law, property does not the less devolve upon a person because it has been procured by the murder of a person through whom the right to it accrues. Before 1870 the law was otherwise, as the whole of a felon's property was, by his conviction, ipso facto forfeited to the Crown. But the Act 33 & 34 Vict. c. 23 abolishes forfeiture for felony, and provides that the Crown may commit the custody and management of the property of a convict to an administrator, who, besides having power to pay the debts of the convict, and the costs of his prosecution and defence, "may (section 16) cause such payments and allowances for the support or maintenance of any wife or child, or reputed child of such convict, or of any other relative, or reputed relative, of such convict dependent upon him for support, as to such administrator shall seem fit." The provision of section 15, that the adminis trator may cause to be paid out of the property of the convict "such sum of money by way of satisfaction or compensation for any loss of property or other injury alleged to have been suffered by any person through, or by means of, any alleged criminal or fraudulent act of such convict as to him shall seem just, although no proof of such alleged criminal or fraudulent act may have been made in any court of law or equity," are very wide, and might, perhaps, include the case of compensation to the dependent relatives of a murdered person; but the case of devolution of property procured by murder is unprovided for, and is, perhaps, too rare to require providing for by law. IT HAS BEEN SUGGESTED by the jury in the Lamson case that the sale of poisons ought to be more restricted than it is at present, and the suggestion appears to have sprung from the prevalent opinion that medical men can procure poisons more easily than other people. The Pharmacy Act provides (section 17) that certain poisons may not be sold "to any person unknown to the seller, unless introduced by some person known to the seller"; but that such provision shall not apply to " sales by wholesale to retail dealers in the ordinary course of wholesale dealing," nor to "any medicine supplied by a legally qualified apothecary to his patient," nor to "any article when forming part of the ingredients of any medicine dispensed by a person registered" under the Act. There is nothing in the Act authorizing the supply ad libitum of poison by chemists to medical practitioners as such. The case of Berry v. Henderson (L. R. 5 Q. B. 296), however, shows that a certain amount of laxity is allowed in the application of the law. There a person unknown, and not introduced, brought a prescription to be made up, which was signed by the initials of a medical man; and it was held that the dispensing chemist could not be convicted, although there was no evidence that the person for whom the prescription purported to be intended was an existing person. It would seem to be reasonable to require that the name and address of the prescribing medical practitioner should be furnished to the dispensing chemist. With respect to the sale of arsenic, it may be noticed that the exception in the Arsenic Act (14 & 15 Vict. c. 13) applies only to sale by prescription, or by wholesale to retail dealers, "upon orders in writing in the ordinary course of wholesale dealing," and the exception in the Pharmacy Act provides that where medicine containing poison is sold, it is to be "labelled with the name and address of the seller," and that the ingredients are to be entered "with the name of the person to whom it is sold or delivered, in a book to be kept by the seller for that purpose." BOTH THE Criminal Law Amendment Bill, "to prescribe the procedure in England and Ireland relative to indictment or information for the punishment of offenders, and to provide appeal in criminal cases," which is brought in by Mr. HopwoOD and other members, and the Criminal Procedure Bill, "to prescribe the procedure by indictment for the punishment of offences against the criminal law," which is brought in by Mr. GORST and Mr. ARTHUR BALFOUR, reproduce, to a very great extent, and often word for word, the provisions of part 7 of the well-known Criminal Code (Indictable Offences) Bill. The Amendment Bill contains 133 clauses, the Procedure Bill 110. Following in the main the order of their model, they deal with committal by justices and bail, with the whole of criminal pleading, with the mode of trial and challenges of the jury, and with appeal, new trial, and costs. In neither of the Bills is there any schedule of repealed Acts, though it is obvious that there is an implied repeal of some score of them, the so-called "Indictable Offences Act, 1848 " THE LIMIT TO THE DOCTRINE OF FROM a very early period in the history of English law, covenants The former class These covenants are said to run with the land at law, and the cases which involve their consideration may be divided into two principal classes, according as there is, or is not, privity of estate between the covenantor and the covenantee. embraces those cases in which the covenant is between the lessee and his lessor. The latter division embraces those much more obscure and difficult cases, of which The Prior's case, cited by Lord Coke in Spencer's case, is the prototype, where no privity of estate, in respect of the lands affected by the covenant, subsists between the covenantor and the covenantee. These last covenants are still subject to the common law, so far as regards their capacity to run with the land to which they relate. The rules by which they are governed are exceedingly obscure and of very limited application; and we do not propose to enter upon the investigation of them. (Jervis's Act, No. 1, 11 & 12 Vict. c. 42), being the most import-been IF THE PRESSURE of business