tracting parties and the other the character of those tribunals. The first standpoint had been expressed by the French-German tribunal in the Société Vissicole de Champagne v. Mumm case as follows: "As a matter of fact it is manifest that the treaty intended to institute the competency of mixed tribunals in the broadest way. It is evident from the notes exchanged before the signing of the treaties between the allied and associated powers of the German delegation that the contracting parties agreed in admitting the competency of the mixed arbitral tribunals for all the litigious questions concerning the application of the treaty." On the other hand it must be kept in mind that when one had to deal with a competency based on a contract by which an ordinary municipal court was excluded, the competency must always be considered in doubtful cases as rather restricted. These two standpoints had, if possible, to be combined. Coming to the question whether the mixed arbitral tribunals had the right to definitely decide whether they were competent in a case or not, the lecturer said that art. 250 of the Trianon peace treaty stipulated that the property, rights and interests of Hungarian nationals, or companies controlled by them, situated in the territories which formed part of the former Austro-Hungarian monarchy should not be subject to retention or liquidation in accordance with those provisions and that such property rights and provisions should be restored to their owners freed from any measure of transfer, compulsory administration or sequestration, taken since the 3rd Nov. 1918 until the coming into force of the treaty. Claims made by Hungarian nationals under the article were to be submitted to the mixed tribunals. Many suits had been brought on the base of this article against the Roumanian State by Hungarian nationals whose goods were liquidated on former Hungarian, but now Roumanian territory. The Roumanian State entered into the proceedings, but with reservation, and attacking the competency of the court. It argued that the expropriations were executed in accordance with Roumanian agrarian reform law, which made no difference between Roumanian and nonRoumanian nationals. Thus these liquidations did not fall within the scope of art. 250, and could not be investigated by the mixed arbitral tribunals. A further argument of the Roumanian State was that where art. 250 of the Trianon Treaty spoke of retention or liquidation, it referred to bellicose dispositions for war purposes. Finally, it argued that at a conference on the 27th May 1923 at Brussels, at which, in addition to the delegates of the two interested States, Mr. Adatchi, charged by the council of the League of Nations, and some high functionaries of the League took part, the Hungarian representative gave his assent to the text of a declaration, the sense of which, after this standpoint, should be that he recognised that the Roumanian Government, in instituting the agrarian law, remained loyal to the principles laid down in the Peace Treaty, and that the report of Mr. Adatchi upon the Brussels conference was taken due notice of by the council of the League. The mixed tribunal after long discussion, declared itself competent. The question whether the liquidations under consideration could be executed upon the base of the agrarian law did not, according to the opinion of the tribunal, fall within the question of competency. The liquidations of which art. 250 of the treaty spoke could be both war and after. war liquidations. The further motive of the decision of the tribunal was that the declaration and assent of the Hungarian Government's delegate and the decision of the council of the League referred to could not serve as a reason for the non-establishment of its competency. The tribunal fixed a two months' term within which the Roumanian Government had to submit its defence on the merits. The Roumanian Government declared that its arbiter would not continue to function, and appealed to the League on art. 11 of the covenant. Hungary asked that the council of the League should, according to art. 239, nominate two neutral personalities for the purpose of substituting the resigned Roumanian arbiter, provided that the Roumanian Government should not, within one month, nominate a new arbiter. The question arose whether a RoumanianHungarian mixed arbitral tribunal had the right to decide upon its own competency, and whether an appeal to another international authority against this decision was possible, or whether it was definitely obligatory. The question, as it concerned international law in general, had a great past. It could be considered as a rule in international law that international courts decided definitely upon their own competency. In this the most qualified jurists were agreed, and it was interesting that Lapradelle and Politis, the latter of whom acted as a lawyer in the Roumanian Hungarian conflict, wrote years ago in their Recueil des Arbitrages Internationaux, that if the international court were deprived of arbitration, of the right to decide whether the compromise extended to a case submitted to itself, the court would be forced to declare itself incompetent in any case when its competency came into question. The same standpoint was taken up in his memorandum addressed to the Powers in which he declared that "it is impossible to refuse to the arbiters the power to appreciate in case of doubt the points which enter, or do not enter, into their competency." This view had been shared by Mérignac, Higgins, and Lammasch. The "Institut du Droit International also declared as follows: "In cases in which the doubt concerning the competency depends upon the interpretation of the compromise the parties are considered as having given to the arbiters the faculty to decide the question, except a contrary clause exist." Art. 48 of the first Hague Convention of 1899, as well as art. 73 of the second Hague Convention, stipulated that The Hague

