KEATING, MARY, Liverpool, tobacconist. Ct. Liverpool. Pet. Aug. 9. Order, Aug. 28. REYNOLDS, GEORGE WILLIAM LEWIS, Shepton Mallet, schoolmaster. Ct. Wells. Pet. Aug. 26. ROBERTS, WILLIAM HENRY, Wigan, monumental mason. Ct. Wigan. Pet. Aug. 27. Order, Aug. 27. SIMPSON, JAMES, Cheltenham, draper's assistant. Ct. Cheltenham. Pet. Aug. 25. Order, Aug. 25. TOMLINSON, JOSEPH, Bury, schoolmaster. Ct. Bolton. Pet. Aug. 25. Order, Aug. 25. Gazette, Sept. 2. To surrender at the High Court of Justice, in Bankruptcy. BOOTY, WILLIAM, late Pentonville-rd, wholesale boot manufacturer. Pet. Aug. 22. Order, Aug. 30. GREEN, FRANK, late Ramsgate, steward on board a mail steamship. Pet. Aug. 29. Order, Aug. 29. KELLY, TIMOTHY, West India Dock-rd and Lukach Wharf, Cubitt Town, engineer. Pet. Aug. 30. Order, Aug. 30. PARDOE, SAMUEL EDWARDS, South-st, Grosvenor-sq, lodging-house keeper. Pet. Aug. 29. Order, Aug. 29. PICK, ANSELM, Queen Victoria-st, furrier's manager. Pet. June 18. Order, Aug. 27. ROOPER, CHARLES FREDERICK, Heathcote-st, Mecklenburg-sq, gentleman. Pet. July 10. Order, To surrender at their respective District Courts, CLARKE, JOHN, Tipton, grocer. Ct. Dudley. Pet. Aug. 28. Order, Aug. 28. HURRY, WILLIAM, and HURRY, THOMAS WILLIAM, Ipswich, paper manufacturers. Ct. HERBERT, GEORGE THOMPSON, late Leeds, butter factor. Ct. Leeds. Pet. Aug. 29. Order, Aug. 29. ILIFF. WILLIAM, Burton-on-Trent, licensed victualler. Ct. Burton-on-Trent. Pet. Aug. 28. LONGLEY, AARON, Sutton, carman. Ct. Croydon. Pet. Aug. 8. Order, Aug. 26. MONIE, CLARA JANE, Southport, hairdresser, widow. Ct. Liverpool. Pet. Aug. 30. Order, PINCH ESS, JOSEPH, Leicester, boot manufacturer. Ct. Leicester. Pet. Aug. 27. Order, Aug. 27. FIRST MEETINGS AND PUBLIC EXAMINATIONS. ACOCK, EDWARD, Cheltenham, sadler. Ct. Cheltenham. Meeting, Sept. 6, at 4.30, at County BURROWS, OLIVER, Enfield-rd, Kingsland-rd, manager to boot manufacturer. Ct. High Court of Justice, in Bankruptcy. Meeting, Sept. 9, at 11, at 33, Carey-st, Lincoln's-inn. Exam. Sept. 30, at 12 30, at 34, Lincoln's-inn-fids. BLOOMER, ROBERT, Accrington, printer. Ct. Blackburn. Meeting, Sept. 5, at 2.30, at the County Court-house, Blackburn. Exam. Oct. 21, at 10.30, at the County Court-house, Blackburn. Order sum. adm. Aug. 25. BISHOP, WILLIAM FRANCIS, the Parade, Chiswick, draper. Ct. Brentford. Meeting, Sept. 8, at 3. at 95, Temple-chambers, Temple-avenue. Exam. Oct. 7, at 2.15, at the Townhall, Brentford. Ord. sum. adm. Aug. 28. BROWNSON, WILLIAM HENRY, Nottingham, publican. Ct. Nottingham. Meeting, Sept. 5, at noon, at office of Off. Rec. Nottingham. Exam. Oct. 17, at 10, at the County Court-house, Nottingham. BAMBER, CHARLES JAMES, Preston, wholesale fruiterer. Ct. Preston. Meeting, Sept. 5, at 11.30, at office of off. Rec. Preston. Exam. Oct. 10, at 11, at the County Court offices, Preston. Order sum, adm. Aug. 23. BEECH, GEORGE. Sheffield, beerhouse-keeper. Ct. Sheffield. Meeting, Sept. 9, at 3, at office of Off. Bec. Sheffield. Exam. Oct. 9, at 11.30, at the County Court-hall, Sheffield. Order sum. adm. Aug. 22. BARBEN, THOMAS, Barrow-in-Furness, coal dealer. Ct. Ulverston and Barrow-in-Furness. Meeting, Sept. 16, at noon, at office of Off. Rec. Barrow-in-Furness. Exam. Sept. 16, at 2.15, at the Court-house, Barrow-in-Furness. Order sum, adm. Aug. 22. CATHRICK, CHARLES JONATHAN, Stockwell Park-crescent, Brixton, clerk. Ct. High Court of Justice, in Bankruptcy. Meeting, Sept. 5, at 1, at 33, Carey-st, Lincoln's-inn. Exam. Sept. 30, at 12.30, at 34, Lincoln'--inn-fids. Order sum. adm. Aug. 8. CASSON, JONATHAN, Windermere, livery stable-keeper. Ct. Kendal. Meeting, Sept. 13, at 11.45, at office of Off. Rec. Kendal. Exam. Sept. 13, at 1, at the Court-house, Kendal. Order sum. adm. Aug. 20. DIMBLEBY, STEPHEN. Imperial-mansions, New Oxford-st, manufacturer's agent. Ct. High Court of Justice, in Bankruptcy. Meeting, Sept. 8, at noon, at Bankruptcy-bldgs, Portugalst, Lincoln's-inn. Exam. Sept. 23, at 11, at 34, Lincoln's-inn-filds. Order sum. adm. Aug. 25. GREAVES, FRANK HUBERT, Liverpool, milliner. Ct. Liverpool. Meeting, Sept. 11, at 3, at office of Off. Rec. Liverpool. Exam. Sept. 11, at 11, at Government-bldngs, Liverpool. Order sum adm. Aug. 19. HENDERSON, JOHN YOUNG, and CRAIG, CHARLES TAYLOR, Eastcheap, commission merchants. Ct. High Court of Justice, in _Bankruptcy. Meeting, Sept. 10, at noon, at Bankruptcy.bldngs, Portugal-st, Lincoln's-inn. Exam. Sept. 23, at 11.30, at 34, Lincoln's-inn-fids. JONES, MORRIS, Graham-st, City-rd, dairyman. Ct. High Court of Justice, in Bankruptcy. Meeting, Sept. 10, at 11, at Bankruptcy-bidngs, Portugal-st, Lincoln's-in. Exam. Sept. 23, at 11.30, at 34, Lincoln's-inn-fids. Order sum. adm. Aug. 6. JOHNSTON, MARY DIXON, Turton, domestic servant. Ct. Bolton. Meeting, Sept. 5, at 11.30, at MORRISON, ROBERT, Mumbles, late commission agent. Ct. Swansea. Meeting, Sept. 5, at noon, Gazette, Sept. 2. Ct. AKERMAN, EDWARD, Brooksby-st, Liverpool-rd, Islington, licensed victualler's manager. BLYTH, CARLTON E., Berkeley-st, gentleman. Ct. High Court of Justice, in Bankruptcy. Meeting, Sept. 17, at noon, at Bankruptcy-bldngs, Portugal-st, Lincoln's-inn. Exam. Oct. 15, at noon, at 34, Lincoln's-inn-fids. BRICK, GEORGE, Birkenhead, no occupation. Ct. Birkenhead. Meeting, Oct. 1, at 3, at office of CHESTER, HENRY, Long-acre, commercial olerk. Ot. High Court of Justice, in Bankruptcy. Meeting, Sept. 10, at 1, at 33, Carey-st, Lincoln's-inn. Exam, Oct. 15, at noon, at 31, Lincoln'sinn-fids. Order sum. adm. Aug. 18. CROW, GEORGE, Canterbury, builder. Ct. Canterbury. Meeting, Sept. 10, at 10, at office of Off. Reo. Canterbury. Exam. Sept. 19, at 