to him by Mrs. B. he had consented to become responsible for anything which occurred at the home. Held, that the deciding point in the case was whether the evidence given at the trial with the object of showing that the appellant had undertaken a legal duty towards the inmates of the home was sufficient to support the verdict of the jury; that no fault could be found with the summing up of the learned judge; that the evidence given before the coroner, which was not produced at the trial, showed that the appellant had not personally assumed control over the maintenance and health of the inmates of the home; that the court would exercise their powers under sect. 4 of the Criminal Appeal Act 1907; and that the verdict must be set aside and the appeal allowed. [Rex v. Hall. Ct. Crim. App.: Lord Reading, C.J., Avory and Roche, JJ. July 1.-Counsel: for the appellant, Sir Edward Marshall Hall, K.C., Eustace Fulton, and H. R. Pigeon, instructed by Goldberg and Barrett; for the Crown, Travers, Humphreys and Roland Oliver, instructed by the Director of Public Prosecutions.] Durham, Tuesday (R. By) Glossop, Wednesday, at 10 Grays Thurrock, Wednesday, at 11 Halifax, Tuesday, Thursday, and Thursday (By at 10.30), and Friday (J.S.), at 10 Kingston-on-Thames, Tuesday Leyburn, Monday, at 10.30 Llanelly, Monday and Friday 11 Tuesday, Marylebone, Monday, Tuesday, Wednesday, Thursday, and Friday, at 10.30 Matlock, Monday, at 10 Neath, Wednesday and Thursday Nuneaton, Friday, at 10 (By) and Presteign, Friday, at 2 St Austell, Monday, at 10 Seaham Harbour, Monday, at 9.80 Sheffield, Thursday (By at 2) and Shoreditch, Tuesday and Thursday South Shields, Thursday, at 10 Spalding, Wednesday, at 10 Stockton-on-Tees," 9.30 Tuesday, Stoke, Wednesday, at 9.30 Stratford-on-Avon, Monday, at 10 at Swansea, Monday, Tuesday, and Wednesday Swindon, Wednesday, at 10.30 Temple Cloud, Saturday, at 10.30 Todmorden, Wednesday Trowbridge, Friday, at 10.15 Uttoxeter, Friday, at 10 Wakefield, Tuesday, at 10 Waltham Abbey, Saturday, at 11 Wellington (Salop), Wednesday, at 10 West Hartlepool. Friday, at 9.30 Westminster, Monday, Tuesday, Wednesday, Thursday, and Friday Whitechapel, Wednesday and Friday Whitehaven, Wednesday, at 9.30 Wigan, Tuesday (J.S.), at 9 Wigton, Monday, at 9.30 Winchester, Monday Wednesday (By) and Windsor, Friday, at 10 Witney, Tuesday, at 10.15 Workington, Friday, at 9.30 Wymondham, Thursday. at 2. * Other sittings are specially fixed if necessary. No returns from Circuits 21 and 50. BOROUGH QUARTER SESSIONS. Abingdon, Thursday, July 31 Canterbury. Monday, July 7, at Cardiff, Friday, July 11 King's Lynn, Thursday, July 10 Maidstone, Saturday, July 5 Manchester, Thursday, July 31 Merthyr Tydfil, Wednesday, July 9 Saffron Walden, Thursday, July 10 Wigan, Thursday, July 31. TO SOLICITORS AND EXECUTORS.-I am a buyer of unquoted or nominally quoted shares. Payment arranged through bankers. If you should hold securities of this description which you wish to realis, please send me details. W. P. Bisgood, Dashwood House, New Broad-street, E.C. 2.-[ADVT.] LEGISLATION. Sales and Notices to Quit. A Bill has recently been introduced which will largely meet a grievance felt in many parts of the country of late. Owners of agricultural land have been somewhat callous in the way in which they have issued their notices to quit prior to sales, and the object of the new Bill is to put fetters on such transactions in the case of sales of "agricultural land." This is a phrase which needs some elucidation, and it is accordingly so defined as to show that the plan proposed will apply alike to land wholly pastoral or wholly agricultural or partly agricultural; and as to the rest, pastoral or wholly or partly cultivated as a market garden. The proposal is that when an owner is making a contract for sale of such agricultural land, which may comprise one or more holdings, a notice to quit, given by him or his predecessor to a tenant of a holding within twelve calendar months prior to the making of the contract for sale, is to be null and void. There is one exception only to the universality of the suggested rule, and that is that the tenant, after this measure comes into operation, and prior to the contract for sale, agrees in writing that the notice to determine his tenancy shall be valid. By a "holding" is meant a parcel of agricultural land held by a tenant, such not being let to him during his continuance in any office, appointment, or employment held under the landlord. It would appear that the agricultural aspect of the land might be regarded as much watered down in practice, since any given parcel might be only in part agricultural, and as to the rest, might be devoted for purposes of a most miscellaneous nature. Since the Bill would call that a market garden" which is cultivated only mainly for the trade or business of market gardening, and the residue of the land which is not agricultural may be only in part cultivated as a market garden. 