courts had the right to decide the question of their own competency. It was chiefly the greatly respected Dutch international jurist, Asser, who demanded at the conference a completely free hand for the Court of Arbitration in deciding its own competency, and it should be observed that he met with no opposition. There was no doubt that it was a rule in international law that international courts had the right to decide definitely upon their own competency. If that were so, it must still more be true as concerned especially Mixed Arbitral Tribunals, because the Peace Treaties said "the high contracting parties agree to regard the decision of the Mixed Arbitral Tribunals as final and conclusive, and to render them binding upon their nationals." The treaties did not distinguish, but spoke in general of decisions, and thus it was beyond all doubt that this also referred to decisions of the tribunals upon their own competency. The attitude of the Roumanian Government in appealing against the decision of a tribunal to the Council of the League of Nations was contrary, not only to the treaty, but also to the general principles of international law.

The Chairman observed that they had listened to a clear and complete statement of the utmost importance at the present time. The substitution of arbitration for force was vital for the peace of the world.

Mr. Manisty suggested that the Permanent Court might act as a court of appeal to the Mixed Arbitral Tribunals upon the question of jurisdiction.

Dr. Von Auer replied that at the time of the treaty there was no Permanent Court in existence, and by the Treaty of Trianon the decisions of the Mixed Arbitral Tribunals was definite and conclusive. The Hungarian Government had proposed to submit the question to the Permanent Court, but Roumania refused.

Sir Graham Bower said that it was a question of policy, and arbitral tribunals ought to have an entirely free hand, free from any rules of judicial procedure.

Mr. Barratt contended that the only body which was competent to decide the question of the Mixed Arbitral Tribunal was the tribunal itself.

Mr. Bewes asked whether there had been any instance of a State refusing to carry out the award of the arbitral tribunals on the ground of want of jurisdiction.

Dr. Von Auer replied in the negative.

The Chairman said that he thought it was for the council to decide as to the competence of the tribunal, otherwise the treaty became a farce.

Dr. Bellot supported the view taken by Dr. von Auer. He submitted that the council was not a proper body to determine a judicial question. It was a political body, and quite unfit for such a duty. If both parties consented it would be within their power to submit a question for the advisory opinion of the Permanent Court.

Dr. Von Auer declared that it was a danger to international law if a body like the Council of the League could decide questions au fond.

A vote of thanks to Dr. Von Auer, moved by Sir Graham Bower, and seconded by Mr. Manisty, was carried by acclamation.

THE HARDWICKE SOCIETY

Ar a meeting held in the Middle Temple Common Room on Friday, the 17th June, the president, Mr. J. Buchan Ford, in the chair, Mr. L. A. Abraham moved : "That in the opinion of this House, colour bar legislation will defeat its own ends." Mr. S. Seuffert opposed. There also spoke Mr. Mayers, Mr. Kennedy Skipton, Dr. Gerald Slot, Mr. King, Mr. Shawcross, Mr. Douglas, Mr. Ifor Lloyd, Mr. Raphael, and Mr. Button. The mover having replied, the House divided, and the motion was carried by five votes.

The Hardwicke Society annual dinner will be held on Wednesday, the 13th July, at the Grand Hotel, Trafalgar-square. Lord Carson Mr. Justice Eve, Mr. Augustine Birrell, K.C., and Mr. Norman Birkett, K.C. have accepted the invitation of the society to be present. Tickets, price 10s. 6d., can be obtained from the hon. secretary, Mr. Ifor Lloyd, 4, Paper-buildings, Temple.

Mr. Frederick William Washington Kingdon, barrister-at-law, left estate of the gross value of £1534 (net personalty £1367). Mr. Francis Montagu Muirhead, barrister-at-law, left estate of the gross value of £249,119, with net personalty £249,079.

Mr. Kighley John Hough, solicitor, of Carlisle, left estate of the gross value of £24,724 (net personalty £20,205).

Mr. William Fox Tibbitts, solicitor, of Sheffield, left estate of the gross value of £1,522,687 (net personalty £1,472,379).

Mr. Arthur James Greenop, solicitor, left estate of the gross value of £6709 (net personalty £3192).

Mr. Richard Muir, solicitor, of Leeds, left estate of the gross value of £7927 (net personalty £2412).