10.30, at the Guildhall, Canterbury. DAY, WILLIAM THOMAS, Bloomsbury-sq, auctioneer. Ct. High Court of Justice, in Bankruptcy. Meeting, Sept. 9, at 1, at 33, Carey-st, Lincoln's-inn. Exam. Oct. 15, at noon, at 34, Lincoln's. inn-fids. DAIMPRE, ISIDORE, Colebrooke, olerk in holy orders. Ct. Exeter. Meeting, Sept. 12, at noon at office of Off. Rec. Exeter. Exam. Sept. 25, at 11, at the Castle, Exeter. Order sum, sum, adm. Aug. 28. GUNTON, THOMAS HENRY, Luton, licensed victualler. Ct. Luton. Meeting, Sept. 12, at 4, at office of J. G. Roberts, solicitor, Luton. Exam. Sept. 23, at noon, at the Court-house, Luton. Order sum. adm. Aug. 21. GRIFFITHS, WILLIAM, Dafen, butcher. Ct. Carmarthen. Meeting, Sept. 9, at 11, at office of off. Reo. Carmarthen. Exam. Sept. 26, at 11.30, at the Guildhall, Carma: then. Order sum. adm. Aug. 29. GREEN, GEORGE, West End-la, Kilburn, late cabmaster's manager. Ct. High Court of Justice, HURRY, WILLIAM, and HURRY, THOMAS WILLIAM, Ipswich, paper manufacturers. Ct. Ipswich. JACOBS, JOSHUA, Jewin-cres, Cripplegate, furrier. Ct. High Court of Justice, in Bankruptcy. Meeting, Sept. 12, at noon, at Bankruptcy-bldngs, Portugal-st, Lincoln's-inn. Exam. Oct. 7, at 11, at 34, Lincoln's-inn-fids. Order sum. adm. Aug. 16. JARVIS, FRANCIS BERKELEY, Exeter-st, Strand, inanaging director of Damant and Co. Ct. High Court of Justice, in Bankruptcy. Meeting, Sept. 16, at 11, at 83, Carey-st, Lincoln's-inn. Exam. Oct. 7, at 11.30, at 34, Lincoln's-inn-fids. LEAH, JOHN (trading as Edward Willcox), late Birmingham, provision dealer. Ct. Birmingham. LOWE, GEORGE THOMPSON, Derby, grocer. Ct. Derby. Meeting, Sept. 12, at 2.30, at office of Off. at office of Off. Rec. Leeds. Exam. Sept. 23, at 11, at the County Court-house, Leeds. Order sum. adm. Aug. 29. PIKE, FREDERICK HENRY, Salisbury, bootmaker. Ct, Salisbury. Meeting, Sept. 9, at 12.30, at office of Off. Rec. Salisbury. Exam. Oct. 10, at 2, at Council-house, Salisbury. Order sum. adm. Aug 29. PRIDMORE, WILLIAM EDWARD, Aylesbury, baker. Ct. Aylesbury. Meeting. Sept. 15, at noon, at 1, St. Aldate's, Oxford. Exam. Sept. 22, at 11, at 25, Walton-st, Aylesbury. Order sum. adm. Aug. 25. PLUMB, ROBERT MINSON, Upwell, manure merchant's agent. Ct. King's Lynn. Meeting, Sept. 13, at 1, at office of Off. Rec. Norwich. Exam. Oct. 15, at 11.30, at the Court-house, King's Lynn. Order sum. adm. Aug. 7. PINCHESS, JOSEPH, Leicester, boot manufacturer. Ct. Leicester. Meeting, Sept. 11, at 3, at office of Off. Rec. Leicester. Exam. Oct. 29, at 10, at the Castle, Leicester. QUICK, HENRY, Portsea, baker. Ct. Portsmouth. Meeting, Sept. 15, at 4, at 166, Queen-st, Portsea. Exam. Sept. 15, at noon, at the Court-house, Portsmouth. Order sum. adm. Aug. 28. REYNOLDS, GEORGE WILLIAM LEWIS, Shepton Mallet, schoolmaster. Ct. Wells. Meeting, Sept. 17, at 12.30, at office o Off. Rec. Bristol. Exam. Oct. 21, at 11, at the Townhall, Wells. SEBRIGHT, ARTHUR E. S., late Parish's hotel, George-st. Ct. High Court of Justice, in Bankruptcy. Meeting, Sept. 12, at noon, at 33, Carey-st, Lincoln's-inn. Exam. Sept. 23, at 12.30, at 34, Lincoln's-inn-fids. SHAKELL, WILLIAM E., late Bournemouth, estate agent. Ct. High Court of Justice, in Bankruptcy. Meeting, Sept. 11, at 11, at Bankruptcy-bldngs, Portugal-st, Lincoln's-inn. Exam. Oct. 7, at noor, at 34, Lincoln's-inn-fids. SHAW, ZACHARIAH, Netherton, butcher. Ct. Dudley. Meeting, Sept. 9, at 11, at office of off. Rec. Dudley. Exam. Sept. 9, at 2, at the Court-house, Dudley. Order sum. adm. Aug. 18. SENDYK, OSCAR, Sydenham Park, gentleman. Ct. Greenwich. Meeting, Sept. 9. at 11, at 24, Railway-approach, London Bridge. Exam. Oct. 7, at 1, at the Court-house, Greenwich. Order sum. adm. Aug. 22. SHAW, ROBERT, Sunderland, painter. Ct. Sunderland. Meeting, Sept. 9, at noon, at office of Off. Rec. Sunderland. Exam. Oct. 23, at 2.30, at the Court-house, Sunderland. Order sum. adm. Aug. 30. SMITH, GEORGE, Walsall, boot dealer. Ct. Walsall. Meeting, Sept. 10, at 10.30, at office of Of. WHITE, WILLIAM, Margate, carpenter. Ct. Canterbury. Meeting, Sept. 10, at 4, at 56, High-st, NOTICE OF DAY APPOINTED FOR PROCEEDING WITH PUBLIC NORMAND, JOSEPH, East Molesey, architect. Ct. Kingston, Surrey. Exam. Oct. 17, at 2.30, at the County Court, Kingston, Surrey. ADJUDICATIONS. Gazette, Aug. 29. ATKINSON, ALFRED, Knaresborough, commission agent. Ct. York. Order, Aug. 25. Pet. Aug. 25. BULLOCK, GEORGE SCOTT, Devons-rd, Bromley, licensed victualler. Ct. High Court of Justice, in Bankruptcy. Order, Aug. 26. Pet. Aug. 25. BROOKE, PHILEMON, Outlane, linsey manufacturer. Ct. Huddersfield. Order, Aug. 26. Pet. BAMBER, CHARLES JAMES, Preston, wholesale fruiterer. Ct. Preston. Order, Aug. 25. Pet. CROW, GEORGE, Canterbury, builder. Ct. Canterbury. Order, Aug. 26. Pet. Aug. 26. FORD, JAMES WILLIAM, Cheltenham, licensed victualler. Ct. Cheltenham. Order, Aug. 25. GRIFFITHS, WILLIAM, Dafen, butcher. Ct. Carmarthen. Order, Aug. 28. Pet. Aug. 25. LEE, RUFUS, Northowram, coal dealer. Ct. Halifax. Order, Aug. 27. Pet. Aug. 13. MARKS, EZEKIEL, Birmingham, tailor. Ct. Birmingham. Order, Aug. 26. Pet. July 14. ROBERTS, WILLIAM HENRY, Wigan, monumental mason. Ct. Wigan. Order, Aug. 27. Pet. SMITH, ALFRED ALLEN, Great Grimsby, miller. Ct. Great Grimsby. Order, Aug. 26. Pet. SHAW, ROBERT, Sunderland, painter. Ct. Sunderland. Order, Aug. 23. Pet. Aug. 23. Order, TILBY, GEORGE FREDERICK, Seymour-pl, Bryanston-sq, corn dealer. Ct. High Court of Justice, WALTON, DAVID, Leeds, hydraulic leather maker. Ct. Leeds. Order, Aug. 25. Pet. Aug. 25. Gazette, Sept. 2. AKERMAN, EDWARD, Brooksby-st, Liverpool-rd, Islington, licensed victualler's manager. Ct. Aug. 