Leonard Plowman (Mr. J. Tharp Plowman, of the firm of Messrs. Winter and Plowman, of London). Alan Knowles Speeden, LL.B. Liverpool (Messrs. Laces and Cɔ., of Liverpool, and Messrs. Sharpe, Pritchard. and Co., of London). George Eric Stevens (Mr. William Stevens, of Brighton). Raymond Melville Thrupp (Mr. George Coleman, of Hove; Mr. Charles Rowe Sawyer, deceased, and Mr. William Westcott Withall, both of London). Frank Trasler (Mr. James Ley Douglass, of Market Harborough). John Westbrook (Mr. Daniel Pennington and Mr. Joseph R. Westbrook, both of Hyde). Thomas Dawkin Windsor Williams (Messrs. Cuthbertson and Powell, of Neath). The council of the Law Society have accordingly given class certificates and awarded the following prizes of books: To Mr. Wallace, the Daniel Reardon Prize, value about £23, and the Clement's-inn Prize, value about £10; to Mr. Tee, the Clifford'sinn Prize, value £5 5s.; to Mr. Peycke, the John Mackrell Prize, value about £9. The council have given class certificates to the candidates in the second and third classes. One hundred and thirty-three candidates gave notice for the examination. CORRESPONDENCE. 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. BANKRUPTCY-COUNTY COURTS.-I have read the articles on pp. 86, 212, and 277 of your journal with reference to part payment of a judgment depriving the creditor of the right to issue a bankruptcy notice, and rule 13 of Order XXIII. is spoken of as giving defendant liberty to pay into court a part of what is due under a judgment. It does not appear to me that this rule is intended or states that the effect is to give any such liberty, but simply provides that where a payment of any instalment of over 10s. has been made the registrar must give notice of it. In by far the largest number of judgments obtained in the County Court the judgment itself is for payment by instalments, but it is only in cases where there is a direct order for payment by instalments that the defendant has power or liberty to do so. FRANCIS S. WHITE. LEGAL OBITUARY. Mr. ABEL THOMAS, K.C., M.P., died suddenly on Tuesday from heart failure at his hotel at Swansea, where he was attending the Glamorgan Assizes. Mr. Thomas was born in 1848, a son of the Rev. Theophilus Evan Thomas, of Trehele, Pembrokeshire, Baptist minister. He was educated at Clifton, and took the degree of B.A. at London University. He was called by the Middle Temple in 1873 and joined the South Wales Circuit, took silk in 1891, and became a Bencher of his Inn in 1900. He was a magistrate for Pembrokeshire for many years, and was elected Chairman of Quarter Sessions. He took a prominent part in the "tithe war "" in South Wales twenty years ago. E Mr. JOHN JAMES WATERWORTH, solicitor, of the firm of Waterworth and Son, Keighley, died at his house in Keighley on the 14th inst., aged sixty-nine. Mr. Waterworth was the son of Mr. Thomas Waterworth, and was for many years identified with a practice which was the oldest in the town and which was started early last century by the late Mr. Christopher Nether wood, of Cliffe Hall. He was admitted in 1865. He was rarely seen in litigious cases in the courts, but he had a large practice, especially in conveyancing. He was a commissioner for oaths, B was deputy registrar of the Keighley County Court, and hee was joint solicitor to the Governors of the Drake and Tonson Foundation and the Silsden Building Society. Some eight years ago he was placed on the Commission of the Peace for the borough, being one of the earliest solicitors to be appointed & magistrate. He married a daughter of the late Mr. H. B. Clarke, a London solicitor, who survives him. Mr. Waterworth was a member of the Law Society and of the Solicitors' Benevolent Association. THE COURTS AND COURT PAPERS. HIGH COURT OF JUSTICE.