170. EXECUTORS TRUSTEES FOR SALE-DEATH-APPOINTMENT OF NEW TRUSTEES.-A. died in 1916, having by her will appointed B. and C. executors thereof and devised her real estate to B. and C. upon trust for sale and investment of the net proceeds and payment of the income to D. (who is still living) for life with remainder over, with power for B. and C. to postpone the sale as they should think fit. B. died some years ago and C. has recently died intestate. Letters of administration of C.'s estate have been granted to E., who proposes to appoint F. and G. as new trustees of A.'s will and trustees for sale of her real estate (no part of which has yet been sold). No written assent to the devise on trust for sale has yet been made. What documents are required to effect E.'s purpose and in what order should they be dated ? H. B. AND W.

This transaction can be carried out by one composite deed. E. can appoint F. and G. trustees for sale by a deed in the usual form and can then in the same deed assent to the trust property vesting in the trustees: (see Prideaux's Precedents in Conveyancing, 22nd edit., vol. 3, p. 848). Alternatively E. can appoint F. and G. trustees by one deed, and subsequently in writing assent to the trust property vesting in them. The appointment must precede the assent in either case. Notice of the assent must be endorsed on the probate in accordance with the provisions of sect. 36 of the Administration of Estates Act 1925. DE P. 171. ABSTRACT OF TITLE-COMPANY'S ARTICLES AND MEMORANDUM.-On the sale of land by a company should the vendor's solicitor abstract parts of the company's memorandum and articles of association to show that the company has power to buy and sell land, &c., and to show the formalities necessary for affixing the common seal? W. C. S.

Under the Companies Act 1908, s. 16, duly incorporated companies have power to hold lands notwithstanding the Mortmain Acts. A solicitor need not therefore abstract any express power the company has; the purchaser can safely assume that the company has such a power. Nor need he show the formalities necessary for affixing the common seal, as under sect. 74 (1) of the Law of Property Act 1925, if the seal is affixed to a conveyance as therein mentioned, the conveyance shall be deemed in favour of a purchaser to have been duly executed, and takes effect accordingly. A.

172. TENANTS IN COMMON-DEVISE.-A. and B. in 1878 took a conveyance of a house in fee simple as tenants in common. They executed similar wills appointing X. sole executor and trustee, and each devised her share to X. upon trust for sale, and to pay the income to the other for her life and after her death three-fifths to X. and two-fifths to Y. absolutely. A. died in 1921, and X. duly proved her will. (1) What was the position on the 1st Jan. 1926 in view of the new Law of Property Acts? B. died in 1927, and X. proved her will. It is now required to sell. (2) What is now the position in view of the said Acts? S. W. AND B.

(1) Immediately before the coming into operation of the Law of Property Act 1925 this land was held at law or in equity in undivided shares vested in possession, and fell within the scope of Part IV. of the First Schedule of the Act. As A. was dead and her share was vested in X. as trustee, par. 1 (2) did not apply, but the case fell within par. 1 (4), and thereunder the legal estate vested in the Public Trustee upon the statutory trusts. (2) Now that B. is dead, X. is interested in one moiety as trustee for sale, and in the other as executor, and is beneficially entitled to three-fifths of the entirety absolutely. He is in a position, therefore, to appoint trustees in the place of the Public Trustee under par. 1 (4) (iii.), and the property will vest in the persons so appointed upon the statutory trusts. X. can appoint himself and Y. such trustees, when the persons beneficially interested will also have the legal estate; or he can appoint such other persons, as he thinks fit. If the shares have been incumbered the consent of the incumbrancers must be obtained. For a form of appointment see Prideaux's Precedents in Conveyancing, 22nd edit., p. 491. DE P.

173. CLUB-NEW TRUSTEES TRUSTEE ACT 1925.-We are acting for the trustees of the local conservative club who now desire to appoint new trustees. In the year 1919 certain freehold properties were conveyed to six trustees of the said club upon trust for sale with power to postpone. Of these trustees there are now three surviving, and it is desired to appoint nine new trustees and to vest the real estate in twelve trustees (the three survivors of the original trustees plus the nine new trustees). Does this trust come within the exception contained in sub-sect. 3a of sect. 34 of the Trustee Act of 1925, which provides that the restriction of the number of trustees to four shall not apply in the case of land vested in trustees with charitable, ecclesiastical or public purposes? Are the purposes of a political club public purposes within the meaning of the above-mentioned sub-section ? LEX.