25. ACOCK, EDWARD, Cheltenham, saddler. Ct. Cheltenham. Order, Aug. 28. Pet. CLARKE, JOHN, Tipton, grocer. Ct. Dudley. Order, Aug. 28. Pet. Aug. 28. GREAVES, FRANK HUBERT, Liverpool, milliner. Ct. Liverpool. Order, Aug. 29. Pet. July 30. HAMBLING, ROBERT WILLIAM WOODROFFE, Dunstable, insurance agent. Ot. Luton. Order, Aug. 28. Pet. Aug. 1. HIGGS, JAMES, and HIGGS, BENSON, Southampton, grocers. Ct. Southampton. Order, Aug. 30. Pet. Aug. 22. HURRY, WILLIAM, and HURRY, THOMAS WILLIAM, Ipswich, paper manufacturers. Ct. Ipswich. Order, Aug. 27. Pet. Aug. 27. ILIFF, WILLIAM, Burton-on-Trent, licensed victualler. Ct. Burton-on-Trent. Order, Aug. 28. LONGLEY, AARON, Sutton, carman. Ct. Croydon. Order, Aug. 29. Pet. Aug. 8. MEADOWS, JAMES CARSWELL, Liverpool, aërated water manufacturer. Ct. Liverpool. Order, MONIE, CLARA JANE, Southport, hairdresser, widow. Ct. Liverpool. Order, Aug. 30. Pet. PARDOE, SAMUEL EDWARDS, South-st, Grosvenor-sq, lodging-house keeper. Ct. High Court of T HOTEL METROPOLE LONDON Situated in NORTHUMBERLAND AVENUE and WHITEHALL PLACE, TRAFALGAR SQ., Is arranged and furnished to afford Residents every possible convenience and comfort. In addition to a large number of Single and Double Bed Rooms, and Bed Rooms with Bath Room and Lavatory attached, there are clegant Suites of Private Apartments, and most luxurious General Rooms. HIGHEST CLASS CUISINE, FINEST WINES, AND VERY BEST ATTENDANCE. SERVICE À LA CARTE; also TABLE D'HÔTE. Breakfast, Luncheon, & Dinner at Separate Tables. Telegrams, "Metropole, London." THE BEST PRICE for WASTE PAPER Sittingbourne, Kent, where the paper is re-manufactured on the premises, which is not done by any other buyer. Send for Waste Paper Circular, which gives every parti. cular, and compare prices with those of any advertisers who are not paper manufacturers. THE Pet. BIRTHS, MARRIAGES, AND DEATHS. BIRTHS. MACDONALD.-On the 23rd ult., at Leigham Court-road West, Streatham, the wife of Thomas MARRIAGES. 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Four lines of thirty words, or less than thirty words, in body type 35. 6d. Each additional line, or ten words, or less than ten words.......................................................... Os. 6d. For three insertions a reduction of 10 per cent; for six insertions a reduction of 80 per cent. Advertisers whose reference is under initials to this office should remit 6d. additional to defray postage in transmitting replies to their Advertisements. Advertisements must reach the Office not later than five o'clock on Thursday afternoon, and must be accompanied by a remittance. Post-office Orders payable to Horace Cox. THE struggle between labour and capital seems likely to bring into being one of the most wealthy and influential federations of modern times. We refer to the new Shipping Union, which purports to be a federation of the entire shipping trade of the British Empire. Its main object is to deal with all labour questions directly or indirectly affecting British shipping. The law, it is said, has proved to be powerless to cope with the difficulty, mainly owing no doubt to the fact that the struggle between the two interests is of modern growth, and is each day developing new features. Conciliation seems impossible. The formation of the new union ought, if properly managed, to show that our age is not without a remedy for an evil which is rapidly destroying and paralysing the trade of the world. Let each interest feel that it has a foeman worthy of its steel, and the result will probably be mutual concessions. Without espousing either side, there are, no doubt, grounds for mutual complaints. If each interest is sufficiently powerful to fear and respect the other, we ought in a short time to hear the last of the tyrannous and unreasonable conditions of which each at present complains. It may be that the proposed union may provoke a more serious struggle than the commercial world has yet seen, but if it is to be decisive the world ought not to grudge the cost. IN future metropolitan vestries may flag footpaths and recover the expense of so doing from the frontagers. The 78th section Vol. LXXXIX.-No. 2476. of the Metropolis Management Act 1862 (25 & 26 Vict. c. 102) is now repealed by a new Act (53 & 54 Vict. c. 54), and the rule which is to prevail from to-day may be shortly stated. When a London footway has been repaired at the public expense, but is not flagged or is only partially flagged, and the vestry or district board of works in its wisdom thinks it expedient to flag the footway or complete its flagging, then the owners of houses and lands abutting on the road or street are to pay the amount of the expense incurred. If the estimate exceeds the actual cost, then the surplus will be returned, and vice versa. But the owners of land may be charged in a less proportion than the owners of house property if the local authority think it right. The expense of flagging will be apportioned and recovered according to the well-known statutory method. And when the footway is once flagged, the vestry or district board of works will be bound to keep the flagging in good and substantial repair. Henceforward we ought to see fewer instances of unpaved causeways in suburban districts. WHEN one sees an amendment of the unfortunate Bills of Sale Act 1882 (45 & 46 Vict. c. 43) actually in the Statute-book, one hopes that some substantial progress has been made towards removing the many difficulties which have arisen under that Act. The hope is a vain one, for all that the new Act of 1890 (53 & 54 Vict. c. 53) does is to exempt certain letters of hypothecation from the operation of sect. 9 of