-LONG VACATION NOTICE. DURING the Vacation up to and including Wednesday, the 4th Sept., all applications "which may require to be immediately or promptly heard," are to be made to the Hon. Mr. Justice Bankes. of COURT BUSINESS.-The Hon. Mr. Justice Bankes will, until further notice, sit in the Lord Chief Justice's Court, Royal Courts of Justice, at 10.30 a.m. on Thursday in every week, commencing on Thursday, the 8th Aug., for the purpose hearing such applications of the above nature as, according to the practice in the Chancery Division, are usually heard in court. No case will be placed in the judge's paper unless leave has been previously obtained, or a certificate of counsel that the case requires to be immediately or promptly heard, and stating concisely the reasons, is left with the papers. The necessary papers, relating to every application made to the Vacation judges (see notice below as to judges' papers), are to be left with the cause clerk in attendance, Chancery Registrars' Office, Room 136, Royal Courts of Justice, before one o'clock two days previous to the day on which the application is intended to be made. When the cause clerk is not in attendance they may be left at Room 136, under cover, addressed to him, and marked outside Chancery Vacation papers, or they may be sent by post, but in either case so as to be received by the time aforesaid. 66 URGENT MATTERS WHEN JUDGE NOT PRESENT IN COURT OR CHAMBERS.-Application may be made in any case of urgency to the judge, personally (if necessary), or by post or rail, prepaid, accompanied by the brief of counsel, office copies of the affidavits in support of the application, and also by a minute, on a separate sheet of paper, signed by counsel, of the order he may consider the applicant entitled to, and also an envelope, sufficiently stamped, capable of receiving the papers, addressed as follows: Chancery Official Letter: To the Registrar in Vacation, Chancery Regis trars' Office, Royal Courts of Justice, London, W.C." On appli cations for injunctions, in addition to the above, a copy of the writ and a certificate of writ issued must also be sent. The papers sent to the judge will be returned to the registrar. The address of the judge for the time being acting as Vacation judge can be obtained on application at Room 136, Royal Courts of Justice. CHANCERY CHAMBER BUSINESS.-The chambers of Justices Swinfen Eady and Neville will be open for Vacation business on Tuesday, Wednesday, Thursday, and Friday in each week, from ten to two o'clock. KING'S BENCH CHAMBER BUSINESS.-The Hon. Mr. Justice Bankes will, until further notice, sit for the disposal of King's Bench business in Judge's Chambers at 10.30 a.m. on Wednesday in every week, commencing on Wednesday, the 7th Aug. PROBATE AND DIVORCE.-Summonses will be heard by the registrar at the Principal Probate Registry, Somerset House, every day during the Vacation at 11.30 (Saturdays excepted). Motions will be heard by the registrar on Wednesdays, the 14th and 28th Aug., the 11th and 25th Sept., at the Principal Probate ah Registry, at 12.30. Decrees will be made absolute on Wednesdays, the 14th and 21st Aug., the 4th and 18th Sept., and the 2nd Oct. All papers for motions and for making decrees absolute are to be left at the Contentious Department, Somerset House, before two o'clock on the preceding Friday. The offices of the Probate and Divorce Registries will be opened at eleven and Cclosed at three o'clock, except on Saturdays, when the offices will Ebe opened at ten and closed at one o'clock. JUDGE'S PAPERS FOR USE IN COURT.-CHANCERY DIVISION. -The following papers for the Vacation judge are required to be left with the cause clerk in attendance at the Chancery Registhe trars' Office, Room 136, Royal Courts of Justice, on or before Ke one o'clock, two days previous to the day on which the application was the to the judge is intended to be made: 1. Counsel's certificate of dent urgency or note of special leave granted by the judge. 