United Kingdom-Release Refused ]-The fact that the defendants have given a guarantee abroad to put in bail to answer the judgment of a foreign Court in a case of collision is not a ground for ordering the release of their ship from an arrest in an action commenced in this country, where no legal proceedings have been instituted in the foreign Court. The Christiansborg (54 L. J. P. 84; 10 P. D. 141) distinguished. The Mannheim, 6.

VI. Harbour Authority. Duty to provide Efficient Tugs-Liability— Ribble Navigation Act, 1883.] Under the Ribble Navigation Act, 1883, the defendants were constituted the harbour authority for the port of Preston, and all vessels entering or within the port or harbour were under the control of the defendants' harbour master, whose orders they were bound to obey. The plaintiffs' vessel on arrival at the mouth of the river was lightened under the orders of the defendants, and their harbour master subsequently informed the plaintiffs' master that there would be sufficient water on a certain morning to enable the plaintiffs' vessel to dock at Preston, and a tug was supplied by the defendants for the purpose of towing her to the dock. The plaintiffs' vessel was preceded up river by two smaller vessels which were towed by two tugs also supplied by the defendants. Owing to bad stoking, or some other cause which was not explained by the defendants, the leading tug occupied an hour in doing what she should have accomplished in thirty-five minutes. It was impossible for the plaintiffs' vessel, owing to the narrowness of the channel, either to pass the leading vessel and her tug or to turn back. The two leading vessels entered the Preston dock, but the plaintiffs' vessel was stranded about a quarter of a mile from the dock owing to the river having fallen about fourteen inches, and was damaged:-Held, that the defendants, as between themselves and the plaintiffs, had the

duty imposed upon them to supply an efficient tug for the leading vessel, and that as a prima facie case had been made out by the plaintiffs that the tug was not efficient, and that prima facie case had not been explained away by the defendants, they were liable for the damage caused to the plaintiffs' vessel. The Ratata, (C.A.) 39.

VII. Jurisdiction.

County Court-Trial by Jury.]-Section 101 of. the County Courts Act, 1888, does not confer a right upon the plaintiff or the defendant in an action brought on the Admiralty side of a County Court under section 2 of the County Courts Admiralty Jurisdiction Amendment Act, 1869, to have the case tried by a jury. The Theodora, 50.

VIII. Bottomry Bond.

Necessaries-Bond on Ship, Freight, and Cargo Claim by Material Men to have Assets Marshalled.]-The Court, acting upon equitable principles, will not direct assets to be marshalled except in cases where the two funds to which one of the creditors can resort belong to the same person. The Edward Oliver (36 L. J. Adm. 13; L. R. 1 A. & E. 379) distinguished. The Chioggia, 174.

WORDS. "Accidents of the seas," 172.

"Alleged adulterer," 57.

"Cruelty," 122.

"Desertion," 31.

"Passengers," 152.

"Ship or Vessel," 99.