the Act of 1882. In future "any instrument given or executed at any time prior to such deposit, reshipment, or delivery as hereinafter mentioned, "hypothecating or declaring trusts of imported goods during the interval between the discharge of the goods from the ship in which they are imported and their deposit in a warehouse, factory, or store, or their being reshipped for export or delivered to a purchaser, not being the purchaser giving or executing such instrument," is not to be deemed a bill of sale within the purview of the Act of 1882. But the new Act contains a saving for the operation of sect. 44 of the Bankruptcy Act 1883 (46 & 47 Vict. c. 52) in respect of any goods comprised in any letter of hypothecation, if the goods would but for the Act of 1890 be within the 'reputed ownership' "clause. The amendment now made is a modest but a useful one. 66 THE Marriage Act 1890 (53 & 54 Vict. c. 47) will be useful in facilitating the marriage of two British subjects, or of one British subject and a foreigner, outside the United Kingdom. Marriages at British Embassies, &c. are to be valid (sect. 2). The Consular Marriage Acts 1849 and 1868 are made applicable to certain governors or other officers authorised to solemnise marriages. This section is not limited to places outside HER MAJESTY'S dominions (sect. 3). Marriages may be solemnised on the QUEEN'S ships on foreign stations, and the Consular Marriages Acts are to apply (sects. 4, 6). Consuls may register marriages, solemnised in accordance with local law, where at least one party is a British subject (sect. 6). Notices of marriages at consulates are to be suspended for fourteen days whether there is a licence or not, and the hours of marriage are extended to 3 p.m. (sects. 7, 8). Regulations of a very varied character may be made by Order in Council (sect. 9). The Act does not affect the Royal Family, and contains a general saving (sect. 10). It comes into operation on 1st Jan. 1891. We trust that the regulations which may be made under sect. 9 will be very carefully considered, as they may be framed so as to prohibit marriage in places where it is thought that sufficient facilities for marriage exist, and also may "adapt" (not merely "adopt ") the Consular Marriage Acts in various cases. Such regulations are to be laid before Parliament, and are, to have the force of statute. It is obvious that the validity of marriages may be endangered by these regulations, which will necessarily be of a complex character, unless there is a provision contained in the Order in Council to the effect that non-compliance therewith shall not invalidate a marriage solemnised by the proper officer or his deputy. Such a provision would fall within the lines of the more general recommendations of the Royal Commission on the laws of marriage, who published their valuable report in 1869. AN Act of considerable importance is now in operation; we mean the Tenants' Compensation Act 1890 (53 & 54 Vict. c. 57). Its principal object is to amend the law with respect to compensation due to tenants on land under mortgage. When a man occupies land under a contract of tenancy with the mortgagor, whether made before or after the passing of this Act, which is not binding on the mortgagee of such land, then (a) the occupier shall, as against the mortgagee who takes possession, be entitled to any compensation which is, or would, but for the mortgagee taking possession, be due to the occupier from the mortgagor as regards crops, improvements, tillage, or other matter connected with the land, whether under the custom of the country or under the Agricultural Holdings Act 1883 (46 & 47 Vict. c. 61), and the Allotments and Cottage Gardens Compensation for Crops Act 1887 (50 & 51 Vict. c. 26), or under agreements sanctioned by these Acts. Only any sum ascertained to be due to the occupier for such compensation, or for any costs connected therewith, may be set off against any rent or other sum due from him in respect of the land, and recovered as compensation under the Acts of 1883 and 1887, but, unless so set off, shall, as against the mortgagee, be charged and recovered in accordance only with sect. 31 of the Act of 1883, as if the mortgagee were the landlord within the meaning of that section. Secondly, (b) before the mortgagee deprives the occupier of possession of the land otherwise than in accordance with the contract of tenancy, he is to give the occupier six months' notice in writing of his intention so to deprive him, and if he so deprives him compensation shall be due to the occupier for his crops, and for any expenditure upon the land which he has made in the expectation of holding the land for the full term of his contract of tenancy, in so far as any improvement resulting therefrom is not exhausted at the time of his being so deprived, and such compensation is to be determined in like manner as compensation under the Acts of 1883 and 1887, and is to be set off, charged, and recovered in the manner already stated. But this last rule is only to apply where the contract of tenancy is for a tenancy from year to year, or for a term of years not exceeding twenty-one, at a rack rent. These are useful and substantial amendments of the law. It is also a serviceable change to make improvement in parts 1 and 2 of the schedule to the Act of 1883, when charged by an order under sect. 31 of that Act, land charges under the Act of 1888 (46 & 47 Vict. c. 61), and registered accordingly. Provisions for the payment of tithe rentcharge arising under the Tithe Commutation Act (6 & 7 Will. 4, c. 71) are very properly excepted from the new Act. SOME questions of the highest