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greater value than those in which it was received, than to say that it may be discharged by dollars of no value at all.

At the time several of the dividends were declared, the chief currency, and, when the others were declared, almost the entire currency, of that part of the country in which the railroad was operated, was in Confederate notes; and whatever currency of bank notes there may have been in circulation, was of no greater real value. This currency may fairly be said to have been imposed on the country by irresistible force. There was no other in which the current daily transactions of business could be carried on, and there could be no other while the rebel government kept control of the rebel States. The necessity for using this currency was almost the same as the necessity to live. No protest, no resistance, no rejection, could avail any thing. At the same time, this currency, though it depreciated rapidly, had a sort of value. Its redemption, though improbable, was not impossible, and, until the downfall of the Confederacy, it had a greater or less degree of purchasing power.

Under these circumstances, we cannot refuse to take notice of the fact that the dollars which the company received were not of either description of dollars recog. nized as lawful money by the laws of the United States; nor can we hold the officers of the company as incurring any liability to the stockholders by receiving the currency actually in circulation for its earnings, beyond that of prompt payment in like currency to such stockholders as were in a situation to receive such payment, and payment as soon as practicable in currency of equivalent value to such as were resident in States, intercourse with which was, at the time, not only cut off by the Civil War, but was also interdicted by the Congress of the United States.

In the case of Shortridge v. Mason, 2 Am. Law Rev. 95, it was held that the accrual of interest upon a note for a certain sum and interest was not suspended by the Rebellion. The dividends, in the present case, are in a different predicament. Dividends are only payable on demand, and it is agreed in this case that there was no demand until the filing of the bill. Interest, therefore, can only be allowed from that date.

We shall decree, therefore, that the respondents pay to the complainants the dividends declared upon the stock of their intestate with interest from Nov. 23, 1866. The amount of the several dividends at the several dates when made, will be computed by deducting such percentage as will reduce them to equal value in lawful money, and interest on the aggregate amount will be cast from Nov. 23, 1866, to this date at six per cent. 'And decree will be entered for the sum thus ascertained. The computations may be made by the counsel, or by a master, as they may prefer.

GREAT BRITAIN. New APPOINTMENTS. — At the time of going to press, it is impossible to give with any certainty the legal appointments of Mr. Gladstone's Government. The utterances of the capricious submarine monster are even more than usually unintelligible and absurd. To extract a meaning from them, they require as many and ingenious emendations as the chorus of a Greek tragedy. We venture, though with great diffidence, to suggest that perhaps the statement, that “Henry Woods is to be Chancellor of the Exchequer, and Sergeant Gifford, Lord Chief Justice," may mean that Sir William Page Wood is to be Lord Chancellor, and that the place of Lord Justice of Appeal in Chancery, which will be, in that case, · vacated by him, is to be filled by the promotion of Vice Chancellor Giffard.

THE QUEEN V. ANDERSON. — Case stated by Byles, J.
The prisoner, an American citizen, serving as seaman on board a British mer-


chant vessel, was indicted at the Central Criminal Court for the murder of another seaman, also an American citizen, serving on board the same vessel.

At the time of the offence, the vessel was in the river Garonne, within the boundaries of the French territory, at a point about forty-five miles from its mouth, where the river was about half a mile wide. The tide flowed up to the place in question, and beyond it. No evidence was given as to whether the place was within the limits of the port of Bordeaux or not.

It was objected, for the prisoner, that, the offence having been committed within the empire of France, and the prisoner being an American citizen, the Central Criminal Court had no jurisdiction to try him.

The prisoner was convicted of manslaughter.
M. Williams, for the prisoner.
Poland (Beasley with him), for the Crown.

The court held that the Admiralty had jurisdiction, and that the prisoner was rightly convicted at the Central Criminal Court.

Conviction affirmed.
Attorney for the Crown: Solicitor to the Treasury.
Attorneys for the prisoner: Senior, Attree, & Johnson. — Weekly Notes.

