ROSSER, DAVID, jun., Tonna, school attendance officer. Ct. Neath. Meeting, Nov. 14, at 11.30, at office of Off. Rec. Swansea. Exam. Nov. 17, at 11.30, at Townhall, Neath. ST. JOHN, HARRY, Gray's-inn-passage, Holborn, carpenter. Ct. High Court. Meeting, STAMMERS, JOSEPH, Hunslet, boot manufacturer. Ct. Leeds. Meeting, Nov. 16. at 11, VANSTONE, JOHN EALES, St. Mary Church, gardener. Ct. Exeter. Meeting, Nov. 26, at 11, at office of Off. Rec. Exeter. Exam. Nov. 26, at 11.30, at the Castle, Exeter. WOOD, JAMES HENRY, and COMPTON, WILLIAM, Rushden. shoe manufacturers. Ct. Northampton. Meeting, Nov 14, at 12.15, at County Court-bldgs, Northampton. Exam. Dec. 8, at noon, at County-hall, Northampton. The following amended notice is substituted for that published in the Gazette of Oct. 23. HILL. JAMES, Southampton, gentleman. Ct. Southampton. Exam. Nov. 25, at 11, at Court-house, Southampton. GAZETTE, Nov. 10. ANDREWS, WILLIAM, Carmarthen, licensed victualler. Ct. Carmarthen. Meeting, Nov. 17, at noon, at office of Off. Rec. Carmarthen. Exam. Dec. 9, at 11, at Guildhall, Carmarthen. ALLEN, JAMES WALKDEN, Wigan, licensed victualler. Ct. Wigan. Meeting, Nov. 19, at 10.30, at Court-house, Wigan. Exam. Nov. 19, at 11.15, at Court-house, Wigan. BATES, CHARLES. Graham-rd, Hackney, farmer. Ct. High Court. Meeting, Nov. 17, at 11, at Bankruptcy-bldgs. Exam. Dec. 9, at 11.30, at Bankruptcy-bldgs. BRADLEY, GEORGE, late Castleford, solicitor. Ct. High Court. Meeting, Nov. 20, at 11, at Bankruptcy-bldgs. Exam. Dec. 9, at 11.30, at Bankruptcy-bldgs. BRAUN, SAMUEL PETER, late Great St. Helens, merchant. Ct. High Court. Meeting, Nov. 20, at noon, at Bankruptcy-bldgs. Exam. Dec. 9, at 11.30, at Bankruptcy-bldgs. BANNER, HARRY TIMOTHY, Great Malvern, late carriage builder. Ct. Worcester. Meeting, Nov. 19, at 11.15, at office of Off. Rec. Worcester. Exam. Dec. 15, at 2.15, at Guildhall, Worcester. BANNISTER, GEORGE (trading as the City of London Flour and Grain Company), Luton. Ct. Luton. Meeting, Nov. 24, at 11, at Court-house, Luton. Exam. Nov. 24, at noon, at Court-house, Luton. COTTERILL, JAMES HENRY, and BUTLER, GEORGE (late trading as the Birmingham and CHRISTEN, A., Great Russell-st, Bedford-sq, advertising contractor. Ct. High Court. CLAYTON, GEORGE, Skegby, shoemaker. Ct. Nottingham. Meeting, Nov. 17, at noon, at office of Off. Rec. Nottingham. Exam. Dec. 4, at 10, at County Court-house, Nottingham. DE BERENSBERG, VICTOR CLAVER, Haverfordwest, professor of languages. Ct. Pembroke Dock. Meeting, Nov. 17, at 3, at office of Off. Rec. Carmarthen. Exam. Dec. 4, at 11.30, at Temperance-hall, Pembroke Dock. EVANS, WILLIAM, Gloucester-mews West, cabowner. Ct. High Court. Meeting, Nov. 17, at noon, at Bankruptcy-bldgs. Exam. Dec. 17, at 11.50, at Bankruptcybldgs. FITTER, MATTHEW ALEXANDER, late Birmingham, solicitor. Ct. Birmingham. Meeting, Nov. 18, at 11, at 23, Colmore-row, Birmingham. Exam. Nov. 27, at 2, at County Court, Birmingham. GOUGE, GEORGE, Cardiff, late licensed victualler. Ct. Cardiff. Meeting, Nov. 18, at 11, at office of Off. Rec. Cardiff. Exam. Dec. 11, at 10, at Townhall, Cardiff. GRUNDY, FREDERICK (trading as F. Grundy and Co.), Northwich, timber merchant. Ct. Nantwich and Crewe. Meeting, Nov. 20, at 10.45, at Royal hotel, Crewe. Exam. Nov. 20, at 11.30, at Court-room, Crewe. GROOME, FREDERICK, Kettering, boot manufacturer. Ct. Northampton. Meeting, Nov. 18, at 12.30, at County Court-bldgs, Northampton. Exam. Dec, 8, at noon, at County-hall, Northampton. GARSIDE, JABEZ, Oldham, wholesale baker. Ct. Oldham. Meeting, Nov. 18, at 3, at office of Off. Rec. Oldham. Exam. Nov. 20, at 11, at Court-house. Oldham. GRIFFITHS, THOMAS (trading as Thomas Griffiths and Son). Wednesbury, gas-fitting manufacturer. Ct. Walsall. Meeting, Nov. 19, at 11 30, at office of Off. Rec. Walsall. Exam. Nov. 19, at noon, at Court-house, Walsall. HANNEY, BLANCHE, late London-st, Paddington, widow. Ct. High Court. Meeting, HENLEY, WILLIAM GORDON, late Mount-st, Grosvenor-sq, estate agent. Ct. High HUMPHREY, JOHN PRIOR, Manor Park-rd, Harlesden, builder. Ct. High Court. JONES, HUGH, Rhoscolyn, farmer. Ct. Bangor. Meeting, Nov. 18, at 1.45, at Marine KNIGHT, J. B.. late