should prevent any large alteration of the criminal law in the present session, we would express an earnest hope that that small portion of the two Criminal Law Amendment Bills, or of the Criminal Code, which deals with pleading only, may be passed. As the law at present stands, it is still necessary, when a person is indicted for publishing a libellous book, to copy out in the indictment all the passages alleged to be libellous. The amending Bills propose (see Criminal Code, Form Q. Q.) to allege in the indictment that the defendant published a libellous book, and to annex a marked copy of the book to the indictment Other, but not quite so obvious, amendments of the present ridiculous system of pleading will occur to everybody versed in the subject. As for the Criminal Code itself, the reason why it has made so slow a progress in the House of Commons is plain. Since the brilliant opening speech of Lord Justice HOLKER in introducing the measure about three years ago, the House of Commons has never had the slightest opportunity of considering it. The view that the House of Commons can no more make a code than paint a picture has been pressed too far, and the Bill was referred prematurely to the Royal Commission. We hope that it may be introduced and discussed early, and be referred to a joint select committee of the two Houses of Parliament. On the 10 h inst., in the House of Commons, Mr. Hicks a ked the Attorney-General whether he had now come to a decision as to the way in which he would deal with the present waste of judicial power, and the great inconvenience caused to jurors and others by the present system of holding four assizes. The Attorney-General said that he saw no reason for departing from the system that no one should remain in custody without trial for a longer pericd than three months. But it was under the consideration of the Government how far the inconvenience resulting to the judicial bench and to ja:ors might be mitigated. The statute of Hen. 8, c. 34, which largely extended the benefit of these covenants, as between lessor and lessee, by largely extending the circumstances under which they could be sued upon, did not at all extend the scope of the covenants in the sense of causing any covenants to run with the land which would not equally have run with the land before the statute. Though the words of the courts to this meaning; see Spencer's case, ad fin. statute are very wide, they were reasonably restricted by the The definition of these covenants remained drawn upon the narrow lines of the common law. The same need which had originally operated to obtain from the common law a limited was and an interim injunction to that effect was actually granted, though it afterwards happened, owing to peculiar circumstances, that the Bill was dismissed. The above cited passage, which obviously includes all chattels in its scope, quoted with approval by Lord Justice Selwyn in Catt v. Tourle (L. R. 4 Ch. 654, at p. 657). The earlier case of Wilson v. Hart (L. R. 1 Ch. 463), had decided that constructive notice is sufficient to bring a purchaser within the meaning of the principle. It is evident that the two last-mentioned cases contain within them the germs of a very wide development; and the courts for a good many years showed no signs of intending to restrict their growth. But a remarkable step has recently been taken in this direction by the case of Haywood v. Brunswick Permanent Benefit Building Society (30 W. R. 299). The facts of this case, so far as they are material, were as follows:-In 1866 Charles Jackson granted certain lands in fee simple to Edward Jackson, partly in consideration of a rent-charge limited in fee simple to Charles Jackson by way of use, and partly in consideration of the covenants on the part of Edward Jackson contained in the deed. Among these covenants was a covenant to pay the rent-charge, and another, expressed to be entered into by Edward Jackson "for himself, his heirs, executors, and administrators," that he would, within two years, erect and keep in repair buildings of the annual letting value of double the rent-charge. The rent-charge, with all the remedies in respect of it, was afterwards assigned to the plaintiff, and the lands were legally mortgaged to the defendant society, who subsequently entered into possession. The society having in 1880 failed to pay the rentcharge and to keep the buildings in repair, an action was brought, among other things, for an injunction to restrain the defendants from committing further breaches of the covenant to repair, and to compel specific performance of that covenant. Mr. Justice Stephen gave judgment for the plaintiff, holding that, though the covenant did not at law run with the land, yet the defendants, being mortgagees in possession, and having had notice of the covenant, were bound to perform it. This judgment was unanimously reversed by the Court of Appeal, consisting of Brett, Cotton, and Lindley, L.JJ., upon the ground that the covenant did not at law run with the land, and that the doctrine of Tulk v. Moxhay is applicable only to restrictive covenants forbidding the user of the land in certain prescribed ways possibly (according to Lord Justice Brett) with the addition of such covenants as, when enforced, would constitute a burden upon the This decision has very recently been referred to with approval by the Court of Appeal in the case of The London and South Western Railway Company v. Gomm (ante, p. 296). land. It is certainly a remarkable thing that in cases where, as in Tulk v. Moxhay itself, the covenant was partly of an affirmative character, binding the covenantor positively to do something, including, inter alia, an obligation to keep a piece of ground in good repair as a pleasure-garden, the injunction