2. Two nd the copies of writ and two copies of pleadings (if any), and any other op documents showing the nature of the application. 3. Two copies He of notice of motion. 4. Office copy affidavits in support, and also large affidavits in answer (if any). ner N.B.-Solicitors are requested, when the application has been Cour disposed of, to apply at nce to the judge's clerk in court for the e and return of their papers. me e Chancery Registrars' Office, Royal Courts of Justice, Peacef e app July 1912. To surrender at the High Court of Justice, in Bankruptcy. ATKINSON, HUGH C., Half Moon-st, Piccadilly, retired captain in the army. July 16. BENNETT, HANNAFORD (trading as Bennett and Co), Henrietta-st, Covent Garden, publisher. July 15. TCONSTABLE, CLIFFORD EDWARD, late Carlyle-mansions, Cheyne-walk, Chelsea, gentleman. July 16. se of the a may o tly stu EDELSTEN, WILLIAM, Brixton-rd, Brixton, variety agent. July 16. MCCARTHY, EDWARD ADYE, Whitefriars-st, journalist. July 16. To surrender at their respective District Courts. BISHOP, WILLIAM, Middlesbrough, fruiterer. Ct. Middlesbrough. July 17. cer BUORMAN, JOSEPH (trading as William Boorman). Westhoughton, grocer. Ct. Bolton. July 15. BRANSBY, FRANK RANSOME DUNFORD, Mumbles, tea merchant. Ct. Swansea. July 15. сорга BRIGHT, JONATHAN JASPER, Wellington, contractor. Ct. Shrewsbury. July 15. BROWN, JOHN, Devizes, bootmaker. Ct. Bath. July 15 BROWN, SETH, Oswestry, licensed victualler. Ct. Wrexham and Llangollen. July 12. BURNS, ALFRED, East Greenwich, jeweller. Ct. Greenwich. July 16. CLARKE, ALFRED EDWIN, Bristol, commission agent. Ct. Bristol. July 15. of COLEMAN, GEORGE, FREDERIC, Nantwich, cycle agent. Ct Nantwich and Crewe. July 13. COLES, HERBERT, Stain forth, fish dealer. Ct. Sheffield. July 15. CROWTHER, ALBERT, Leeds, commission agent. Ct. Leeds July 16. CURTIS, LAWRENCE, Middlesbrough, grocer. Ct. Middlesbrough. July 16. DEWEY, WILLIAM, and DEWEY, LLEWELLYN GEORGE (trading as Dewey and Son), Portsmouth, hardware merchants. Ct. Portsmouth. July 15. DREW, ANN NEWNHAM, Stourport, confectioner, spinster. Ct. Kidderminster. July 16. EVANS, HENRY (trading as H. Evans and Co.). Worcester, oil dealer. Ct. Worcester. July 16. FIELD, WALTER, Hastings, superintendent of the Hastings Borough Cemetery. Ct. Hastings. July 16. FIELDEN, EDMUND, Littleborough, print works labourer. Ct. Rochdale. July 17. GARDNER, THOMAS, Southampton, corn merchant's assistant. Ct. Southampton. July 15. GOOCH, FREDERICK CHARLES, late Henley, insurance broker. Ct. Windeor. HEYWOOD, ERNEST WILLIAM, Nantwich, painter. Ct. Nantwich and HOCHMAN, ISADORE (trading as the London Cheap Stores), Middlesbrough, hosier. Ct. Middlesbrough July 15. KELLY, JOHN, Burnley, grocer. Ct. Burnley. July 13. LANGLEY, FRANK, Rugby, theatre proprietor. Ct. Coventry. July 13. SHIRT, JAMES, Buxton, coach builder. Ct. Stockport. July 15. WAY, FREDERIC EDWARD, Trowbridge, agent. Ct. Bath. July 15. WINWOOD, HENRY JOHN, Worcester, carting agent. Ct. Worcester. YAXLEY, ERNEST EDWARD, Norwich, draper. Ct. Norwich GAZETTE, JULY 23. July 15. To surrender at the High Court of Justice, in Bankruptcy. CROWDER, J., Charing Cross-rd, financial agent. July 19. FITCH, JOHN OSBORNE, F'enchurch-st, manufacturers' agent. July 19. FULLER, FREDERICK JAMES, late Grove-la, Camberwell, licensed victualler. July 19. HEWSON, GILBERT, Bond-ct, Walbrook. July 19. JAY, MOSS, Kingsway, entertainment caterer. July 19. TAYLEUR, LIEUTENANT C. E., late Curragh Camp, Ireland, officer in the TYLER, GEORGE E., late Cambridge-st, Paddington, articled clerk to a solicitor. July 18. WEATHERLEY, WALTER, late Anatola-rd, Upper Holloway, general cartage contractor. July 19. ARTHUR WILLIAMS AND CO., Queen Victoria-st, bankers. July 18. To surrender at their respective District Courts. BERRY, WILLIAM, Plymouth, corn merchant. Ct. Plymouth. July 18. COLE, GEORGE