Conduit-st. Ct. High Court. Meeting, Nov. 18, at 1, at Bank- MASTERS, JAMES, Cardiff, builder. Ct. Cardiff. Meeting. Nov. 18, at 11.30, at office OSBORNE, JAMES, Kidderminster, upholsterer. Ct. Kidderminster. Meeting, Nov. 18, at 2, at office of Spencer Thursfield, Oxford-st, Kidderminster. Exam. Nov. 18, at 2.20, at Townhall, Kidderminster. POWERS, JAMES, Birmingham, late grocer. Ct. Birmingham. Meeting, Nov. 19, at 11, at 23, Colmore-row, Birmingham. Exam. Nov. 27, at 2, at County Court, Birmingham. REEVE, HASTINGS JOHN, Wormwood Scrubbs, late victualler. Ct. High Court. Meeting, Nov. 17, at noon, at Bankruptcy-bldgs. Exam. Dec. 4, at 11.30, at Bankruptcy-bldgs. RITSON, CHARLES, Hastings, bootmaker. Ct. Hastings. Meeting, Nov. 23, at 3, at SMEATON, THOMAS, Birmingham, draper's assistant. Ct. Birmingham. Meeting, SEAL, WILLIAM GARRICK (late trading as W. G. Seal and Co.), Manchester, monumental mason. Ct. Manchester. Meeting, Nov. 18, at 3, at Ogden's-chmbrs, Bridge-st, Manchester. Exam. Nov. 30, at 2, at Court-house, Manchester. SMITH, CHARLES THOMAS, Whitby, tobacconist. Ct. Stockton-on-Tees and Middlesbrough. Meeting, Nov. 18, at 3, at office of Off. Rec. Middlesbrough. Exam. Nov. 18, at 10.30, at Court-house, Stockton-on-Tees. SHAW, GEORGE HENRY, late Fenton, plumber. Ct. Stoke-upon-Trent and Longton. ULLMANN, CHARLES, late Ryder-st, St. James's, oyster merchant. Ct. High Court. Nov. 19, at noon, at Bankruptcy-blags. Exam. Dec. 8, at 11.80, at Bankruptcy bldgs. WILLIAMS, DAVID, Blaengarw, haulier. Ct. Cardiff. Meeting, Nov. 17. at 11.30, at office of Off. Rec. Cardiff. Exam. Dec. 11, at 10, at Townhall, Cardiff. WATIS, JOHN HENRY, Shepton Mallet, fishmonger. Ct. Wells. Meet ng, Nov. 18, at noon, at office of Off. Rec. Bristol. Exam. Dec. 1, at 11.80, at Townhall, Wells. NOTICE OF DAY APPOINTED FOR PROCEEDING WITH PUBLIC EDELSTON, JAMES (late trading as H. C. Owtram and Co.), Manchester, cotton manufacturer. Ct. Manchester. Exam. Nov. 30, at 2, at Court-house, Manchester. ADJUDICATIONS. GAZETTE, Nov. 6. BANNISTER, GEORGE (trading as the City of London Flour and Grain Company), Luton, FITTER, MATTHEW ALEXANDER, late Birmingham, solicitor. Ct. Birmingham. Order, GOODCHILD, PHILIP PETER PERRING, Bonchurch, late lieutenant-colonel. Ct. Newport and Ryde. Order, Oct. 31. HATCHWELL, ALICE (trading as Maison Moderne), late Oxford-st. Ct. High Court. Order, Nov. 3. HOLLAND, MARY, Birstal, milliner. Ct. Bradford, Yorks. Order, Nov. 4. HEWETT, SAMUEL. Pontypool, late grocer. Ct. Newport, Mon. Order, Nov. 4. Order, JONES, THOMAS, jun., South Cornelly, licensed victualler. Ct. Cardiff. Order, Nov. 21 KETTERINGHAM, JOHN HAZELWOOD, York-rd, Battersea, draper. Ct. Wandsworth' Order, Nov. 3. LAWRENCE, CHARLES LENDON, Hereford, commercial traveller. Ct. Hereford. Order, LOXTON, CHARLES, Swansea, boot dealer. Ct. Swansea. Order, Nov. 3. PHILLIPS, WILLIAM (trading as the Amman Valley Saw Mills Company), Garnant, timber merchant. Ct. Carmarthen. Order, Nov. 4. QUINTON, EDWARD, late Emsworth, baker. Ct. Portsmouth. Order, Nov. 4. WILLIAMS, WILLIAM, Chepstow, grocer. Ct. Newport, Mon. Order, Nov. 4. GAZETTE, Nov. 10. ASHBY, ELIZABETH, Newport, widow. Ct. Newport and Ryde. Order, Nov. 6. BROAD, FRANK, Hoo, dairyman. Ct. Rochester. Order, Nov. 6. BANNER, HARRY TIMOTHY, Great Malvern, carriage builder. Ct. Worcester. Order, Nov. 5. CHADWICK, DAVID, Bolton, late furniture broker. Ct. Bolton. Order, Nov. 6. CLEAVER, EDWARD, late New Malden. Ct. Kingston, Surrey. Order, Nov. 7. DEXTER, MARY ELLEN, and GELSTHORPE, MARY ELIZABETH (trading as Dexter, DRAGE, WILLIAM HICKMAN, Northampton, pawnbroker. Ct. Northampton. Order, Nov. 7. DE BERENSBERG, VICTOR CLAVER, Haverfordwest, professor of languages. Ct. Pembroke Dock. Order, Nov. 7. GRIEVES, JOHN WILLIAM (trading as the International Trade Exhibition Syndicate), Gresham-st, exhibition promoter. Ct. High Court. Order, Nov. 7. GILL, WALTER JAMES, Goole, commission agent. Ct. Wakefield. Order, Nov. 6. HILL, JAMES, Southampton, gentleman. Ct. Southampton. Order, Nov. 5. Order, Nov. 5. Order. Nov. 6. Ct. Plymouth and East Stone JELLEY, HUGH, Leicester, boot manufacturer. Ct. Leicester. Order, Nov. 