importance affecting the criminal procedure in this country arose in Dixon v. Wells (62 L. T. Rep. N. S. 812). In this case an information was laid before two justices against the appellant, under the Sale of Food and Drugs Acts 1875 and 1879, with reference to the sale of a quantity of new milk upon the 20th Sept. No summons was issued by such justices, but subsequently a summons returnable on the 23rd Oct. was issued by a justice who had not heard the information. The appellant appeared and objected that the justices had no jurisdiction, as the summons had been illegally issued; but the objection was overruled by the stipendiary magistrate, on the ground that, even assuming there had been a defect in the issuing of the summons, the same was cured by the defendant appearing. A case was, however, stated for the opinion of the court, asking (1) whether there was any irregularity in the issue of the summons; (2) if so, whether it was cured by appearance; (3) whether the magistrate had jurisdiction to hear and determine. Lord COLERIDGE said the objection taken was, that this was no summons at all, because the justice who issued the summons did not hear the information, and the justices who did hear the information did not issue the summons. "We are told," continued the LORD CHIEF JUSTICE, "that a practice has grown up by which a clerk to justices hears a complaint, draws out a summons, and then, without any written information, takes the summons to any justice whom he can find for signature. Whether there is any prima facie case or not the justice is perfectly ignorant, and I must say that I cannot imagine any practice which is more likely to lead to injustice to persons than such as has been described to us in this case. If the justice who issued the summons in this case had heard all the facts he might never have signed the summons at all. I cannot regard this document as a summons at all, and it seems to me to be issued in direct defiance of Jervis's Act (11 & 12 Vict. c. 43), s. 1." This section says that, where a complaint is made to justices upon which they have authority to make orders, they may issue a summons. Lord COLERIDGE proceeds: "If I was at liberty to lay down the law, I should say the above provision of Jervis's Act should be strictly obeyed, and that, if persons purporting to act under it disobeyed that provision, such persons would be acting without jurisdiction. But that is not the law, because, so far back as 1865 Chief Justice ERLE, in Reg. v. Shaw (12 L. T. Rep. N. S. 470; 34 L. J. 169, M.C.), laid down the law to be that, if a man was brought before the justices without any summons or information they could convict him." His Lordship then cited Reg. v. Hughes (40 L. T. Rep. N. S. 685; 4 Q. B. Div. 614) as confirming the opinion of Chief Justice ERLE. Lord COLERIDGE, however, considered that there were two circumstances which distinguished the case before him from those cited: First, that here there was a distinct protest; second, that in sect. 10 of the Sale of Food and Drugs Act 1879 there is an express provision with reference to the time between the summons and the return day. On these grounds (but chiefly on the latter) the conviction was quashed. We trust that, after the very plain language of the LORD CHIEF JUSTICE, the practice that he has condemned will be discontinued. Whether in an ordinary case (not under the Sale of Food, &c., Act) a protest by the person irregularly summoned would be sufficient, he really left undecided. By sect. 3 of the Life Assurance Companies Act 1870 (33 & 34 Vict. c. 61) every company commenced to carry on the business of life assurance is required to deposit the sum of £20,000 with the official therein referred to, to be invested by him as therein mentioned. Such deposit is to be returned to the company "so soon as its life assurance fund accumulated out of premiums shall have amounted to £40,000." It is, we think, tolerably plain that the meaning of the words "accumulated out of premiums" is that the company shall have so successfully carried on its life assurance business as to permit of its having accumulated out of the premiums of that life assurance business the sum of £40,000. At any rate, that was the view taken by Mr. Justice KAY, as to the interpretation of the phrase, in the recent case of Ex parte The Scottish Economic Life Assurance Society Limited (62 L.T. Rep. N.S. 926). But few questions turning upon that section have come before the courts, as its clear provisions scarcely leave room for any doubt in ordinary cases. However, in Ex parte The Scottish Economic Life Assurance Society Limited an entirely new point was raised, payment out of the deposited fund being claimed by two life assurance companies which had agreed to amalgamate. It appeared that the Scottish Economic Society, upon being formed to carry on the business of life assurance, had made the statutory deposit of £20,000. The society subsequently went into liquidation, and then entered into an agreement for amalgamation with the Scottish Metropolitan Life Assurance Company, the society's liability for policies, amounting to about £260,000, being taken over by the latter company. The society, not having accumulated the necessary £40,000, was not entitled to the return of its deposit of £20,000. The company, on the other hand, had accumulated £100,000. A petition was presented by the company, the society, and the liquidators of the society, asking that the deposit, which had been duly invested, might be transferred and paid to the company. The important question was whether the amalgamated bodies were not justified in claiming such