JAMES, Poole, hairdresser. Ct. Poole. July 19. HARCOURT, ALFRED HENRY, Mansfield, jeweller. Ct. Nottingham. July 20. NUTTALL, HENRY, Leigh, hardware dealer. Ct. Bolton. July 19. PEACOCK, CHARLES MATTEN, late Reading, tobacconist. Ct. Maidstone. RUSSELL, ROBERT, Sheffield, draper. Ct. Sheffield. July 20. ST. QUINTIN, ERNEST CHARLES, Norwich, journeyman brush maker. Ct. Norwich. July_20. SIMMONS, SIDNEY WILFRED, Northfleet, baker. Ct. Rochester. July 19. STRIDE, CHARLES, late Chichester, auctioneer. Ct. Brighton. July 22. BENNETT, JOSEPH HANNAFORD (trading as Bennett and Co., described in the receiving order as Hannaford Bennett), Henrietta-st, Covent Garden, publisher Ct. High Court July 17. BIGGS, SAMUEL THOMAS (late practising as Biggs, Roche, and Co.),. Lincoln's-inn-fids, solicitor. Ct. High Court. July 16. BISHOP, WILLIAM, Middlesbrough, fruiterer. Ct. Middlesbrough. July 17. BOORMAN, JOSEPH (trading as William Boorman), Westhoughton, grocer. Ct. Bolton. July 15. BRANSBY, FRANK RANSOME DUNFORD, Mumbles, tea merchant. Ct. Swansea. July 15. BRIGHT, JONATHAN JASPER, Wellington, contractor. Ct. Shrewsbury. July 17. BROWN, SETH, Oswestry, licensed victualler. Ct. Wrexham and Llangollen. July 12. CLARKE, ALFRED EDWIN, Bristol, commission agent. Ct. Bristol. July 15. COOKSON, ERNEST EDWARD SAUREY, Richmond. Ct. High Court (transferred from the County Court of Yorkshire, holden at Northallerton). July 17. COLEMAN, GEORGE FREDERIC, Nantwich, cycle agent. Ct. Nantwich and COLES, HERBERT, Stain forth, fish dealer. Ct. Sheffield. July 15. DAVIS, JOHN, Eastbourne. Ct. Eastbourne and Lewes. July 15. EVANS, HENRY (trading as H. Evans and Co.), Worcester, oil dealer. Ct. FIELDEN, EDMUND, Littleborough, print works labourer. Ct. Rochdale. July 17. GARDNER, THOMAS, Southampton, corn merchant's assistant. Ct. Southampton, July 15. GRAHAM, THOMAS JOSEPH (described in the receiving order as Thomas Gráham), Bute-st, South Kensington. Ct. High Court. July 16. GRAY, JOHN ELTON, Hucclecote, publican. Ct. Gloucester. July 16. GRIFFITHS, WILLIAM ROBERT, Blaenau Festiniog, quarryman. Ct. Portmadoc and Festiniog. July 16. HEYWOOD, ERNEST WILLIAM, Nantwich, painter. Ct. Nantwich and Crewe. July 13. HOCHMAN, ISADORE (trading as the London Cheap Stores), Middlesbrough, hosier. Ct. Middlesbrough. July 15. HOLDCROFT, ELLEN, Hanley, confectioner. Ct. Hanley. July 17. MCCARTHY, EDWARD ADYE, Whitefriars-st, journalist. Ct. High Court. MEE, WILLIAM EDWARD, Nottingham, watchmaker. July 16. POYNTER, CLAUDE KIBBLE, Ealing, retired bank clerk. July 5. Ct. Nottingham. Ct. Brentford. RADFORD, MAURICE, Nottingham, fishmonger Ct. Nottingham. July 17. REGAN, JOHN, Ondine-rd, East Dulwich. Ct. High Court. July 16. RUTTER, WILLIAM CAMPION, Middlesbrough, late general credit salesman. Ct. Middlesbrough. July 15. SHAND, EDGAR, East Dulwich-rd. Ct High Court. July 16. WEBSTER, ROBERT, Wallasey, coal merchant. Ct. Birkenhead. July 15. July 17. YAXLEY, ERNEST EDWARD, Norwioh, draper. Ct. Norwich. July 15. GAZETTE, JULY 23. BERRY, WILLIAM, Plymouth, corn merchant. Ct. Plymouth. July 18. BLAKELOCK, WILLIAM LISLE, Stockton-on-Tees, wholesale druggist. Ct. Stockton-on-Tees. July 19. BROWN, JOHN, Devizes, bootmaker. Ct. Bath. July 19 COLE, GEORGE JAMES, Poole, hairdresser. Ct. Poole. July 19. DUNPHY, JAMES C., Bulford, army chaplain. Ct. Salisbury. July 20. GILBERT, FRANK, and GILBERT, THOMAS, late Accrington, builders. Ct. Blackburn and Darwen. July 18. GOLDING, ERNEST EDWARD, late Bures Saint Mary, innkeeper. Ct. Colchester. July 20. HARCOURT, ALFRED HENRY, Mansfield, jeweller. Ct. Nottingham. July 20. NUTTALL, HENRY, Leigh, hardware dealer. Ct. Bolton. July 19. REYNOLDS, VINCENT, Aldridge, late farmer. Ct. Walsall July 19. RUSSELL, ROBERT, Sheffield, draper. Ct. Sheffield. July 20. ST. QUINTIN, ERNEST CHARLES, Norwich,, journeyman brush maker. Ct. SARJEANT, WALTER FERMOR (described