66 National Health Insurance. THE war has brought in its train a series of enactments which have extented the scope of the National Insurance Act 1911, and an addition is likely to be made to this series by the rather sudden appearance of Major Astor's Bill to alter the basic rate of remuneration. At the present moment par. (g) of Part 2 of the first schedule to the Act of 1911 excepts from the Act employment otherwise than by way of manual labour and at a remuneration exceeding £160 per annum. This sum in 1911 represented very fairly the general dividing line between workers on non-manual labour who were on the one hand included in, and on the other hand excluded from insurance. To-day, however, salaries and wages have grown up to such an extent that the sum of £160 does not form a dividing line at all, and so it is proposed to raise the limit from £160 to £250 so as to keep pace equitable with the closest possible approximation to the rise in salaries and wages in the case of non-manual workers. The Bill offers certain exceptions. Sect. 2 of the Act of 1911 provided for certificates of exemption from insurance in the case of those who proved that he was either (a) in receipt of £26 a year not dependent on his personal exertions; or (b) that he was ordinarily and mainly dependent for his livelihood on someone else. The new Bill adds that this certificate of exemption is to be given when the Minister of Health is satisfied, on an application made before the 1st Jan. next (or some later date allowed in an individual case by the minister) that the applicant is engaged in employment which but for the provisions of this Bill would have been excepted from part 1 of the Act of 1911, and that he has not since this Bill operated been engaged in any employment which would not have been so excepted. The certificate of exemption is to become void and of none effect if its grantee subsequently enters into any employment which would not have been thus excepted. It is proposed with necessary adaptations to apply these provisions to Scotland and Ireland and to bring it into operation on the 30th June, so, however, that no liability is to be imposed on any person in respect of the payment of contributions payable between that date and the date when the Bill actually passes into law. Dogs' Protection. THE latest version of this Bill to be found, numbered 112, represents the changes made by Standing Committee E and on report The last version would sill prohibit experiments on dogs, either with or without anesthetics, but some loophole for scientific medical research was afforded by means of the grant of a special certificate to show that the experiment needed a dog and no other animal was available. Changes were also made as regards the penalties. On Friday, the 27th June, the order for third reading came on, and, on the motion being made, Sir Watson Cheyne voiced a widespread feeling that the matter was a serions one, for those responsible for the research work needed to protect the community's health. The result of a very incisive debate was framed in a resolution to the effect that the House declined to proceed further with a measure which would impose an unnecessary and vexatious obstacle to medical research. This brings to an inglorious end a measure which tended to throw abominable charges of cruelty on medical science. Had such a Bill been passed before the war many lives now saved would have been sacrificed in consequence. OCCASIONAL NOTES. Mr. Justice Darling will open the commission at Lewes on the second part of the South Eastern Circuit on Wednesday next. When the business at this town is finished he will return to London and remain until the end of the present sittings. Mr. Justice A. T. Lawrence and Mr. Justice Avory will to-day (Saturday) leave London for Chester on the North and SouthWales Circuits, and will open the commission on Monday next. Mr. Justice Coleridge and Mr. Justice Roche will leave London on Thursday next for Birmingham on the Oxford and Midland Circuit. When the business at this town is finished they will return to London and remain until the end of the present sittings. Mr. Justice Rowlatt and Mr. Justice McCardie will open the Commission at Leeds on the north-eastern circuit on Friday next. When the business at this town in finished they will return to London and remain up to the long vacation. The Probate and Divorce special jury list will be taken on Thur day next and will be continued up to and including Friday the 25th inst (Saturdays and Mondays excepted). The first July sitting at the Mayor's court will commence on Monday next at 11 o'clock. The second sitting in this month will commence on Monday the 28th inst. also at 11 o'clock. The Midsummer Quarter Sessions for cases arising in the County of Middlesex will commence to-day (Saturday) at the Guildhall, Westminster, at 10.30. The Calendars of Prisoners at the Assizes and Sessions can now be consulted at the Bar Library at the Royal Courts of Justice. The Lord Chancellor will attend a reception by the judges and Bar of Belgium on the 18th inst, at Brussels Signor Mortara, the Minister of Justice in the newly formed Italian Cabinet, is the president of the