7. Ct. Ashton-under-Lyne and Stalybridge. Order, Nov. 4. Ct. High Court. RICHARDSON, GEORGE, Preston, cabinetmaker. Ct. Preston. Order. Nov. 7. ST. JOHN, HARRY, Gray's-inn-passage, Holborn, carpenter. Ct. High Court. Oct. 29. SMEATON. THOMAS, Birmingham, draper's assistant. Ct. Birmingham. Νον. 5. Order, Order, SHAW, GEORGE HENRY, Fenton, plumber. Ct. Stoke-upon-Trent and Longton. Order, Nov. 7. TAYLOR, THOMAS HENRY, Burton-on-Trent, bicycle dealer. Ct. Burton-on-Trent. Order, Nov. 7. WISE, JOHN THOMAS, late Rawcliffe, farmer. Ct. Stockton-on-Tees and Middiesbrough. Order, Nov. 4. WILLGOOSE, ARTHUR, Derby, plumber. Ct. Derby. Order. Nov. 7. WOOLLEY, JOHN, Nottingham, fish salesman. Ct. Nottingham. Order, Nov. 6, BIRTHS, MARRIAGES, AND DEATHS. BIRTHS. FERRIER. On the 4th inst., at No. 8, South-quay, Great Yarmouth, the wife of Richard F. E Ferrier, Solicitor, of a son. GODFREY. On the 2nd inst., at Montague House, Beccles, Suffolk, the wife of J. R. R. Godfrey, Barrister-at-law, of a son. LIGHTFOOT. On the 1st inst., at 6, Howard-ter, Carlisle, the wife of George Augustus Lightfoot, Solicitor, of a son. ORMOND.-On the 24th ult.. at Calcutta, the wife of Ernest W. Ormond, Barrister-atlaw, and Judge of the Puisne Court, of a son. PYKE. On the 5th inst, at No. 2, Cornwall-grdns, S.W., the wife of L. E. Pyke, Q.C., of a daughter. RUSBY. On the 6th inst., the wife of James William Rusby, LL.B., Solicitor, of MARRIAGES. CLARKE NEAME.-On the 4th inst., at St. Mary de Lode's Church, Gloucester, by the Vicar, the Rev. S. R. Robertson, Charles Frederick Loriston Clarke, of Bristol, Solicitor, son of the Rev. C. G. Clarke, M.A., of Tunbridge Wells, to Alice Neame, elder daughter of the late C. B. Walker, M.A., J.P., of Wotton House, Gloucester. DUMONCEAN-WEST.-On the 31st ult., at St. Peter's Church. Redcar, Edmond Gustave Dumoncean, of Maestricht, Holland, to Elizabeth Emily (Lilly), eldest daughter of the late Thomas West, Barrister-at-law, of Newton Hall, Yorkshire. and Malines, Belgium. HENNESSY-BERTRAM.-On the 31st ult., at Darjeeling, Percival Hennessy, third son of James Hennessy, Esq., of 5, Lancaster-gate, London, to Adelaide Mary, eldest daughter of W. Bertram, of Nisbet and Kirsewell, Lanarkshire, J.P. and D.L., late 72nd Highlanders and 77th Regiment. SIMNER SIMONS.-On the 7th inst.. at the parish church, Barnet, Nugent Charles Simner, of the Middle Temple. Barrister-at-law, elder son of Win. Lewis Simner. of Potter's Bar, to Alice Maude, elder surviving daughter of Joseph Simons, or Elmhurst, New Barnet. DEATHS. CORYTON. On the 7th inst., at No. 1, Essex-ct, Temple, from pneumonia, John Coryton, Esq. (son of the late Gen. John R Coryton), Barrister-at-law, late Judge of the Naval Court, Calcutta, and Recorder of Rangoon and Moulmein, in his 71st year. Friends please accept this intimation. FINDLATER.-On the 2nd inst.. at 22, Fitzwilliam sq. Dublin. Muriel Demster, dearlyloved daughter of William Fi dlater, D. L., and Marion Findlater, aged 12 years. Fox. On the 7th inst., at Ballards Lodge, North Finchley, Joseph Fox, of Southampton-st, Strand, Solicitor, second son of the late Edwin Fox, of Gresham-st, London, E.C. JEFFERY.On the 7th inst., at Oak Mount, Manningham, Bertha Greenwood, the dear wife of Herbert J. Jeffery, Solicitor, Bradford. WARNER.-On the 8th inst., at 20, Hyde-st, Winchester, Frederic Isaac Warner F.L.S., Solicitor, aged 55. YOUNG. On the 2nd inst.. at Westgate-on-Sea, Thomas Young, of 29, Mark-la, E.C., and Abbotsford, Mount-view-rd, Crouch Hill, Solicitor, senior partner in the Firm, of Young and Sons, in his 82nd year. AT ALL BOOKSELLERS AND RAILWAY BOOKSTALLS. BENTLEY'S FAVOURITE NOVELS. Uniformly bound. Each Work can be had separately, price LATEST ADDITION: price 6s. By ROSA N. CAREY. SUSAN FIELDING. By HAWLEY SMART. BREEZIE LANGTON. By Mrs. W. K. CLIFFORD. AUNT ANNE. By HELEN MATHERS. COMIN' THRO' THE RYE. By Mrs. ALEXANDER. THE WOOING O'T. HER DEAREST FOE. By Mrs. AUGUSTUS CRAVEN. A SISTER'S STORY. By MAARTEN MAARTENS. MY LADY NOBODY. AN OLD MAID'S LOVE. THE SIN OF JOOST AVELINGH. THE GREATER GLORY. London: RICHARD BENTLEY and SON, New Burlington-street. Publishers in Ordinary to Her Majesty the Queen. To Readers and Correspondents. PROFESSIONAL ETIQUETTE.