in the receiving order as Walter SUSSEX, WILLIAM, Rockbeare, cattle dealer. Ct. Exeter. July 18. TWEED, HUBERT STILLFRIED, Gordon-mansions, Francis-st, broker. High Court. July 18. Ct. VINE, LOUIS HOOPER, Purley. Ct. Croydon. July 19. WAY, FREDERIC EDWARD, Trowbridge, agent. Ct. Bath. July 20. WEATHERLEY, WALTER. late Anatola-rd, Upper Holloway, general cartage contractor. Ct. High Court. July 19. LICENSES INSURANCE CORPORATION AND GUARANTEE FUND LIMITED. Messrs. Butterworth and Co. BUTTERWORTH & CO., BELL YARD, TEMPLE BAR, LONDON. To Readers and Correspondents. All communications must be authenticated by the name and address of the writer, not necessarily for publication, but as a guarantee of good faith. Anonymous communications are invariably rejected. All communications intended for the Editorial Department should, in order to prevent delay, be addressed to the "EDITOR OF THE LAW TIMES.' Any contributions that may be sent on approval will be carefully considered by the Editor; but no responsibility whatever can be accepted in respect thereof, although, if unsuitable, every effort will be made to return them, provided that a stamped addressed wrapper is inclosed for that purpose. The copyright of all contributions (including reports paid for) shall belong to the proprietors of the LAW TIMES, together with the right of republication in any form they may think desirable. Apart from any express agreement that may be made, contributions are only received and considered on these conditions. Advertisements, orders for papers, &c., should be kept distinct, and addressed to the Publisher, Mr. HORACE Cox, "Law Times" Office, Windsor House, Bream's-buildings, E.C. TO SUBSCRIBERS.-PREPAYMENT TERMS OF SUBSCRIPTION. United Kingdom. WITHOUT REPORTS. £2 14 0 For One Year 7 0 For Half-Year Foreign. For Half-Year WITH REPORTS. For One Year .£3 0 WITHOUT REPORTS. 0 For One Year 1 10 0 For Half-Year For Half-Year £2 2 0 1 1 0 £2 4 4 1 2 2 Portfolios for preserving the current numbers of the LAW TIMES, price Each additional line 3 6 One column 6 10 0 0 5 0 0 3 10 0 Advertisements ordered for a series of three insertions are charged 10 per cent. under scale, and for six or more insertions 20 per cent. under. Paragraph Advertisements 1s. per line, minimum 58. No series discount. 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. Vol. 133.-No. 3618. PRINTZ (app.). v. SEWELL (resp.).— Motor-car-Use on highway at night-Unlighted lamp.... KING'S BENCH DIVISION, IN BANK- Re TEALE; Ex parte BLACKBURN.— Cooper Wallis, K.C.-Mr. Herbert Baring Garrod-Mr. Edward Sharman Giles COURT PAPERS. Rules of the Supreme Court-Long Vacation Notice 310 340 THE GAZETTES........................................................................ 341 BIRTHS, MARRIAGES, and DeathHS 342 ... The Law and the Lawyers. The Additional Judges. Ar the time of going to press, no announcement has been made as to the intention of the Government with regard to the appointment of additional judges in the King's Bench Division. Not for some years past has the Long Vacation been entered upon with so many actions awaiting trial, and the only way in which the existing position can be remedied is by the appointment of two additional judges to take up their duties immediately upon the commencement of next sittings. Many rumours, doubtless without foundation, are current as to who will be selected to fill these posts should Parliament give the necessary authority; but one hopes that Lord HALDANE, like his predecessor Lord LOREBURN, will disregard all political and private personal claims, and will make his selection solely on the ground of professional fitness. The "Titanic" Report. LORD MERSEY'S report on the loss of the Titanic is entirely what the Profession expected it to be-practical, judicial, and impartial. The court finds that the loss of the ship was due to collision with an iceberg, brought