Land vested in trustees upon trust for the purposes of a club of this kind is not land vested in them for charitable, ecclesiastical, or public purposes so as to bring it within the Trustee Act 1925, s. 34 (3) (a). "Public purposes must be construed as meaning the purposes of the state or some public body. The Conservative party cannot claim to be such a body. The number of trustees for sale must not, therefore, be more than four: (see Prideaux's Precedents in Conveyancing, 22nd edit., vol. 1, p. 709, note (g).

A.

174. WILL-LEASEHOLD-VESTING DEED-PRECEDENT.-A. died in 1927, having made a will under which he appointed B. and C. as trustees, and then proceeded as follows: "I give unto my trustees all my cottage property to pay the income arising therefrom unto and to the sole use of my wife and after her decease to my children in equal proportions. I give unto my wife for her sole use and benefit the residue of all my real and personal property wherever situate." He died possessed of two long leasehold cottages of a total value of about £500. Am I right in assuming that B. and C. must now execute a vesting assent in favour of the widow and that she will then become tenant for life; and the trustees will become trustees under the Settled Land Act 1925 ? Can you refer me to a precedent? CECIL E. HART.

A.'s will is a trust instrument creating a settlement, and his personal representatives are bound to convey the property to the tenant for life (see sect. 6 of the Settled Land Act 1925). The widow under sect. 20 (1) (viii.), is a person having the powers of a tenant for life, and is entitled to have the conveyance executed in her favour. Such conveyance (see sect. 8 (4) (b) can be by assent, which will be a vesting assent, and must contain the like statements and particulars as are required by the Act in the case of a principal vesting deed. (For a form of vesting deed see the Settled Land Act, First Schedule, Form 5). B. and C., as A.'s executors, are the trustees of the settlement for the purposes of the Act under sect. 30 (3). B. A. B.

175. NOTICE TO QUIT.-A. verbally lets a house to B., saying the rent is £a a month, payable on the first of every month. B. enters on the 1st July 1926. A. gives B. a rent book, inside which is a statement "Six months' notice on either side," signed by both A. and B. Can six months' notice be given on any first of a month, or must such notice be given to expire on some 1st July? The first entry in the rent book shows rent due the 1st Aug. £a, and as having been paid accordingly. The essence of a monthly tenancy is that it is a letting from month to month, and is determinable by a month's notice. It is submitted that the true view of the above facts is that a yearly tenancy was constituted, the rent being payable monthly. H. D.

This is not a yearly tenancy as the premises are not let at a yearly rent determinable at the end of the first or any subsequent year of the tenancy, but is a half-yearly tenancy and can be certainly determined by notice expiring on the 1st July or the 1st Jan: (see Doe d. King v. Grafton, 1852, 18 Q. B. 496, and Woodfall's Landlord and Tenant, 20th edit., p. 274). Whether the tenancy can be determined at any intermediate month is more doubtful, but as there is no particular rule as to the determination of this form of tenancy I think the notice can be given at any time to expire on the first of any month provided six months have elapsed. A.

176. HORTICULTURAL PRODUCE (SALE ON COMMISSION) ACT 1926. It is suggested that, having regard to the definition clause, there is nothing to prevent the consignor and consignee agreeing to contract that the Act shall not apply. But what will be a sufficient consideration, or is any consideration necessary? Does the word " agreement" in the Act mean more than that the parties are ad idem that the Act shall not apply, or does it mean that the agreement must possess the requisites of a legally enforceable contract? CAMBS.

In order for the Act not to apply, under sect. 3 (2) (b), the parties must enter into an agreement in writing that the produce is not consigned for sale on commission. The Act applies only to horticultural produce consigned for sale on commission; sect. 3 (2) provides that all produce consigned for sale shall be deemed to have been consigned for sale on commission. Sub-clauses (a) and (b) provide a means by which the presumption contained in the first part of the sub-section can be rebutted, but not a means for contracting out of the Act if the produce is sold on commission. It is not possible to contract out of the Act, but by an agreement it is possible to arrange for produce to be sold otherwise than on commission, when the Act will not apply. Such an agreement, arranging as it would for the sale of produce, and the terms on which it was to be sold, would necessarily have adequate consideration to support it. A.

177. STAMP DUTY-CONVEYANCE-ONE TRANSACTION.-A. died seised of a block of six houses. He devised four to his son B., and the remaining two to his son C. B. and C. have agreed to sell the whole block to a purchaser for £700, of which C. is to get £400 and B. £300. If two conveyances are made, one by each brother in respect of his own property, can the certificate of value under sect. 73 of the Finance (1909-10) Act 1910 be inserted, or will the transaction be regarded as a series of transactions in respect of which the aggregate amount or value of the consideration exceeds £500"? PUZZLED.