-Your communication is too vague to be of any use. RALPH SIMEY.-All the information on the subject you mention will be found in All communications intended for the Editorial Department should. in order to prevent SUPREME COURT OF JUDICATURE. MILES Re WORTHAM'S SETTLED ESTATES AND Re NATIONAL BANK OF WALES LIMI 293 means "One-man Companies "- tion of Agent's Authority-Civil COMMENTS ON CASES OCCASIONAL NOTES.. NOTES OF RECENT DECISIONS NOT 295 CORRESPONDENCE... NOTES AND QUERIES shares 296 LAW STUDENTS' JOURNAL. - The R CONCESSIONS TRUST LIMITED; MCKAY'S CASE.-Company-Winding-up-Sale of shares-Certification on transfer-Fully-paid shares -Estoppel..... QUEEN'S BENCH DIVISION. BRIDGE (app.) v. HOWARD (resp.).— Adulteration-Food and drugsSufficiency of certificate-Grounds of opinion set out LEADING ARTICLES; &c. TO READERS AND CORRESPONDENTS.. LEADING ARTICLES.-Topics of the Week-What a Block on the Bench Vol. CII.-No. 2799. 298 300 51 NOW READY PATERSON'S PRACTICAL STATUTES of the SESSION 1896 (59 & 60 Vict.), with Introductions, Notes, Tables of Statutes repealed and Subjects altered, Lists of Local and Personal and Private Acts, and a Copious Index. By J. S. COTTON, Barrister-at-Law. Forty-eighth issue of the Series. Cloth, 108.; half-calf, 128.; calf, 13s. 1896. N.B.-The Vols. from 1858 to 1895 may also be had. Price 5s. a volume if complete set is taken HORACE COX, "Law Times" Office, Windsor House, Bream's-buildings, E.C. The Law and the Lawyers. LORD ESHER says that he is not to be understood as having expressed his intention to resign. It has, we believe, been too readily assumed that Sir RICHARD WEBSTER Would accept the Mastership of the Rolls if a vacancy occurred. As illustrating the inevitable stagnation at the Bar, consequent on the block on the Bench, we may mention that, whilst 1 Chancery judge has been made during the last ten years and 7 Queen's Bench judges, 102 barristers have become Queen's Counsel in the same period. THE Executive Committee of the Bar Council has appointed a strong special committee, consisting of three Queen's Counsel and five junior barristers, to inquire and report whether it is desirable, and if so, practicable, to establish a Club or Institution for the use of members of the Bar. A NOVEL feature in the list of students called to the Bar on Tuesday was the mention that one had recently been a solicitor, and one had taken honours in the Solicitors' Final Examination. Hitherto references have been confined to distinctions obtained at the Bar examinations. Ar the institution of the Inns of Court they were resorted to by squires and knights to acquire elegant manners. There The is no reason why this aim should not be pursued still. forensic costume is for the Courts, and we are quite sure that in old times it would have been execrable form to lunch at Fleet-street taverns in bands, or to smoke cigarettes on the 59 steps of the High Court in full costume. In the past there Now there is none. a censorship on such matters. These practices, however, offend the sense of propriety. was 64 64 65 65 66 68 68 69 69 70 71 LEGAL OBITUARY.-Mr. James Price- 72 BIRTHS, MARRIAGES, AND DEATHS... 74 THE statement of the Central News, which has been extensively circulated, that "Broadly speaking, the Queen's writ does not run even in a foreign Embassy or Legation, the members of which, provided their names be registered in the archives of the Foreign Office, are free from arrest or proceedings in British courts," must be taken subject to many qualifications. It is, for instance, highly arguable whether the statute 7 Anne, c. 12, under which this immunity is claimed, is applicable to members of foreign Embassies or Legations who are, notwithstanding this position, British subjects. Again, it is the clear opinion of text-writers, supported by several cases, that these immunities do not extend to protect the members of a foreign Embassy or Legation in acts of aggression towards the inhabitants of the country in which the Embassy or Legation is situate. Thus, when the coachman of Mr. GALLATIN, the United States Minister in London, committed an assault outside the