transfer and payment without any further delay, as their joint life assurance funds accumulated out of premiums much exceeded the amount specified in the section. Mr. Justice KAY thought that there were serious objections to the claim. As the learned judge pointed out, the accumulation made by the company was not effected out of the premiums on the policies of the society. The letter of the Act of 1870 was therefore not complied with, because sect. 3 requires that, before payment out of the deposited fund, there must be an accumulation of £40,000 out of the premiums on the policies of the particular company by which the deposit was made. Moreover, in his Lordship's opinion, the spirit of the Act was not satisfied, because there had been no sufficient accumulation in respect of or to meet the policies of the society. Mr. Justice KAY came to the conclusion that, before the £20,000 could be paid to the company, as petitioned for, there must be an accumulation of £40,000, which might, however, be made up out of the premiums of any or all of the policies of the company, in addition to the fund set apart to answer the liability of the company in respect of its policies existing previously to the amalgamation. By this means the accumulated fund of £100,000 set apart as a proper security for the policy-holders of the company before the amalgamation took place was not affected. It seems evident that Mr. Justice KAY in directing this course adopted the only way out of the difficulty that was open. EFFECT OF BANKRUPTCY ON ANTECEDENT TRANSACTIONS-COMPLETION OF ATTACHMENT BEFORE RECEIVING ORDER. IT is always a somewhat difficult matter to ascertain whether or not a debtor's goods or lands have been taken in execution or a debt attached within the meaning of sect. 45 of the Bankruptcy Act 1883, so as to prevent the trustee in bankruptcy of the person to whom the goods or land belong or the debt is due from becoming entitled to them or it, instead of the judgment creditor who issued the execution or obtained the order of attachment. Numerous decisions had been given under sub-sects. 2 and 3 of sect. 95 of the Act of 1869, which are now more or less embodied in or remedied by the words of sect. 45. At first sight sect. 45 seems to define with sufficient exactness the position of the execution creditor who has issued execution against land or goods, or who has attached debts due to the debtor, though, when that section is put practically to the test, it is found to be, owing to its somewhat general terms, not quite so clear as was expected. The result of the law as enacted by that section is shortly put in Williams on Bankruptcy, as follows: The title of the trustee will prevail over that of an execution creditor, unless the creditor has (1) completed the execution or attachment by seizure and sale in the case of goods, and by seizure or the appointment of a receiver in the case of land, or by the receipt of the debt; (2) completed before the date of the receiving order, and before notice of the presentation of any bankruptcy petition or of the commission of any available act of bankruptcy. We do not propose at present to deal with execution against land or goods, but intend to confine our remarks to the attachment of debts. It will be observed that sect. 45 says that the attachment of a debt must be complete before the date of the receiving order, and before notice of the presentation of any bankruptcy petition by or against the debtor, or of the commission of any available act of bankruptcy by the debtor, otherwise the creditor cannot retain the benefit of his attachment as against the debtor's trustee in bankruptcy. The section then goes on to define how an attachment of a debt is completed, and enacts that: "An attachment of a debt is completed by receipt of the debt." Not by receipt of the money due, but by receipt of the debt. In our unreported decisions (ante, p. 293) will be found a case of Re Trehearne; Ex parte The Chief Official Receiver v. The Local Board of Ealing, where the question as to what is a receipt of a debt within the meaning of sect. 45 was discussed. In April 1889 the debtor Trehearne entered into contracts with the Local Board of Ealing, under which contracts he was entitled to receive certain sums of money. Trehearne had, however, got into debt with one Fardell, and on the 22nd July of the same year Fardell obtained judgment against Trehearne for the sum of £128 19s. 6d. A sum of between £70 and £80 of this debt remained unpaid; so in August Fardell obtained a garnishee order nisi to attach the moneys which were due to his debtor from the Local Board of Ealing. At this time the members of the local board had suspended their sittings for vacation, and accordingly the clerk to the board met Fardell, the judgment creditor, and entered into an arrangement with him with regard to the payment of the money which the board owed to his debtor. By this arrangement the clerk allowed the garnishee order nisi to be made absolute, and on his part undertook that by the 3rd Oct. following the money should be forthcoming, and Fardell on his part agreed not to take any steps for enforcing the garnishee order which he had obtained. It is most probable that under this arrangement every thing would have turned out satisfactory had not a receiving order been made against Trehearne, on which he was adjudicated bankrupt. Notwithstanding that, the Ealing Local Board kept to their arrangement, and after the receiving order had been made paid Fardell the debt which they owed to Trehearne. The trustee in bankruptcy of the debtor, however, stepped in and claimed the money on behalf of the