66

Upon a conveyance by different persons of separate interests in separate properties the conveyance has to be stamped with several stamps upon the separate considerations: (see Dart's Vendor and Purchaser, 6th edit., p. 795). Such a conveyance contains in fact several transactions and is recognised by the stamping authorities as such. This is a similar case, and as the vendors are different persons selling different properties the sale, if carried out by two conveyances, can be stamped at the reduced rate and the certificat

of value required by sect. 73 of the Finance Act 1909-10 properly given.

DE P. 178. LESSOR-RIGHT TO DISTRAIN.-In Dec. 1926 A. let a freehold dwelling-house to B. and C. as joint tenants for a term of seven years at £100 a year, the rent to be payable quarterly. B. has now made default in payment of the rent due the 25th March last. On the granting of the lease it was agreed that B. and C. could let the separate floors of the house to different tenants, which he did. Can A. distrain on the goods of the different tenants for the rent owing to him by B. and C.? The different tenants pay their rent weekly to the lessees. Would it make any difference if such rent were paid quarterly? Authorities will oblige. Jus.

This case falls within the scope of the Law of Distress Amendment Act 1908. If the undertenants' rents are of the full annual value of the premises or of the part thereof which is comprised in their tenancy, they are protected by sect. 1 (a) of the Act, and the superior landlord cannot levy distress upon their goods: (see Woodfall's Law of Landlord and Tenant, 20th edt., p. 556). A. cannot distrain upon the goods of the sub-tenants as they are apparently protected by this section, but the position cannot be definitely defined until the rents they are paying is known. The superior landlord can, however, serve a notice on the sub-tenants requiring future payments of rent to be made direct to the superior landlord (see sect. 6). Where this notice has been served the effect will be to establish an immediate relationship of landlord and tenant between A. and the under-tenants, and A. can, during the currency of such notice, recover sums payable thereunder from the undertenants by distress. (2) It would make no difference if the rent was paid quarterly, but if the rent was payable at longer intervals the Act would not apply. A.

179. TENANTS IN COMMON-CONVEYANCE.-A. and B., husband and wife, held realty as tenants in common. A. made a will, leaving all he had to B. for life, and on her death to his five children, and died, and his will was proved by B. and a son, C. B. made a will leaving her half share to two children, and appointed C. and one of the two children, D., joint trustees and executors. She is now dead and the two executors have proved her will, and it has been arranged to sell part of the realty. How is the conveyance to be effected? J. E.

It does not appear when A. and B. died. If they were both alive on the 1st Jan. 1926 the Law of Property Act 1925, Sched. I., Part IV., par. 1 (2), applies, and the legal estate vested in them as joint-tenants upon the statutory trusts. On the death of A. the legal estate survived in B. and passed on her death to her personal representatives who hold it upon the statutory trusts. In the event of A. having died before 1926 his moiety of the property became, under his will, settled land, and the entirety vested, when the Act came into operation, under par. 1 (4) of Part IV., in the Public Trustee upon the statutory trusts. In order to convey the property the legal estate must be got in from the Public Trustee. C. and D. together are the personal representatives of both A. and B. and can appoint new trustees in the place of the Public Trustee under the power conferred on them by par. 1 (4) (iii.). C. and D. could appoint themselves such new trustees or some other persons, and the legal estate will vest in such trustees upon the statutory trusts. Until the legal estate has been got in by such an appointment no sale is possible. For a form of appointment see Prideaux's Precedents in Conveyancing, 22nd edit., p. 491.

CORRESPONDENCE

DE P.

This department being open to free discussion on all Professional topics, the Editor does not hold himself responsible for any opinions or statements contained in it.

Re SUPREME COURT RULES, Order 55, RULE 57-POSTAGE and NOTICES.-We enclose some correspondence, which we have recently had with the Accountant-General respecting the procedure which has been for many years in practice in his department, whereby persons leaving notices as to payments under £5 were required to pay the postage thereon. You will observe that this practice is now to be abandoned. As the matter is one of interest to the Profession, we venture to suggest that the decision of the Accountant-General should be given as wide publicity as possible. In these circumstances, perhaps you will consider it of sufficient importance to refer to it in your next issue.

LINKLATERS AND PAINES.