Embassy, the Government claimed the right of arresting him within the house of the Minister. SUN YAT SEN, in a speech at a banquet, given in his honour on Saturday, said that he was detained in the Chinese Embassy on the pretext that he was insane. Before 1816 a pretext of this nature would have been sufficient to deprive a person in custody of the benefit of the Habeas Corpus Act. A sensible difficulty was long felt from the incompetency of the judges to inquire into the truth of a return made to the writ. For though, in cases within the statute, the prisoner might always look to legal discharge at the next sessions of gaol delivery, the same redress would not always be obtained when he was not in custody of a common gaoler. The statute 56 Geo. 3, c. 100, enables in vacation the judge before whom the writ is returned to inquire into the truth of the facts alleged therein, and, in case they shall seem to him doubtful, to release the party in custody, on giving surety to appear in court on some day in the ensuing sittings, when the court may examine by affidavit into the truth of the facts alleged in the return, and either remand or discharge the party according to their discretion. Now that it is on all hands admitted that compensation should be given to persons wrongfully convicted of a criminal offence, it seems naturally to follow that Imperial funds should be available for the benefit of persons who have been ruined or impoverished by judicial error. We deal elsewhere with the decision of the House of Lords in the one-man company case, in which Mr. Justice WILLIAMS launched a theory which the Court of Appeal too readily adopted. The Court of Appeal express the theory thus: that " seven persons" in the Act means "seven independent bona fide members with a mind and will of their own, and not the puppets of an individual," and Mr. Justice WILLIAMS held that the business was that of Mr. SALOMON and that he chose to employ a limited company as his agent. Mr. SALOMON appealed to the House of Lords in forma pauperis. In the Court of Appeal Lord Justice LINDLEY said: "Mr. ARON SALOMON's scheme is a device to defraud creditors." Lord Justice LOPES said the company was a mere nominis umbra." "To legalise such a transaction would be a scandal." Lord Justice KAY described 66 the company as a pretended association" and the sale to the company as an utter fiction." 66 66 PICTURES, prints, books, manuscripts, works of art, scientific collections, and other things not yielding income, if they appear to the Treasury to be of national, scientific, or historic interest, and if they be settled so as to be enjoyed in kind by a life tenant or tenants, are, so long as they are so enjoyed in kind, exempted from estate duty by sect. 20 of the new Finance Act. The principal Act had, by sect. 15 (2), allowed the Treasury to remit estate duty on such pictures, &c., when bequeathed for national purposes, or to any university, county council, or municipal corporation; but the present Act has gone many steps farther, and cast upon the Treasury duties of considerable delicacy and difficulty. The words appear to the Treasury seem to constitute the Treasury absolute judges without appeal as to whether any particular picture, &c., has the status of exemption from duty or not, and when the Treasury has once intimated its view, any revocation or modification does not seem to be within its power. Nor is any provision made for taking the evidence of experts, such as the president of the Royal Academy, with regard to pictures, or the librarian of the British Museum with regard to books and manuscripts. Moreover, all this vast power may be exercised by a single individual, for, by sect. 12 (2) of the Interpretation Act 1889, the expression "the Treasury" means in any Act of Parliathe Lord High Treasurer for the time being or the Commissioners for the time being of HER MAJESTY'S Treasury." ment " 66 THE Short Titles Act, it should be borne in mind, contains collective titles" of groups of Acts, as well as single titles of single Acts, and some of these collective titles require more than a passing glance from those who are looking through the statutes of the year. In