about by the excessive speed at which she was being navigated, and, although in some quarters exception is taken to the form of the finding and it is suggested that speed was not the only factor that brought about the disaster, it is abundantly clear that it was the chief determining cause. Praise is accorded where due, and Lord MERSEY is not sparing in censure when such is deserved; while certain unfounded aspersions that during the inquiry were cast on certain persons are described as unfounded. It is not surprising that the failure of the Board of Trade to revise their rules should be the subject of adverse criticism at the hands of the commissioner, while his recommendations with regard to boat drill, look-outs, and wireless telegraphy will commend themselves to everybody. The recommendation also that an international conference should be called to consider and, as far as possible, to agree upon a common line of conduct upon the main questions raised in this inquiry is a good one, and might do much to assist in reducing some of the dangers which exist as regards ships at sea. Canadian Marriages. A STRONG board of the Judicial Committee of the Privy Council has now finally determined the difficult question that has arisen, with regard to marriages in Canada, as to the respective powers of the Federal and Provincial Legislatures. Under sect. 91 of the British North America Act 1867, the Dominion Parliament may make laws in relation to all matters not coming within the classes of subjects by the Act assigned exclusively to the Provincial Legislatures, and it declares that the exclusive legislative authority of the Dominion Parliament extends (inter alia) to marriage and divorce. By sect. 92, however, Provincial Legislatures may exclusively make laws as to the solemnisation of marriage in the province. It has now been held that the jurisdiction of the Dominion Parliament, on the true construction of those sections, does not cover the whole field of validity, and that under sect. 92 the power conferred on the Provincial Legislatures operates by way of exception to the powers conferred as to marriage by sect. 91, and enables them to enact conditions as to solemnisation which may affect the validity of the contract. The effect of this decision is to uphold the conclusions arrived at by the Supreme Court of Canada, and doubtless it will be sought to obtain an amendment of the Act of 1867 to enable the Dominion Parliament to pass a uniform marriage law throughout the Dominion. Where religious questions are concerned, it is always a matter of great difficulty to frame an enactment that shall be fair and just to all, but, at the same time, the supreme authority in matters of marriage and divorce must be. the entire State, and the interference by any particular Church cannot be tolerated. The County Courts and the Franchise. SHOULD the Franchise Bill become law, another onerous duty will be imposed upon the already overburdened County Courts, for, in addition to their existing duties, County Court judges, on the abolition of the revising barristers, will every year have to revise the electoral lists of their districts. We presume it is considered that, if the Bill is placed on the statute-book, registration will become a matter of such simplicity that hardly any disputes as to the lists will arise for determination. A very good specimen of the type of legislation designed to do away with all forms of litigation is the Workmen's Compensation Act, which the public were informed could be administered with practically no recourse to the courts. As our readers are aware, few statutes have given rise to more lit gation, and we have no doubt whatever that the Franchise Bill will give as much work to the County Court judges, as the present system has given the revising barristers in the past duties which have been excellently performed by