never to reach, the amount transacted in the years prior to 1858; and the work has of late years been comparatively easy, although still heavier than that of the superior courts of Dublin.

The worst days of "incumbered estates came to an end about the time when the Court was permanently established; and in the new jurisdiction of making title to unincumbered properties, carrying out contracts for sale, and otherwise giving effect to amicable dispositions of property, the old character of the Court, as of a tribunal busied in enabling creditors to realise their demands, passed away. It was a great relief to Hargreave to be able to resume studies from which he had been for some years almost entirely debarred. He found it possible, moreover, during the last three or four years of his life, to spend a few days in almost every term in London, renewing his acquaintance with old friends, and appearing in hall among the benchers of the Inner Temple. Here he met with society of a very congenial kind, which he much enjoyed. In 1865 he was master of the library of his inn, and had he lived he would this year have succeeded to the office of treasurer.

Judge Hargreave, although not an ardent politician, took an interest in public affairs, and carefully studied the Parliamentary debates. He might be classed among the "constitutional Whigs," if classification were justifiable with regard to one who never interfered in political strife. He was well acquainted with international law, and had a considerable knowledge of political economy, and especially of the writings of Mr. J. S. Mill, from whose conclusions on many points he, however, dissented. He showed practically his approbation of those systems of entail and strict settlement of which Mr. Mill and some other philosophical minds disapprove, by the testamentary dispositions which he made of his own property. He took an interest in many of the proposals made from time to time for amending the law; but his remarks on this subject usually had reference rather to the administration of the law, and to modes of procedure, than to any change in the doctrines

of law. He frequently expressed a decided opinion that all cases arising out of libel, slander, assault, &c., where substantial injury had not accrued, ought to be summarily disposed of, without the cumbrous and costly machinery of an action tried before a jury.

We have seen that the ability, energy, and vigilance, so signally displayed during the early years of the Incumbered Estates Court, when the pressure of business rendered the utmost dispatch a matter of necessity, led to the permanent establishment of the tribunal, to which was committed the power of issuing Parliamentary or indefeasible titles. That power having been safely and prudently, although rapidly, exercised under an extreme pressure of business, it was rightly concluded that it ought to be continued in easier times, when the diminution of applicants rendered a still more careful scrutiny possible. The history and success of the Incumbered Estates Court were very prominently brought forward in the speech of Sir H. Cairns, when, in 1859, he brought forward his plan for establishing in England a similar court, and also a registry of indefeasible title. Again, in 1862, Lord Chancellor Westbury, while introducing his Bill (afterwards passed into a law) for establishing the Land Registry Office, eulogised the conduct of the Irish court, and quoted its success as a justification for establishing in England a system which, however perfect in theory, could never have been introduced here unless strongly fortified by the favourable experience of many years in Ireland.

Some years previously, a commission had been organised for selling incumbered estates in the West Indies, the forms and procedure of which were modelled after those of the Irish court. The progress of indefeasible title in England has hitherto been slow; but a beginning has been made; and it is highly probable that, before many years have expired, it may be found necessary to establish a separate court in connection with the Land Registry Office, for it is not to be expected that the already inadequate judicial staff of the Court

of Chancery will be able to transact business of an unusual kind in addition to ordinary duties.