Court of Cassation in Rome. He is comparatively a young man. Born in 1866 he possesses great energy, is of an equable temperament and is looked upon as a reformer of solid character. This week Mr. James Kenyon, the chief associate in the King's Bench Division, completed his forty fifth year of service at the Royal Courts of Justice. It is a matter for congratulation that Mr. Kenyon does not contemplate retirement, and that his valuable services will still be available for both Profession and Public. M. Evain, the newly elected president of the Paris Municipal Council, is an avocat of the Court of Appeal. He is fifty-five years of age, has been on the council for nineteen years, and is an authority on economic questions Although free from obligation to serve, M. Evain joined up as a private at the beginning of the war, and rose to the rank of lieutenant, winning the croix de guerre. He is a chevalier of the Legion of Honour. The Vice-Chancellor of the Duchy and County Palatine of Lancaster (Mr. R. B. Lawrence, K ̊C.) was entertained to dinner on Saturday evening, the 21st June, at the Exchange Hotel, Liverpool, by members of the Bar of the Palatine Court. Mr. Courthope Wilson, K.C. presided, and there was a large attendance of members of the Chancery Bar from Manchester and Preston, as well as Liverpool, together with the registrars of the court. The 26th of June being the grand day of Trinity term at Gray's inn, the treasurer (the Lord Chancellor) and the Masters of the Bench entertained at dinner the following guests: the Archbishop of York, the Duke of Sutherland, Lord Salisbury, KG, Lord Lonsdale, Lord Sandhurst, Lord Coleridge, Mr. Winston Churchill, Sir Seymour Fortescue, RN, K.C.V.O., Lord Justice Eldon Bankes, Mr. Justice Eve, and Mr. Urban Broughton. The Benchers present in addition to the treasurer were: Mr. J. A. Clyde, K.C., Judge Mulligan, K C., Mr. M. W. Mattinson, K.C., Sir Lew 8 Coward, K.C., Mr. Thomas Terrell, K.C., Sir Dunbar Barton, Bart, Lord Justice Duke, Mr. H. F. Manisty, K.C., Mr. Arthur Gill, Mr. E. F. Vesey Knox, K.C, Lord Justice Atkin, Mr. Montagu Sharpe, Mr. Justice Greer, Mr. Charles Herbert-Smith, Judge Ivor Bowen, K.C., Colonel Sir Hamar Greenwood, Bart., K.Č., Mr. A. W. Samuels, K.C., with the preacher (the Rev. R. J. Fletcher, D D.) and the undertreasurer (Mr. D. W. Douthwaite). The appointment of the Attorney-General for Ireland Mr, Arthur W. Samuels K.C., to the judgeship in the High Court of Justice left vacant by the retirement of Mr. Justice Madden on the 1st of April last is announced. It is also settled that Mr. Samuels is to go on the Munster circuit with Lord Justice O'Connor. The circuits go out on the 7th July and the business will easily be finished by the end of the month. On the appointment of Mr. Samuels, Mr. Denis Henry, Solicitor-General, will be promoted to the office of Attorney-General, and the former office will be left vacant. The representation of Dublin University will also be left vacant by the elevation of Mr. Samuels, its senior member. Ireland is full of rumours at the present time as to executive changes and changes of policy, but it is impossible to get reliable information upon these matters. The appointment of the new Solicitor. General will throw some light upon the intentions and policy of the Government, and some light has been already thrown upon them by the apparent abandonment of the Irish Private Legislation Bill. In view of the general desire to celebrate the declaration of peace which marks the termination of the war, the Local Government Board have issued an order (General Order No. 65209) sanctioning any reasonable expenses which may be incurred by county councils, metropolitan borough councils, councils of boroughs and urban districts, rural district councils, and parish councils, in connection with any public local celebration of peace, in so far as those expenses are charged in accounts subject to audit by a district auditor. In many localities the funds for the public celebration will be obtained by means of voluntary sub. scriptions and the issue of the order is not intended in any way to discourage subscriptions of this character or other private beneficence. The board consider that the powers conferred by the order should be used where necessary to supplement funds otherwise contributed for public local celebrations rather than to supersede such funds. The board cannot undertake to advise individual authorities or persons as to whether any particular kind of expenditure might be incurred or as to the amount which might properly be expended by any particular authority. The effect of the sanction will be that expenses duly incurred under the terms of the order will not be liable to disallowance by the district auditor, but if questions should be raised hereafter as to whether any expenditure is or is not covered by the order the questions will in the first instance be for the auditor to consider. The County Courts in Ireland have already dealt with several cases under the Criminal Injuries (Ireland) Act 1919, which received the Royal