general body of the creditors. Everything depended upon whether or not there had been a receipt of the debt before receiving order by the execution creditor, as if so he was safe. The case of Butler V. Wearing (17 Q. B. Div. 182), which was the authority cited by the trustee in support of his contention that he was entitled to the money, and was followed by Mr. Justice Cave in giving his judgment, goes very fully into the whole question. In that case Wearing recovered judgment against Jackson on the 15th April 1885 for £71. At the date of the judgment Nelson was indebted to Jackson in a sum of about £16. Wearing having obtained ex parte the usual garnisheo order against Nelson in respect of that debt, Jackson's wife intervened as claimant on the ground that Nelson's debt was due to her and not to her husband. The garnishee paid the money into court under an order of the court, and on the 5th May Jackson committed an act of bankruptcy on which a receiving order was made and Jackson adjudicated bankrupt. Mrs. Jackson, finding that she could not support her claim, thereupon withdrew it, and an issue was directed to try whether Wearing or Jackson's trustee was entitled to the money. Most of the authorities on the subject were then referred to, and the late Mr. Justice Manisty having taken time to consider the question, eventually gave judgment in favour of the trustee. In the course of that judgment it was pointed out "that the only equivalent for an actual sale of goods which will satisfy the words of the Act in the case of a garnishee order is an actual receipt of the attached debt by the garnishor"—not a constructive receipt, as when money is paid into court subject to further order. "It was argued that, when the money was paid into court and the garnishee thereby discharged, there was a receipt by that one of the two contending parties in the interpleader issue who ultimately received the money. It was said that the judgment creditor here, having ultimately been proved to be entitled to the money, must be taken by relation back, as it were, to have received the debt within the meaning of the Act, at the time when the money was paid into court." Mr. Justice Manisty came to the conclusion that that was not the meaning of sect. 45, but that there must be an actual receipt, and no constructive receipt would do. Apply this reasoning to the case of Trehearne, and it will be at once admitted that, as no actual receipt of the debt had taken place, the attachment was not completed. It is true the judgment creditor agreed not to enforce his garnishee order when he had obtained the undertaking that the money would be paid, and it might be urged on that, that it was only the actual day of payment that was suspended, and that the debt itself had been received, though the payment was deferred till October. This, however, would necessitate the application of the doctrine of relation back; i.e., that when he actually received payment his title dated back to August when the arrangement to postpone was come to. This doctrine of title by relation, it was expressly stated in Butler v. Wearing, could not be applied. Under these circumstances the conclusion to which Mr. Justice Cave came, was that Trehearne's trustee was entitled to the money, and not Fardell the judgment creditor-probably a perfectly correct conclusion. We feel bound, however, to express our regret that it was not possible to come to a different determination. SPECIFIC PERFORMANCE OF AGREEMENTS BY LETTERS. NUMEROUS decisions have established the fact that an agreement for the sale and purchase of realty, so as to satisfy the requirements of the Statute of Frauds, may be entered into by letters passing from one person to another, when such letters contain all the terms of the bargain. Where there is an offer to sell a specified property at a given price by one party, and a simple acceptance of that offer by the other, no difficulty arises. But where the acceptance is accompanied by some new stipulation, or exception, or where the parties show by subsequent negotiation in the matter that they do not consider the letters to amount to a complete and final agreement, as where both of them afterwards seek to introduce new conditions into the bargain, it then becomes a question whether there is an agreement that can be specifically enforced at the suit of either party. Recent cases on this subject though somewhat difficult to reconcile on some points agree in others; and it appears to be now established by several decisions that the fact that a simple accept ance of an offer contains a statement that the acceptor "has instructed his solicitor to prepare a formal agreement does not render such acceptance a conditional one. If the true and essential ingredients of a contract, as the parties to the bargain, the description of the property and the price to be paid, be clearly stated, then although the contract may not be set forth in the form which a solicitor would adopt if instructed to draw up the agreement in writing, an acceptance by letter will not the less constitute an agreement between the parties merely because the latter may say, "We will have this agreement put in due form by a solicitor:" (see Rossiter v. Miller, 39 L. T. Rep. N. S. 173; 3 App. Cas. 1124; Bolton Partners v. Lambert, 60 L. T. Rep. N. S. 687; 41 Ch. Div. 295, C. A.) And it would seem that the fact that the acceptance concludes with the words "subject to the title being approved by our solicitors," does not make such acceptance a conditional one-these words seemingly meaning nothing more than a guard against the title being accepted without investigation, but