COURTS OF APPEAL. — The following extract, from a paper read by William Evans, Esq., in the Jurisprudence Section of the Social Science Association, shows the unsatisfactory constitution of the highest Court of Appeal:

“Returning to the statistics to which I have already referred, I find that not only is the judicial tribunal of the House of Lords numerically weak when considered by itself, but that, when regarded with reference to the number of the judges whose judg. ments it has to review, its want of numerical strength is still more striking. Take, for example, one of the eighteen cases already mentioned, namely, the case of Ricket v. The Directors of the Metropolitan Railway Company, in which there was a unanimous judgment of four judges of the Court of Queen's Bench. This was reversed in the Exchequer Chamber by four judges against two, and in the House of Lords the judgment of the Exchequer Chamber was affirmed on the votes of two out of the only three law lords present, the other law lord dissenting, so that two law lords overruled the judgments of four judges of the Court of Queen's Bench, two judges of the Court of Common Pleas, and one law lord, in all seven other judges; whilst the judgment of such two law lords was in accordance with the opinions of only four other judges. In the next succeeding case of Walsh v. Trimmer, we find three law lords reversing the judgment of five judges of the Court of Exchequer Chamber, although that judg. ment was also in accordance with a judgment of one judge of the Court of Queen's Bench.

I will take one other case; viz., that of Xenos v. Wickham. Here two law lords reversed the unanimous judgment of four judges of the Court of Common Pleas, which had been affirmed, with only two dissentients, by the Exchequer Chamber, composed of six judges; so that, in that instance, you have this singular result, that the unsuccessful litigant had eight judges in his favor, whilst his successful opponent had only four.”

LIVES OF THE LORD CHANCELLORS. — Mr. Murray's list of forthcoming books opens with the announcement of “The Lives of Lord Lyndhurst and Lord Brougham, forming the concluding volume of the Lives of the Lord Chancel


lors,' by the late Lord Chancellor Campbell.” The volume will be, in one respect, unique in the history of literature. The death of Lord Campbell preceded by about two years the death of Lord Lyndhurst, and that of Lord Brougham by about five years. It has seldom happened to the biographee, if we may coin such a term, to survive the biographer. The Xanthos of one of Mr. Browning's poems, who “died, and could not write the chronicle," would scarcely have had that palliation of his literary inactivity allowed by a man of the late Lord Campbell's energy. He should have written the chronicle, as that noble and learned lord wrote his lives of Lord Brougham and Lord Lyndhurst, before he died. One one occasion, in the House of Lords, Lord Lyndhurst expressed the alarm with which, on biographical considerations, the possibility of his death before that of Lord Campbell affected him; and Lord Campbell gave him a re-assuring reply, — and all the while Lord Campbell was composing his noble and learned friend's biography. Dr. Johnson, as is well known, said that, if he thought Boswell had any idea of writing his life, he would take Boswell's. But this justifiable homicide, this manslaughter in self-defence, would have been of no use against Lord Campbell. The lives were written. It is curious to think of him returning home from the House of Peers, after a sharp brush with Lord Brougham, to add a new touch to his noble friend's portrait, to give a turn to a feature, and to deepen a shade or heighten a color. Luther spitting on the portrait of Erasmus, or Dante depicting in his Inferno the likeness of his living enemies, would afford some parallel to Lord Campbell's literary labors, if Lord Campbell had not been too calm-tempered and fair-minded a man to misuse his pen for the gratification of personal resentment. After all, the careers of Lord Brougham and Lord Lyndhurst were over before Lord Campbell set about writing their lives. The impartiality of history, if such a thing exists, is out of the question. By way of counterpoise, the judgment of a contemporary, actively engaged in law and in politics, upon the men and events of his own time, and a lawyer's and politician's estimate of his great rivals in law and politics, possess a degree of interest which does not always attach to the premature birth of contemporary biography. Daily News.

A DISPUTED SUCCESSION. — A strange suit of disputed testamentary suc'cession has been commenced in Bengal, the estate claimed being worth, it is said, £40,000 a year. The claimant is a Christian convert, the only son of a highly respected and prosperous Bengalee Brahmin, the Baboo Prosunno Coamar Tagore, Companion of the Order of the Star of India. The Baboo died not long ago, and on his deathbed, to mark his anger at his son's apostasy, executed a will by which he left the bulk of his property to a nephew, already a wealthy man, with an estate of his own valued at £20,000 a year. The joy of the Brahmins over the pious death of the Baboo was great; but the Christian and disinherited son has impugned the validity of the will in the Supreme Court, on the ground that the instrument illegally proposed to tie up the disposition of the property for a hundred years. It is anticipated that the court will upset the will; and, if so, the case will be sent for final decision before the Judicial Committee of the Privy Council; when, it would not be easy to forecast. Besides the bequest to his nephew, the Baboo left large legacies to the University of Calcutta, to a famous idol, and to several charitable societies. If the son's suit be success





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