keep themselves free from the influence of the Roman law in their family relations. 3. The adoption is permanent, yet the adoptive father can by emancipation, and the adopted son at a later period, dissolve the relationship on the same conditions under which the patria potestas can be dissolved on other occasions. But in the case of Adrogation, when the adoptive father emancipates or disinherits the adopted son without good reason, he must surrender not only all the property which the adopted son has brought and in the mean time acquired, but he must also leave him the fourth part of his own property (quarta Divi Pii). When an ancestor gives his own naturalborn children and other descendants in adoption, as a general rule the full effects of adoption (adoptio plena) only take place when the adoptive father is an ancestor; otherwise the adoption had only a minor effect (adoptio minus plena), namely, the capacity to inherit from the adoptive father in case of intestacy. (Article, by Welcker, in the Staats-Lexicon of Rotteck and Welcker.) This account is sufficient to give a general view of the form and effects of adoption in Germany : but the account is deficient in precision. The German law of adoption is founded on the Roman, as will be obvious by comparing the German with the Roman

tion must not be disadvantageous to
them. As the act of adoption is an imita-
tion of the natural relation of parent and
child, and intended to supply its defi-
ciencies, the adopter must be at least
eighteen years older than the person to be
adopted, and for the same reason he must
not have been intentionally castrated.
The guardian cannot adopt his ward be-
fore he has accounted for his guardian-
ship; and as a general rule a poor man
cannot adopt a rich man. The adopter
must have attained a considerable (it is
not said what) age, or for other reasons
have no hopes of children of his own. The
transaction must take place before the
competent jurisdiction, and in the case of
the adrogation or adoption of women, the
approbation of the prince is required. It
is also necessary to have the consent of
the parents and other ancestors who have
hitherto had the child in their power, and
as such would for the future be entitled to
the same right; and also the consent of the
child to be adopted. In the case of Adro-
gation, when the person to be adopted is
a minor, there must also be an inquiry
whether the adrogation is advantageous
to him; the consent of the next of kin
and guardians of the person to be adro-
gated, and security on the part of the ad-
rogator, that in case the child dies in his
minority, he shall transfer the property to
the nearest kinsman, or to a person sub-system.
stituted by the natural father.

The effects of adoption are: 1. In the case of adoption by a man, he acquires the patria potestas over the adopted son and the children of the adopted son, so far as they are in his power. 2. The adopted son acquires all the rights of a natural-born son, and among them the capacity to inherit. He also takes the family name of the adoptive father, which, however, in Germany, he only adds to his old family name. In the case of adoption by a man, he also becomes the Agnate of all the Agnati of the adoptive father, and all his previous relationships of Agnation cease. But no alteration is produced in the relationship of Cognation. Adoption, however, in respect of nobility and the succession to fief and family property, has no effect; a rule which had no other foundation than the wish of the nobility to

There are variations in the several German states. The Prussian law does away with all distinction between adoption and adrogation, and allows the adopted son who is of age to manage his own property. The Austrian law does the same. Both also agree in requiring the age of the adoptive father to be fifty at least. The Prussian law, with respect to the adopted son, merely requires him to be younger than the father; the Austrian code requires him to be eighteen years younger than the adoptive father. (Ersch and Gruber's Encyclopädie, art. Adoption.")

66

The French law of adoption is contained in the eighth title of the first book of the Code Civil. The following are its principal provisions:-Adoption is only permitted to persons above the age of fifty, having neither children nor other legiti mate descendants, and being at least fifteen

D

years older than the individual adopted. | It can only be exercised in favour of one who has been an object of the adopter's constant care for at least six years during minority, or of one who has saved the life of the adopter in battle, from fire, or from drowning. In the latter case, the only restriction respecting the age of the parties is, that the adopter shall be older than the adopted, and shall have attained his majority, or his twenty-first year; and if married, that his wife is a consenting party. In every case the party adopted must be of the age of twentyone. The form is for the two parties to present themselves before the justice of the peace (juge de paix) for the place where the adopter resides, and in his presence to pass an act of mutual consent; after which the transaction, before being accounted valid, must be approved of by the tribunal of first instance within whose jurisdiction the domicile of the adopter is. The adopted takes the name of the adopter in addition to his own; and no marriage can take place between the adopter and either the adopted or his descendants, or between two adopted children of the same individual, or between the adopted and any child who may be afterwards born to the adopter, or between the one party and the wife of the other. The adopted acquires no right of succession to the property of any relations of the adopter; but in regard to the property of the adopter himself, it is declared that he shall have precisely the same rights with a child born in wedlock, even although there should be other children born in wedlock after his adoption. It has been decided in the French courts that aliens cannot be adopted.

The law of the Franks allowed a man who had no children to adopt the children of others; the adoption was effected by a transfer of the adopter's property to the person adopted; with a reservation of the usufruct thereof to the adoptive father for his life. The adoption was a solemn act, which took place before the king or other competent authority. The old law of Aragon allowed a man to adopt a son, though he had sons of his own, and the adopted son was on the same footing as a son of a man's body with respect to

right to the inheritance and liability fo the debts of his deceased parent. Th in fact is the Roman law. (Du Cang Gloss. ad Script. Med. et Infim. Latin tatis, "Adoptio Filiorum.”)