The subject of a registry of indefeasible title was always full of interest for Mr. Hargreave; and he perused with great attention the statements made by Mr. R. R. Torrens, lately Registrar-General of South Australia, to whom is due the credit of having been first actually to carry into effect a system of registry of title in the British dominions. When, in 1864, Mr. Torrens, aided by an influential committee, formed a plan for establishing a Registry of Irish Titles, supplementary to the Landed Estates Court, the subject of this memoir wrote a lengthened criticism of the scheme, in the form of a letter to Mr. H. D. Hutton, the honorary secretary of the committee. This document first suggested the formation of a new department of the Landed Estates Court, in which an indefeasible record of titles originally granted by the Court might be maintained, with the power of judicially amending the record, if necessary. The plan so sketched out came under the notice of the law officers of the Crown, who undertook to prepare a Government measure which should accomplish the objects in view. A Bill was accordingly drawn, at their request and under their direction, by the writer of this memoir. It was read a first time in July, 1864, but the close of the session prevented further progress. This Bill proposed to record the titles originated by the Landed Estates Court, not taking notice of trusts; but where trusts existed, recording the trustees as owners, with a system of caveats. In this respect it accorded with the plan of Sir H. Cairns; but other points were suggested by the experience of the English and Australian Acts, as to which careful inquiries had been made. In the recess the Bill was slightly altered, so as to admit of life estates and other limited interests, equitable as well as legal, being separately registered. This change was not approved of by Judge Hargreave; but in other respects the measure had his cordial approval; and, in fact, he had revised and amended the draft of the Bill, not in the character of Judge

of the Court, but as a friend of the draftsman and interested in the subject. During the progress of this measure, he visited more than once the Land Registry Office, in Lincoln's Inn Fields, and gained an insight into the actual working of Lord Westbury's Act. The result of his investigations was that he was convinced of the utility and public importance of a register or record of indefeasible titles. When asked by the Viceroy (the Earl of Kimberley) whether the new office for recording indefeasible titles in Ireland, was likely to prove successful, his reply (as repeated by himself, on the following day, to the writer of this memoir) was decidedly in the affirmative.

In the first week of April, 1866, the Record of Title being fairly established, Judge Hargreave arranged to take charge of any judicial business to arise out of the new jurisdiction; but his last illness at once occurred, to put an end to the hopes founded on his tried ability in working out legal improvements. An eminent mathematician, writing of him, says:

"It is to be feared that his premature death must be imputed to his having chosen as his principal recreation one which only substituted one form of mental labour for another, and which gave his brain scarcely any rest from continuous exertion."

He never published any legal treatise, but his mathematical essays are numerous. For one of the earliest of them, "On the Solution of Linear Differential Equations," the gold medal of the Royal Society was conferred on him, and he shortly afterwards became a Fellow of that distinguished body. Other papers, chiefly contributed to the "Philosophical Transactions," were "On General Methods in Analyses for Resolution of Linear Equations in Finite Differences, &c.," 1850; and “On the Problem of Three Bodies," 1858. He also contributed the following papers to the London and Edinburgh Philosophical Magazine: "Notes on the Solution of Differential Equations," 1847; "Analytical Researches concerning Numbers," 1849; "On the Valuation of Life Contingencies," 1853; "On the Application of the Calculus of Operations to Algebraical Ex

pressions and Theorems ;" "On the Law of Prime Numbers," 1854; “On Differential Equations of the First Order," 1864. The honorary degree of LL.D. was conferred on him by the University of Dublin in 1852.

In the summer of 1865, Judge Hargreave's attention was again drawn to a new method of solving Algebraic Equations, and he commenced the essay on this abstruse question which may be regarded as the cause of his death. The essay is now printed, and it will have a singular interest for "pure mathematicians." For some time previously he had not enjoyed robust health, and his friends had, on this account, frequently endeavoured to withdraw him from the mathematical investigations which seemed to form his favourite occupation during the intervals of court business. Their efforts, however, were in vain. Constant thought and want of rest brought on exhaustion of the brain; and although after some days he rallied, and hopes of his recovery were entertained, a relapse followed, and he died on the 23rd of April, 1866, at Bray, in the county of Wicklow.

ART. IV.-CLERICAL AND LEGAL VIEWS ON RITUALISM.

The Church and the World; Essays on Questions of the Day. By various Writers. Edited by the Rev. ORBY SHIPLEY, M.A. London: Longman & Co., 1866.

THE above volume is, we presume, intended as a manifesto

from the party in the Church of England which calls itself Catholic. The essays relate to a great variety of subjects, but they have all more or less directly one tendency, and are all obviously meant to support one set of opinions. The subjects treated of are principally theological and ecclesiastical, and if not discussed in a strictly judicial manner, the views of the