Assent on the 16th April. The Act, which applies to Ireland only, enables magistrates, policemen, members of the naval, military and air forces, to receive compensation from the ratepayers, where they have been maimed or injured in the execution of their duties, or because of having acted in their offices, and where death resulted their personal representative was enabled to bring the claim on behalf of the relatives. An ordinary civilian was also under the Act entitled to bring a claim, but in such a case it would be necessary for him to show that the injury arose out of some combination of an unlawful or seditious character and was a crime. The County Court judge of Mayo had before him last week an application for £6000 by the widow of Mr. Milling, a resident magistrate at Westport, who was shot in his own house in April last, under circumstances which left no doubt as to the nature of the crime. The salary of the deceased was £700 a year at the time of his death, and it was urged that the amount claimed invested for the benefit of the widow and children would produce a smaller sum, and if anything was too small a sum. The learned judge granted the full amount claimed which he did not consider excessive. He referred to the murder of the magistrate in very strong and severe terms as one of the most unjustifiable and atrocious crimes that stained the country for many years. The pro On the 27th and 28th June eight Canadian soldiers were before the chief magistrate at Bow-street Police Court, charged with manslaughter and riot at Epsom in Surrey, and six of them were committed for trial at the Surrey Assizes. cedure, though somewhat unusual, was in strict accordance with the statutes. Metropolitan magistrates are justices of the peace for each of the home counties (2 & 3 Vict. c. 71, s. 1), and by sect. 5 of the Indictable Offences Act 1848 a justice of the peace for one county, say Surrey, who happens to be" in another county adjoining the first, say London, may act as a justice for the first county "in all matters and things berein before or hereinafter in this Act mentioned." A constable is authorized to take before him " "any and person offending against the law and whom he lawfully may ought to apprehend," and generally to act in all things as if the justice were within his own county. In addition to being a justice for London, Middlesex, Kent, Surrey, Essex, and Hertfordshire, the chief magistrate is always included in the commission of the peace for Berkshire, the object being to enable him to be a member of the court of summary jurisdiction held on the racecourse at Ascot. This practice seems to have originated after an assault on William IV. in 1832 by a naval pensioner, who considered he owed the King a grudge. No justice was at hand to deal with the offender, and steps were taken to ensure the presence of one in the future. Happily he has never had a royal prosecutor before him. The decision of the judges of the Superior and Circuit Courts of Chicago to assume the traditional judicial robe, and the approval of this determination given by the American Law Review, are significant as recognising that in so democratic a country as the United States dignity and prestige may be given to a court by the costume of its judges. For many years the judges of the Supreme Court of the United States have been accustomed to wear black gowns, and in a certain number of the States the appellate judges have followed their example, but the rule has not obtained universal acceptance A judge arrayed in a distinctive costume is doubtless more picturesque and more impressive than one clad in what in America is known as "Jeffersonian simplicity," but there is little likelihood of our kin beyond sea adopting the extensive and expensive judicial wardrobe with which English judges have to provide themselves. The history of these robes, as well as the times and seasons when they are to be worn, are dealt with at length and in interesting fashion by Pulling in his Order of the Coif, and by the Comte de Franqueville in his extremely valuable work, Le Système Judiciaire de la Grand Bretagne. As we have said, the English High Court judge's outfit is both extensive and expensive, and in this connection it may be recalled that a former judge noted for his somewhat gloomy views on things in general, meeting a friend whose promotion to the Bench had just been announced, offered him the cheering observation, "Your robes will cost you a lot of money!" In view of the recent visit to London of Dr. Epitacio Pessoa, the newly elected President of Brazil and the friendly relations between the Republic and Great Britain it may interest readers of the LAW TIMES to know that the President is a member of the legal profession. It goes without saying that he is one of the most notable figures in Brazilian politics, and his presence in Europe was due to his position as chief of the Brazilian Mission to the Peace Conference. Born in 1865 in the State of Parahyba, he was educated in Pernambuco, under the direction of his uncle, the Baron de Lucen, and took his