many cases the grouping, whether right or wrong, is by no means such as the reader would expect. For instance, the group entitled "The Licensing Acts 1828 to 1886," which contains only thirteen Acts, contains no excise licensing Acts, and contains two Acts, the Sunday Closing (Wales) Act 1881 and the Intoxicating Liquors (Sale to Children) Act, which The Police Acts" group are not licensing Acts at all. The law is now settled disposing of all this, but poor SALOMON is in the position of Humpty Dumpty. Not all the judicial power of the House of Lords can set him up again. A new SIR HARRY POLAND's interesting letter to the Times on "Criminal Law Reform " will, it is to be hoped, bring forth useful fruit in the Statute-book of next session. Criminal Law Procedure Act is very much wanted, for the great consolidating Acts of 1861 left procedure, except in respect of aiding and abetting, almost entirely untouched, and about thirty general criminal law Acts of a date prior to 1861 are still, to a great extent, unrepealed. Of these, the Indictable Offences Act 1848, and, perhaps, also the Crown Cases Act 1848, might well be left alone; but such necessary but confusing statutes as the Criminal Law Acts 1826 and 1827, the Criminal Procedure Acts 1851 and 1853, the Prevention of Offences Act 1851, the Criminal Justice Administration Act 1851, and the Vexatious Indictments Act 1859 require a complete rehauling. As for the twenty-three clauses of various Acts which allow an accused person to give evidence, these, except where they occur in the Criminal Law Amendment Act 1885, ought all to be repealed and re-enacted in a single Act with such general amendment as may be thought desirable. And pace Sir HARRY POLAND and other great authorities, we incline to think that Mr. H. D. GREENE'S Bill, which applied to offences triable summarily only, presented the best general mode of dealing with the case. The clauses in pari materia of the Criminal Law Amendment Act may as well be left alone, but the principle of the Bill might be applied to all misdemeanours, as well as to summary proceedings. 66 66 comprehends sects. 190 to 194 of the Municipal Corporations Acts 1882, which deal with borough constables; and the Public Health Acts" group comprehends sects. 7 to 10 of the Housing of the Working Classes Act 1885, which deal with certain duties of sanitary authorities. The Railway Acts are split up into two groups, one containing the Railway and Canal Traffic Acts, and the other the Railway Regulation Acts; and the Railways Clauses Consolidation Act is not contained in either, because we suppose it is taken to be somewhat of the nature of a local and personal Act. THE eleventh and most recent volume of the 2nd edition of the Statutes Revised (which recently appeared) contains in about 1200 pages all the unrepealed statutes (omitting a considerable number as being "local and personal") from 1863 to 1867 inclusive. Preambles are, as a rule, omitted as usual, even that of Leeman's Act (or, as it may now be cited by the Short Titles Act, the Banking Companies Shares Act 1867), which preamble might well have been spared to the public. As for the omission of "local and personal" Acts, no person, we imagine, would miss the Coventry Grammar School Act (27 & 28 Vict. c. 41), much less the Morro Velho Marriages Act (30 & 31 Vict. c. 93); but we are not so sure whether it was wise to exclude the Patriotic Fund Act (30 & 31 Vict. c. 98), the National Gallery Enlargement Act (30 & 31 Vict. c. 41), or even the Queen's Children's Annuity Acts (29 & 30 Vict. cc. 7 and 8). By the way, when may the conclusion of the edition be expected: It was started in 1886 by Mr. GEORGE HOWELL'S representation to the Chancellor of the Exchequer, respecting "the expediency of providing a cheap edition of the statutes for the use of the public, and in particular for sale to public libraries accessible to working men." So it is said in the preface to Vol. I. at p. iv., where it was added (in 1888) that it was expected that the edition would be completed within three or four years; but, unless the present pace of the tortoise of revision can be accelerated, we fear at least a decade must