of the court seems to have dealt only with that part of it which was of a negative character. The injunction in that case did not attempt to compel the defendant to keep the garden in repair, but only restrained him from building upon it or using it otherwise than as a pleasure-garden. This distinction seems to have been present to the mind of Lord Chancellor Cranworth when, in De Mattos v. Gibson, he said:" Although a court of equity cannot compel a specific performance of the contract" (which was in that case a positive contract of charter-party), "yet it will restrain the employment of the vessel in a different manner." It must be borne in mind that the doctrine of Tulk v. Moxhay and its attendant cases has never yet come for review before the House of Lords. Probably this fact may be taken as a fresh evidence that on the whole the doctrine is salutary and consonant with public convenience. But some of its later extensions, notably the two to which we have above adverted, look as though they might perhaps not pass unscathed through the ordeal of the supreme tribunal. Meanwhile we may remind the reader of the opinion formerly expressed by us, that section 65 of the Conveyancing Act has, though evidently without intending it, supplied a convenient machinery for binding lands in perpetuity by such covenants as are commonly used by owners of building land. The incandescent electric light is to be tried in the new courts at the Royal Courts of Justice. THE BILLS OF SALE ACT AMEND- THE somewhat crude Bill introduced in the House of Commons in The Bill made away One of the most important proposals is that of clauses 4, 5, and 6, the effect of which, if passed into law, will be to do with the practice of including after-acquired property in bills of sale. It is proposed to provide that: 4.) Every bill of sale shall have annexed thereto, or written thereon, a schedule containing an inventory of the personal chattels comprised in the bill of sale; and such bill of sale, save as hereinafter mentioned, shall have effect only in respect of the personal chattels enumerated in the said schedule; and shall be void in respect of any personal chattels not so enumerated. sale. 66 "(5.) Save as hereinafter mentioned, a bill of sale shall be void in respect of any personal chattels enumerated in the schedule thereto of which the grantor was not the true owner at the time of the execution of the bill of (6.) Nothing contained in the foregoing sections of this Act shall render a bill of sale void in respect of any of the following things; (that is to say), "(1) Any growing crops separately assigned or charged where such crops were actually growing at the time when the bill of sale was executed. "(2) Any fixtures separately assigned or charged, and any plant or trade machinery where such fixtures, plant, or trade machinery are used in, attached to, or brought upon any land, farm, factory, workshop, shop, house, warehouse, or other place in substitution for any of the like fixtures, plant, or trade machinery enumerated in the schedule to such bill of sale." As to the policy of this proposal, opinions differ widely, but we think that many who are favourable to it will admit that, as at present framed, the clauses are too sweeping. The effect will probably be to abolish altogether bills of sale of stock-in-trade, for, since the scheduled articles will be disposed of in the way of trade, of course, the security of the creditor will be constantly diminishing. We do not, however, object to this. There is a great deal to be urged in favour of abolishing altogether bills of sale of stock-in-trade, whether present or future. As has been several times pointed out in these columns, it is tolerably certain that a trader who gives such a bill of sale is involved in serious embarrassment, and the bill of sale very seldom enables him to tide over his difficulties. Wholesale dealers generally rely on the stock-in-trade of their customers as a test of the amount of credit they will give. The result is that bills of sale of stock-in-trade do little good to the trader, and occasion great loss to his trade creditors. If, therefore, the proposal of the Bill were confined to the stockin-trade of traders, as defined in the Bankruptcy Act, we should be disposed to give it our support. But is there any solid reason for preventing a man who is not a trader from dealing with his present or future property as he may think fit? There is a large class of persons who make a livelihood by letting furnished lodgings (without supplying provisions to their lodgers) who would probably be seriously inconvenienced if the provision as it now stands is passed into law. They can usually only obtain credit upon their furniture, and cannot pay off the debt rapidly, and the value of extend to the furniture and effects scheduled in the bill of sale the security will probably be greatly diminished if it is only to which are constantly wearing out. There ought, at all events, to be inserted a provision excepting from the operation of the clauses we have referred to effects brought upon the premises in substitution for articles enumerated in the schedule. Clause 7 is intended to convert into law the decision of the Common Pleas Division in Davis v. Goodman (28 W. R. 150), afterwards reversed by the Court of Appeal. It is proposed to repeal section 8 of the Act of 1878, which avoids an unattested and unregistered bill of sale in certain cases only, and to provide that "every bill of sale shall be duly attested, and shall be registered under the principal Act within seven days after the execution thereof, . and shall truly set forth the consideration for which it was given, otherwise such bill of sale shall be void in respect of the personal chattels comprised therein." |