degree in law with honours. At the age of twenty-five he become a Deputy for Rio. In 1894 he was again elected, his mandate however was cancelled, but he had already made a name by the fearlessness with which he led the opposition to Marshal Floriano's government. After spending some years in travel in Europe, on his return to Brazil, he was appointed Minister of Justice and Internal Affairs under Campos Salles, and as such was instrumental in bringing about education reform and framing the civil code. He has been Procurator-General of the Republic and a juge of the High Court. He is the author of a Treatise on International Law. His opponent in the Presidential contest, Dr. Ruy Barbosa, is also a lawyer, and represented Brazil at the Hague Conference in 1907. He declined the offer of the headship of the Brazilian Mission to the Peace Conference, which the new president, as stated above, accepted. He is greatly respected, as this excerpt from a Press appreciation when defeated for the presidency shows: "Ruy Barbosa was an excellent Brazilian, and the people were willing to have him represent them anywhere; they were proud of him, but they did not wish him to govern them." L'ordre des avocats à la cour d'appel de Paris last week met for the election of a successor to Me. Henri-Robert, the bâtonnier, who has held the high office since 1914, a period unprecedented in the annals of the Bar of Paris, in modern days at least. The number of voters was 800, and 752 votes were r corded. Me. Mennesson received 511 votes against 241 accorded to Me. Albert Salle. The retiring bâtonnier, Me. Henri Robert, declared Me Mennesson elected, and addressed to him the felicitations of the Bar, and the new bâtonni r suitably replied. It may not be inappropriate on the present occasion to mention that the term bâtonnier is derived from the bannière or bâton which the dean of the religious and juridical confraternity of Saint Nicholas carried. The mention of the term bâtonnier is first found in 1602 In certain of the provinces this title was replaced by the term "syndic." Under the decree of the 14th Dec 1810 the bâtonnier was appointed by the Procurator-General. From this date up to 1870 the law was varied several times. Now the election is governed by the decree of 10-25 March 1870, giving to the ordre the right to elect directly the bâtonnier by an absolute majority. He is legally elected for one year, but he generally holds the high office for a second term. The bâtonnier is the head of the ordre, has charge of the roll, is president of the council of discipline, and is held to see its decisions carried out. He represents the ordre vis à-vis his confreres, over whom he has the direct surveillance and vis-à-vis the corps judiciaires. The office is almost precisely the same as that of the Dean of Faculty in Edinburgh, save the Dean of Faculty when once elected, in practice is re-elected until promotion or some other reason causes his resignation. The only exception to this rule that the present writer can recall was when the Tories ousted Erskine in favour of Robert Dundas of Arniston, who in consequence was immortalised by Burns who suggested scornfully that— Bobby's mouth may be opened yet Till for eloquence they hail him, And swear he has the angel met That met the ass of Balaam.” In certain proceedings before him last week Lord Coleridge quoted the answer of the American lawyer who, when asked what would happen in his country if a man chose to entail a great landed estate, instantly replied, "Set aside the will on the ground of insanity." This remark was used many years ago by Matthew Arnold, in his essay on Equality, in which, with his marked tendency to exalt things foreign over things English, he sought to demonstrate that the higher civilisation he discovered among the French peasantry was due entirely to the testamentary law established by the Code Napoléon-the law which forbids entails, and insists upon the principle of practically equal division of property among a testator's children. There were those among Arnold's critics who declared that the essayist saw the French peasantry through rose coloured spectacles, and entertained grave doubts whether he and George Sand, whom he called in as corroborating his views, were justified in claiming that France was the most civilised of nations, and that its pre-eminence in this respect it owed to the principle of equality. It is certainly significant that not a few later writers, and several of them French, have been questioning the wisdom of the testamentary law as it exists. In his standard work on France Mr. Bodley says that one of its disadvantages is "that its operation after several generations has caused such an excessive sub division of landed property that peasant proprietors meet the inevitable difficulty by limiting the number of their children. Whence the shrinking birth-rate of France, which is a further check on colonial enterprise, and in the days of universal conscription on the Continent is a menace to French security in the face of the steady growth of the armed nation