that it should be subject to investigation in the usual way: (Hussey v. Horne-Payne, 41 L. T. Rep. N. S. 1; 4 App. Cas. 311.) In the recent case of Bolton Partners v. Lambert (supra), the facts, sufficient for our purpose, were these: After some preliminary vorbal negotiation between the parties, the defendant, on the 8th Dec. 1886, wrote to the plaintiffs offering to take from them a lease of their works for the remainder of the plaintiff's term, at a yearly rent of £3500, payable quarterly, with an allowance of £500 from the first quarter's rent on account of repairs, &c. On the 9th of that month Mr. Scratchley, a director of the company, wrote to the defendant, stating that his offer should be laid before the board; and on the 13th Doc. he again wrote to the defendant, stating that the directors accepted the offer made in his letter of the 8th inst., and added that "the company's solicitors had been instructed to prepare the necessary documents." On the 13th Jan. 1887, however, the defendant wrote to the plaintiffs, alleging that he had discovered that he had been misled as to the value of certain of the plant and machinery on the premises, and added, "I therefore withdraw all offers made to you in any way." In an action by the company seeking specific performance of the alleged agreement contained in the letters of the 8th and 13th Dec. 1886, Mr. Justice Kekewich decided in their favour; and from his judgment the defendant appealed. The Court of Appeal held that these two letters constituted a complete and final contract; that the statement in the letter of Mr. Scratchley of the 13th Dec. 1886, as to the preparation of the necessary documents by the company's solicitors, did not render it a conditional acceptance; and that the letter by the defendant of the 13th Jan. 1887 withdrawing his offer was ineffective as having been made after the contract was complete; and the court confirmed the judgment of Mr. Justice Kekewich. On the other hand it appears to be settled that the court will not grant specific performance of an alleged agreement by letters, when looking at the whole correspondence and the conduct of the parties in continuing negotiations, not on a mere matter of form, but on some substantial question involved, after the offer and acceptance, it appears they did not consider the agreement complete and final. Thus, in Hussey Horne-Payne (supra), after some preliminary verbal negotiations, the defendant, on the 4th Oct. 1876, by letter offered the land in question to the plaintiff for £37,500. The plaintiff's agent on the 6th Oct. wrote in answer accepting the offer, subject to the title being approved by his solicitors. Further negotiations, however, followed by letters passing between the parties and their solicitors and by written memoranda, as to the payment of the amount of the purchase money by instalments, and as to the conveyance of the property as the purchase money was paid, wherein reference was made to the signing of a contract, but no such contract was signed. The plaintiff claimed specific performance of an alleged contract contained in the letters of the 4th and 6th Oct., with a declaration that the terms respecting payment of the purchase money and the conveyance of the property were also binding on the parties. But it was held by the House of Lords, that although the two letters, if they had stood alone, would have been sufficient evidence of a concluded contract under the Statute of Frauds, they must be read in connection with the other correspondence and negotiations, whereby it appeared that there were to be other terms which at that time had not been agreed upon; that efforts were made to settle those other terms, and that such efforts did not result in a settlement thereof, and therefore there was in fact no completed agreement between the parties of which specific performance could be decreed. A recent case to the same effect is that of The Bristol, Cardiff, and Swansea Aerated Bread Company v. Maggs, (62 L. T. Rep. N. S. 416), decided by Kay, J. The facts are briefly these: On the 29th May 1889, the defendant Maggs wrote to the plaintiffs offering to sell his business at Cardiff, lease, and goodwill for £450. Fixtures and fittings and stock-in-trade to be taken at a valuation. The offer to hold good for ten days. On the 1st June following Colonel Guthrie, a director of the company, on behalf and with the authority of the company, wrote stating that he accepted the defendant's offer. On the 2nd June the defendant's solicitor sent to Colonel Guthrie a formal memorandum of agreement, which contained several new terms, for approval. This memorandum was altered by the plaintiffs' solicitors, mainly by the insertion of a clause preventing the vendor for five years from carrying on a like business within Cardiff, or within a distance of five miles from the town hall, and returned the memorandum on the 4th June with an accompanying letter. On the 5th June the defendant's solicitor wrote sending the draft again to the plaintiffs' solicitors with a modification of the proposed additional clause. On the 6th June the plaintiffs' solicitors wrote stating that they could not themselves agree to the proposed modification; but they had asked Colonel Guthrie to call about it. On the 7th June the defendant's solicitor wrote stating that Colonel Guthrie had not called, and by his client's instructions he begged to inform them that his client "declined to proceed further in the matter." In an action by the company for specific performance of the alleged agreement by the two original letters, Mr. Justice Kay held that he was bound to look at the whole corre |