them, Should clause 1 of the County Courts Bill and the Franchise Bill be passed into law by the end of this year, the position of the small litigant in the County Court will be absolutely hopeless. "Manual Labour." THE first questions as to what constitutes manual labour under the National Insurance Act were raised this week before Mr. Justice SWINFEN EADY, the learned judge holding that a dairyman's foreman and a tailor's cutter did not exercise manual labour. It is clear that employment may involve considerable physical labour and yet the person exercising it may not be employed in manual labour. Where physical exertion is incidental to the employment and not the substantial object of it, the persons so employed are not engaged in manual labour. There have been numerous cases under the Employers and Workmen Act, the Employers' Liability Act, and the Workmen's Compensation Act, and under those statutes omnibus conductors, tram drivers and conductors, railway guards, and grocers' assistants have been held not to be employed in manual labour. On the other hand, the driver of a motor omnibus has been held to be engaged in manual labour as part of his work was on the car itself. The whole question is really one of degree, but none the less in many cases is difficult of solution. PRIVATE LETTERS. If the ordinary private letter were exactly on a par with the chattel which passes at common law by delivery, the recipient of the letter would, on his receiving it, become the absolute owner thereof, and would be able to exercise an absolute dominion' over it; but although, as has been decided by the case of Perceval v. Phibbs (1813, 2 V. & B. 19), the writer of a letter, in sending it, makes a gift to his correspondent of the actual paper on which the letter is written, yet the real value in the letter is certainly not the substance of the paper on which the letter is written, but the right to make use of the words which are to be found thereupon. It is quite obvious when a person writes a letter about his business, or what are more strictly his private affairs, that his intention is that the addressee should be entitled to use the letter for some purposes, but not all, and he has no wish whatever to place in the hands of the person, to whom he has written, the right capriciously to make use of the letters to his own (the writer's) disadvantage; and therefore, although there does not seem to be any authority for saying that the author of the letters has an absolute and unqualified right of copyright in the letters himself, the law has given him certain powers over the publication of his letters which are intended to enable him to prevent any abuse of the confidence which he has reposed in his correspondent, and accordingly it has restricted the absolute powers of the latter over them. To attempt to define the meaning of the word "publication is a little difficult; merely to say that it means the making public of the letters seems somewhat unsatisfactory, yet that is what it really comes to. Printing the letters and making copies of them of course may come within that description, and so may reading them aloud, provided that all these acts are done in public; but none of these proceedings would seem to be included unless the method in which they are done is a public one, according to the learned editor of Copinger on Copyright, p. 53. It would certainly seem to be the case that an ordinary letter might be read aloud to the members of the family of both the recipient and the sender, and of course this is frequently done, and there seems no reason why the recipient might not show it to his friends, yet it is conceived that in order to bring about a publi cation of the letter it is not necessary to publish it indiscrimi nately to the whole and entire public-even of a locality-and obviously some letters might be shown round more freely than |