beyond the Vosges." It may be, now that the League of Nations is set on its feet, which its sponsors fondly hope will put an end to war-we hope it may, although we have our doubts-the last point touched on by Mr. Bodley has lost some of its force; but, be that as it may, it is interesting to observe that a law intended to secure an equitable distribution of property has in the past so operated as seriously to affect the growth of a nation. No doubt there have been other causes at work tending in the same direction, as has been the case in our own country,where the law of bequest is different, but recent French observers have pointed to this as the chief determining cause of the alarming decrease in the birth-rate. The gradual transfer of the prerogatives of the Crown in their practical exercise from the Sovereign to his Ministers on whose responsible advice these prerogatives are exercised by the Sovereign, no longer on his own initiative and for his own purposes, but on the recommendation of Ministers responsible for the advice so tendered to the House of Commons, and through that House to the commons at large, is one of the leading features in the growth of the Constitution. Blackstone's designation of the Sovereign as the fountain of honour, of office, of privilege" his statement that, as the law supposes that no one can be so good a judge of the several merits and services [of bis subjects] as the Sovereign who employs them, it has therefore intrusted to him the sole power of conferring dignities and honours in confidence that he will bestow them upon none but such as deserve them, his declaration "that from the same principle arises the prerogative of creating and disposing of offices, for honours and offices are in their nature synonymous," are all impressive, but, to use Professor Dicey's criticism of Blackstone's exposition of the Royal prerogative, "have but one fault, the statements are the direct opposite of the truth," although, of course, correct enunciations of the letter of the Constitution as distinct from its practice. Of late, indeed, the formal recognition of the prerogative of the Crown as fountain of honour in the disposition of patronage, in the conferring of honours and offices, has been ignored as appertaining to the Sovereign and the fact acknowledged that such disposition of patronage appertains in reality to the Prime Minister. To give a few illustrations of this development in constitutional practice. Mr. Bonar Law speaking in debate in the House of Commons on the 27th May on a question concerning the practice of the bestowal of honours 66 in consideration of contributions to party funds abandoned, albeit unconsciously, the position of the Sovereign having any initiative in the exercise of such patronage which he regarded not only as appertaining to the Prime Minister but as capable of being delegated by him. "It was of course," he said, the Prime Minister who recommended these distinctions to His Majesty, but since the Coalition was formed it was generally known that he as Leader of one party of the Coalition should, as a rule, recommend to the Prime Minister members of that party who were to receive political honours." The transfer of the prerogative in practice from the Sovereign to the Prime Minister is acknowledged, albeit unconsciously, by the publication of the Honours List being thus announced: "The Prime Minister's list of honours, the publication of which was deferred at the New Year, was issued last night." This method of announcement was not subjected to any criticism. Again the Crown's supremacy in all matters ecclesiastical was definitely established by 1 Eliz., c. 1, usually called the Act of Supremacy. The supremacy in relation to the Established Church as built with the fabric of the State is a feature of our Constitution so marked as to lead many eminent exponents of constitutional law, including Sir William Anson, to regard the King as head of the Church, a title used by Henry VIII., Edward VI. and Mary, but given up by Mary, and never assumed by any other Sovereign. The Sovereign's prerogative in the disposition of Church patronage has till recently been regarded as admitting in its exercise a considerable discretion in acquiescence with the recommendation of the Prime Minister and a yielding in the case of conflict of opinion by the Prime Minister to the wishes of the Sovereign. In the course of half a century, however, the power to grant offices in the church has in practice become virtually vested in the Prime Minister on recommendation to the Sovereign. The Times in a leading article significantly, albeit unconsciously, testifies to this transfer of the prerogative from the Crown to the Minister. "Four bishops," writes the Times, "must shortly be appointed to vacant Sees (since the article was written yet another See has become vacant). Upon the Prime Minister lies the duty of making selections for these vacant Sees. It is right that he should take time before making his recommendations to the Crown, and something must be allowed for his absorption in the supremely