Adoption is still practised both amon the Turks and among other Eastern n: tions. It is common for a rich Tur who has no children of his own, to adop as his heir the child of persons even the poorest class. The bargain is ratifie by the parties going together before th Cadi, and getting their mutual conser recorded; after which the child cann be disinherited by his adoptive fathe D'Herbelot states that, according to th law of Mohammed, a person becomes th adopted son of another by undergoing th ceremony of passing through his shirt whence the expression, to draw anothe through one's shirt, signifies to adopt hi for a son. In India the same thing i said to be frequently done by the tw parties merely exchanging girdles. I the Code of Gentoo Laws published b Mr. Halhed, the 9th section of the 211 chapter is entitled Of Adoption.' Th law permits a child under five years age to be given up for adoption by th father for a payment of gold or rice, i he have other sons, on the parties going before a magistrate and having a jugg, o sacrifice, performed. A woman, however it is added, may not adopt a child with out having her husband's consent; and there is even some doubt if she may with that. "He," concludes the law," whe has no son, or grandson, or grandson's son, or brother's son, shall" (may?) "adopt a son; and while he has one adopted son, he shall not adopt a second."

There is no Adoption in the English or Scotch systems of Law.

The practice of adoption, when properly regulated, appears to be a useful institution. The existence of families is necessary to the conservation of a state; and there seems to be no good reason why those who have no children of their own should not by adoption add to their own comfort while they confer a benefit on others. The practice, however, may be less applicable to some states of society than to others, and before such an insti tution is established anew in any country,

the whole of the reasons on which it was originally founded in the law of Athens and Rome should be well considered.

progress of the pupils, and their improved conduct and character, caused the establishment of other adult-schools throughout Wales.

About the same time, and without any concert or connection with the schools in Wales, a school was established at Bristol, through the instrumentality of W. Smith. This person, "who collected the learners, engaged the teachers, and opened the two first schools in England for instructing adults exclusively, in borrowed rooms, and with borrowed books,”* was the door-keeper to a dissenting chapel. He devoted three out of eighteen shillings, his weekly earnings, to defray the expense of giving to his brethren the means of studying the Scriptures, and of obtaining knowledge from other sources. A short time after these first efforts were made, a Society was formed for the fur

ADULT-SCHOOLS are establishments for instructing in reading and other branches of knowledge those persons who have not been educated in their youth. Thirty or forty years since, there were numerous schools for adult instruction in reading and writing; but at the present time, and for some years past, the efforts of the friends of education have been directed entirely to the education of the young; and the necessity of schools for adults is probably not so great now as at the period when they were first established. There are a few schools for adults in the colliery districts in the north of England. When the Statistical Society instituted an inquiry into the state of education in Westminster, there was only one adult-school. But there are adult-therance of his benevolent views. In the schools in other parts of London, both for young men and young women, in which reading, writing, and arithmetic are taught. Mechanics' Institutes may be considered as adult-schools for instruction in various branches of knowledge.

The number of adults who are incapable of writing is still very large. In the three years ending 30th of June, 1841, the proportion for England and Wales of persons who signed their marriage register with their marks was 33 per cent. of the men, and 49 per cent. of the women: in Hertfordshire, Bedfordshire, and Monmouthshire, the proportion for the men exceeded 50 per cent., and in several counties it exceeded 60 for the women; and for North Wales it was 70 per cent. This test shows the state of education ten or twenty years ago; and for the last of the three years there was a slight increase of those who wrote their names.

The first school avowedly established for the purpose of instructing adults was formed in 1811, through the exertions of the Rev. T. Charles, a clergyman in Merionethshire. Some grown-up persons had previously attended his parish Sunday-school, but they showed a disinclination to learn with children, and this circumstance led to the adoption of more extended views for their benefit. Considerable success, both in the number and

first Report of this Society, dated April, 1813, it was stated that 222 men and 231 woman were already receiving education. Adult-schools were soon afterwards established in different parts of the kingdom, at Uxbridge, Norwich, Ipswich, Sheffield, Salisbury, Plymouth, and other places. Many instances occurred of persons acquiring the art of reading in old age, who gladly availed themselves, in the last few months of their existence, of the means afforded them of reading for themselves the hopes and promises held out by the Scriptures.

The following are the particulars respecting an experiment in adult education tried with success by Dr. Johnstone, at Edgbaston Hall, near Birmingham. This school was established about 1815; and the only expense incurred by the individual with whom the plan originated, was that of providing a room once a week, with fire and candle. It was soon attended by forty members-more than half the labouring population of the parish-of all ages from eighteen to seventy. teaching was confined to reading and writing; and the men taught each other. The school assembled once a week, on Sunday evening, for two hours; but the men often studied their lessons at home

The

* Pole's History and Origin of Adult-Schools.