elapse before the hare of legislation can be caught up. WHAT A BLOCK ON THE BENCH MEANS. THE absence of any rule for judicial retirement has unquestionably had a most prejudicial effect upon the Bar. Our contemporary the Saturday Review, commenting upon the expected retirement of Lord Esher (and six other judges), said that the promotion of leaders would reveal the dearth of rising talent at the Bar. This is perfectly true. The block on the Bench means a block at the Bar. Sir Richard Webster has been Attorney-General with a short interval since 1885. But for Sir Edward Clarke's deviation the office of Solicitor-General would similarly have been held by one man. He is not promoted, and is still in competition with the rest of the Bar. And many others of even longer standing are still at workkeeping down any talent there may be. In Chancery the block is nothing like what it is on the other side. Only two judges have just passed fifteen years, the others are young. In the Queen's Bench Division still at work are barristers who, if they ought not to have been might have been judges, and if they had not been younger men would have been. There is Mr. Murphy, who took silk as long ago as 1874 (Mr. Cohen and Mr. Ambrose are of the same year); Mr. Kemp, who took it in 1875; Mr. Willis, two years later, 1877; Mr. Jelf, created in the same year as Sir E. Clarke, 1880; Sir F. Lockwood, Sir R. Reid, and Mr. Bosanquet in 1882; Mr. Bigham, in 1883; and Mr. Channell, and several others now in practice, in 1885. Death, not resignation, made way for Sir Charles Russell. By a narrow period he escaped continuing indefinitely at the Bar. Every man who is fifteen years a Queen's Counsel cannot get on the Bench, but the rule of judicial retirement should be such as to give some the prospect. As that period goes by men become less and less eligible, and if judges remain on the Bench from eighteen to thirty years the bulk of the select leaders must either retire or die at the Bar. If the latter, men behind them suffer in their turn. Rising talent, if it exists, must force its way through a solid phalanx of tried advocates. Exceptional talent will do even this. To the average talented aspirant the prospect is hopeless. If the Master of the Rolls had resigned even after twentyfive years' service, the advantage to the Profession-looking at the question as one of movement and promotion-would have been enormous. Had Baron Pollock, Lord Justice Lopes, and Sir Henry Hawkins retired when they had earned their pensions, two of the Queen's Counsel given above should have been judges, one seven and one five years ago, while a third might have been raised from the Chancery Bar five years ago. The County Courts, which give some relief to the general congestion, do not touch the front rank. But they have absorbed recently Sir A. Marten, Mr. Lumley-Smith, Mr. French, Mr. Addison, Mr. Waddy, and Mr. Bompas, all of whom had a share of the general practice. Yes, there is a dearth of rising talent, and, if judges can sit without check so long as their faculties hold out, the dearth will become a famine. This, we repeat, is disastrous to the Profession, and consequently a public calamity. 66 'ONE-MAN COMPANIES." THERE is an old story of a 'meeting," which was held to celebrate the re-opening of a great theatre after its all but destruction by fire. The manager came forward to address the audience. "Ladies and gentlemen," he began; but, after a pause, during which he had surveyed the house, he corrected himself and said, "I mean respected individual." When is a company not a company? The obvious answer will at once suggest itself. How can there be a joint-stock company consisting of an individual ? Such a thing is manifestly impossible. Second Sheet The so-called one-man company is a contrivance whereby one man has all the substantial venture, all the substantial capital, all the substantial hope of profit, and all the substantial influence, though there are seven subscribers, and, therefore, a limited liability company is constituted. Whether the possibility of such a thing is politic or not we do not pretend to decide; but there is nothing in the Companies Acts, there