important work which keeps him in Paris. It is to be hoped that Mr. Lloyd George will make his nominations without needless delay." The prerogative has undoubtedly passed to all intents and purposes from the Crown to the Minister. GENERAL INTELLIGENCE. INSURANCE NOTES. A CORRESPONDENT recently inquired about the financial standing of the Consolidated Assurance Company, wanted to know whether the £l fully-paid share, then standing at 87s. 6d., was a desirable purchase, and-as a matter of course-wished to be informed whether there was "any truth in the rumours of an amalgamation," a phrase with which all those interested in insurance matters are getting very familiar. Except upon this latter point, of which the writer of these notes knows nothing, it is easy to satisfy these questions. The Consolidated was established in 1903, and in 1915 it acquired the business of the Catholic and General Insurance Company. The capital consists of 470,740 £1 ordinary shares, with 2s. paid, and 129,269 £1 ordinary shares fully paid At the time of the inquiry those shares stood at 8s 6d and 87s. 6d. respectively, and yielded £2 178. or £2 15s. They have since then been rising in price. The very low yield involved in the current market price is of course highly significant. The company transacts life business, mainly abroad, and also fire and marine re-assurance business. The life and annuity funds now amount to £175,937, the life premium income to £40,587, and the life interest income to £6869. This department is therefore seen to be yet rather in infancy, and, of course, from the point of view of our inquirer, the life business is of subsidiary importance. The premium income derived from other than life business has increased from £166,797, the figure at which it stood in 1910, to £1,088,943, in 1918 Apart altogether from the interest earned by the general funds, the profits earned by the business have been as follows: 1914. 1915 1916. £8 698 1917. £9.513 1918. £18 830 £39,908 £124,297 These figures show the most remarkable progress, and, even if the end of war conditions may render the immediate future of All the profits from the very outset have been reserved. An increasing rate of dividend would seem to be inevitable in the future, just because the growth in the interest income seems to be inevitable. The 1918 report shows a surplus of £281,999, and, after providing fire, general, and marine reserves and writing off £33,396, which includes £20,000, the balance of the organisation expenses, there is enough to increase the general reserve to £150,000. But no company can go on piling up all profits as reserve for ever, and before long it seems that the scale of dividend paid will have to be greatly incre sed. The position is much the same as it was, on a different scale, in the case of the Commercial Union, when their shares, standing in the twenties and then in the thirties, were known by all those whose business it is to follow such matters closely to have an inevitable rise in front of them. Whether or not there be truth in the "rumours" would appear to matter very little to holders of such shares; it is rather like a Victory Bond with its £15 prize. The prize is inherent in the shares, and whether it come sooner or later, come it must eventually. One is therefore not at all surprised that the yield on present prices looks so low, for a Consolidated share has, humanly speaking, a fine future before it. If a The reference above to Victory Bonds reminds us of the many excellent schemes so promptly devised by the insurance offices to enable people to buy the new bonds on the easy instalment system. The Equity and Law quotes with confidence whole-life with profit rates for Victory Bond policies. The premiums quoted are merely tabular rates for a sum insured of £85 bond is drawn for redemption before death the sum insured payable at death is increased from £85 to £100, irrespective of bonus additions. The Legal and General scheme is on different lines. The Victory Bond policy can be either an endowment assurance or a redemption assurance. Annual premiums at tabular rates for £85 are charged, with a loading of 98. Regarding this 9s. as interest, this turns the yield on its investment, from the office point of view, from one of £4 14s. 1d. per cent. into one of £5 58. per cent. If the bond is drawn, the £15 premium is paid over to the policy-holder as a refresher, and the policy becomes one of £85, actual cash at death or survival, and the annual premium is reduced by the 9s referred to above. The Funding Loan can be obtained on the same system, although here the annual premiums are charged for a sum insured increasing with the term of the policy, from £80 at five years' duration to £90 at thirty years in the case of a redemption assurance, with slight modifications for different ages at entry under the endowment assurance tables. * For a loan, however, which has so much of the sporting element about it as a Victory Bond, the Prudential scheme, it must be confessed, seems the most enterprising of all, for this company has caught on to