[Copy.].-2, Bond-court, Walbrook, E.C. 4. 17th June 1927.-Sir,-Anglo-Canadian Lands (1912) Ltd.-Referring to our interview with your representative yesterday, we confirm the protest which we then made to your requirement that we should pay the extra postage of 1d. on each of the 54 Notices which we left with you for the purpose of your sending out remittances under £5. In the ordinary course we send out all Notices with d. stamp, and this, we submit, is all that we can be called upon to pay when we leave the Notices with you for amounts under £3. informed that such Notices would not be sent out unless we paid the full postage of 1d. on each Notice, the reason stated being

We were

that you had no funds out of which to pay for such Notices. This, however, seems difficult to understand, seeing that-after you receive the requests for payment of sums over £5-cheques are sent out to the various payees, and we presume postage on the envelopes is paid, or the letters are franked, and there seems no adequate reason why letters containing cheques under £5 should not be dealt with in the same manner. We can find no Rule or Regulation throwing the cost of the extra postage on the person whose duty it is to send out the Notices, nor obliging him to supply envelopes. Neither Order 55, Rule 57, nor Pay Office Rules and Practice 48 (C) would seem to create this obligation, and the cost of the postage is not allowed on taxation. We shall be obliged by your referring us to your authority for making your requirement. As a matter of principle, we submit the extra postage of 1d. on each of the 54 Notices we left with you should be refunded to us. We are, Sir, yours obediently, LINKLATERS AND PAINES.The Accountant-General, Supreme Courts of Justice, Strand, W.C. 2.

[Copy.]-No. C. D. 4431.-Supreme Court Pay Office, Royal Courts of Justice, London, W.C. 2, 21st June 1927.-Gentlemen,Anglo-Canadian Lands (1912) Ltd.-In reply to your letter of the 17th inst., the practice by which cheques of £5 and under are sent out with the Solicitors' notices in stamped envelopes supplied by them has been in operation for many years and so far as I am aware the particular point to which you draw attention has not been raised before, I have, however, now mentioned it to the Chief Taxing Master and we agree in thinking that Solicitors need not be required to supply any stamps in these cases.--I am, Gentlemen, Your Obedient Servant, J. A. LONGLEY.-Messrs. Linklaters and Paines, 2, Bond-court, Walbrook, E.C. 4.

OBITUARY

His Honour Judge JOHN FELIX KERSHAW died on the 16th June at the age of fifty-three. The son of the late Sir Louis Kershaw, he was educated at Shrewsbury School and Balliol College, Oxford, being called by the Inner Temple in 1897. His appointment in 1902 as Civil Judge at Khartoum formed the beginning of a distinguished judicial career in Egypt extending over more than twenty years. In 1913 he was appointed to the Native Appeal Court at Cairo, a position which he resigned in June 1926. January of this year he was appointed judge of Southwark, Greenwich, and Woolwich County Courts. His death at so comparatively early an age will be much regretted by the Profession.

In

Sir WALTER MURTON died on the 20th June at the age of ninety-one. Admitted in 1858, he was appointed Solicitor to the Board of Trade in 1875 on the formation of the Legal Department and retained that position until his retirement in 1900. In 1894

he received the C.B. in recognition of his services, and in 1899 received the honour of knighthood. In 1900 he was appointed the British representative at the Conference on German Claims arising out of the South African War.

Mr. GEORGE WILLIAM RICKETTS, barrister-at-law, died on the 16th June, at the age of sixty-three. Mr. Ricketts, who was educated at Winchester and Oriel College, Oxford, was called by the Inner Temple in 1889, and as a young man had a very distinguished athletic career. In 1914 he was appointed Recorder of Portsmouth and in the same year he was made Junior Counsel to the Admiralty (Common Law). In 1920 Mr. Ricketts was made a Bencher of his Inn. He was for some years hon. secretary of the Wykehamist Society.

Mr. DONALD WILLIAM GARDEN COWIE, barrister-at-law, late of the Indian Civil Service, died on the 16th June at the age of sixtytwo. Mr. Cowie was called by Gray's Inn in 1894 and was shortly thereafter appointed Registrar of the Madras High Court on the appellate side. He was engaged in executive and judicial work until 1908, when he was made Inspector-General of Police, a position which he held until his retirement in 1914.

Mr. EDWIN SIDNEY HARTLAND, for many years Registrar of the County Court, Gloucester, and District Registrar of the High Mr. Court, died on the 19th June, at the age of seventy-eight. Hartland was in his later years well known as an anthropologist and made a special study of folklore, being the author of several books on this subject.