is nothing in the law of England, to prevent it. In W. S. Gilbert's witty dialogue, which Sir Arthur Sullivan's music has made familiar to Londoners in "Utopia," the English system of joint-stock companies and the legal possibilities in respect of this question are cleverly satirised. The King of the County of Perfection there went so far as to say "it sounds dishonest," and so at first. sight it does so sound in many concrete cases; yet, where no fraud is proved, the assumption of the law must be that there is no dishonesty. The House of Lords has given a decision which raises " one-man companies" to an impregnable position until the day that the Legislature thinks fit to intervene. The decision in question is of the first importance to English business men. annum. The case is reported under the name of Salomon (pauper) v. A. Salomon and Co. Limited (the point, of course, lying in the last word) in the Times of Tuesday, the 17th inst. The facts of the case were as follows: The appellant, Aron Salomon, for about thirty years prior to 1892 carried on business as a leather merchant and hide factor, and wholesale and export boot manufacturer, under the style of A. Salomon and Co. According to the evidence of the appellant and his son, the profits of the business were between £1000 and £2000 per A limited company was formed in 1892 to carry on the business, and the original subscribers to the memorandum were the appellant, his own wife, his own daughter, and his own four sons, who each signed for one share. The appellant's business was sold to the company for £38,782, of which £16,000 was to be paid in cash or debentures, and at the first meeting of the directors, who consisted of the appellant and two of his sons, it was resolved to pay the appellant £6000 in cash and £10,000 in debentures. These debentures were afterwards mortgaged by the appellant to one Edmund Broderip as a security for an advance of £5000; but eventually these debentures were cancelled, and £10,000 fresh debentures were issued to Edmund Broderip. In October 1893 an order was made for the winding-up of the company, at which date the company was indebted to unsecured creditors other than Aron Salomon to the amount of £7733, the business of the company showing a loss of £2600 a year. Action was then brought by the liquidator of the company against the appellant, and the case was tried before Mr. Justice Williams. 66 There is in the minds of men who understand business a great prejudice against these one-man companies," where six of the subscribers to the memorandum of association are the nominees of the seventh, whether his family or his clerks or other persons under his control. The six subscribers are usually worthless; you cannot build one-man companies (any more than the children of Israel could build bricks) without straw. Consequently, there was a great leaning of the tribunals before whom the matter first came in favour of the liquidator; and it was sought, if possible, to find some legal ground on which a conclusion hostile to the one-man company could validly be Mr. Justice Williams found such legal ground in the following proposition: "The business was Mr. Salomon's business and no one else's. He chose to employ as agent a limited company." But the answer to this is Lord Halsbury's inevitable dilemma: Either the company was a legal entity validly created, or it was not. If yea, the business belonged to it and not to Mr. Salomon. If nay, there was no person and no thing to be an agent at all. rested. 66 The Court of Appeal, consisting of Lords Justices Lindley, Lopes, and Kay, while unable to support the reasons given by Mr. Justice Williams, were yet determined to uphold his conclusion, and held that the formation of the company and the issue of the debentures were a" mere scheme" to enable Mr. Salomon to carry on business in the name of the company with limited liability, contrary to the "true intent and meaning the Companies Act 1862, and to enable him to obtain priority over other creditors of the company by means of debentures, and that the appeal must be dismissed: (reported sub tit. Broderip v. 4. Salomon and Co. Limited, 72 L. T. Rep. 755). of |