and developed the lottery element in the loan in a highly ingenious manner. The scheme enables the purchaser to pay for his bond over a number of years without surrendering the right to enjoy the full benefit instantly if the bond happens to be drawn for redemption. The sporting element is therefore incorporated in the policy itself as well as in the bond. However soon a bond may be drawn, the redemption price of £100 for each bond will be handed over to the insured, if living, without payment of any further premiums whatever. If the insured dies before the bond is drawn, his representatives receive the bond free of all incumbrance, all premiums on the policy coming to an end, and the deceased's estate becoming possessed of the dividends and eventually receiving the prize when in due course the bond is drawn. The insured's investment can never depreciate, for he is pro tected by the option which enables him to take £85 in cash for each £100 bond. If the insured die as the result of an accident, an extra £100 is paid in respect of each £100 bond insured. The payment of premiums can, if preferred, be made payable for a limited number of years instead of throughout the duration of the policy. Either whole life or endowment assurance is available. Medical examination is usually dispensed with. When it is remembered that the premiums paid partake of the well-known income tax allowance, and when it is seen that a man of thirty, for instance, can, under the life scheme, get a £1000 bond by paying £26 48. 2d. a year, from which premium anything up to £3 18s. may be deducted as tax allowance, it is making it very difficult for anyone to shirk his duty on the score of poverty. At least twenty offices are catering for these policies, some emphasising one attractive feature and some another, and a man can hardly go wrong with any of them. As long as the income tax allowance remains law, the insurance application of the instalment system must emerge superior to other methods, just as twenty shillings will always be superior to seventeen shillings. ** * It cannot be emphasised too strongly that the Victory Bond in itself provides a valuable insurance policy. A man puts down his £85 as a sort of single premium; the sum insured at death is £100 if the policy be used to defray death duties; and there is an annual cash bonus of about £3 per cent. (4 per cent. less t›x) declared, and indeed guaranteed, under the policy. That, in the terms of life insurance, is what a Victory Bond is when bought for the purpose of paying death duties. No one who has any duties to provide should be caught without this cover. No one over later middle age can, as a mere matter of commerce, obtain so profitable a single premium policy anywhere else. Where the poorer man combines a life insurance policy with a Victory Bond, he enjoys two-fold cover of a most effective kind. "UNWRITTEN LAW." THE term "unwritten law" has been frequently used in a sense quite different from its accepted meaning in our jurisprudence, and must be placed in the category of Archbishop Whately's "undistributed middle terms "-that is to say, terms used by different people in different meanings. Professor Dicey has thus clearly stated the distinction between "written law" in the juridical sense and "unwritten law." Written law is statute law in English jurisprudence, and unwritten law is common law. "There are," says Professor Dicey, "laws of the Constitution, as the Bill of Rights, the Act of Settlement, the Habeas Corpus 'written law' found in the Statute Book-in Acts, which are other words, statutory enactments. There are other most important laws of the Constitution which are unwritten laws, not statutory enactments. Again, some of the laws of the Constitution—such, for example, as the laws regulating the descent of the Crown, which were at one time unwritten or common law, have now become written or statute law." The term "unwritten law" as used by the lay Press and in ordinary circumstances is a term with a widely different meaning from its juridical sense, has become much in vogue of late, largely owing to one of the many deplorable results of the Great War. Unwritten law has been used in the meaning of taking the law into one's own hands under circumstances of great provocation or against the seducers or supposed seducers of the wives and daughters of men placed on trial for murder, manslaughter or grievous bodily injuries. In such cases feelings of sympathy with the accused and indignation at the wrongs to which he has been subjected prevail to produce a strong public feeling of consideration for his crime and to stimulate juries who are bound to find a verdict on the facts on the directions as to the law presented to them by the judge to take the law into their own hands and to acquit on a state of facts which would render a conviction, having due regard to the obligation of their oaths, imperative. It is worthy of note that appeals to this so-called unwritten law against which judges most properly strongly warn juries, are, although evoked in certain cases under present |