buildings shall have all the stairs and the floors of all passages, &c., of fire-resisting material, and that the stairs should be ventilated on every storey by windows or skylights opening directly into the external air (this must be read with Section 34 as to size of air shafts). These provisions are very proper to be applied to all the public parts of the building, but are not necessary, and will be the cause of much difficulty in the private stairs and passages used, for instance, by the housekeeper. The district surveyor should be allowed to use his judgment, and permit a relaxation of the rules in these parts.

Section 57. (Lifts to be enclosed with brickwork 9 inches thick, and the door openings to same to have solid selfclosing iron doors.) These are very severere strictions for the City-the brick enclosure especially so. Is an open well staircase enclosed by a grille, so as to hold a lift, a cause of greater risk in case of fire than the same staircase entirely open? And as to self-closing doors, which I presume are to be imperforate, I imagine the sliding Bostwick gates will still be used, and the solid self-closing iron door fastened back, open all day; if so, who is to see that it is closed at night? I know a public building erected 27 years since where several sets of iron doors were insisted on by the district surveyor, because the cubic contents of the building were so large. The doors have never been closed for over a quarter of a century. The surveyor's demands were absurd, as the building is actively used and the operations therein in full swing day and night.

PART VII. Rights of Building and Adjoining Owners. -It is doubtful whether so much alteration is desirable as is contemplated by the Bill. The provisions of the existing Act have worked with wonderful smoothness on the whole; with a few necessary alterations they might be allowed to remain. The provision of an umpire-surveyor at

once turns the proceedings of the surveyors appointed by the owners to settle disputes into an arbitration, and will bring them under the Arbitration Act, so that a good many of the regulations of the Bill, whether old or new, must be read with that Act, and even if the Bill do not conflict with it and other existing Acts, the law will be somewhat complex. The present arrangement of one surveyor, or three surveyors, such one, or two of such three, to make the award, has answered very well, and need not be altered. Nevertheless, some amendment is required. If, as has been held, every sub-lessee occupying, or entitled to possession of, any part of the adjoining premises is entitled to notice, then he is entitled to appoint a surveyor, so that there may be several sets of three surveyors all adjudicating and making inconsistent awards as to different portions of the same wall. This requires alteration, but the Bill does not touch the point. A further matter for consideration is as to questions of differences which arise after the award has been made, such as those respecting the account of the cost referred to in Section 82, and many others which arise in practice. Are the surveyors functus officio after they have made the award, and have the parties to go through the form of again appointing surveyors to settle such after-questions, or can they be determined by supplementary awards of the original surveyors? What is a "surveyor" for the purposes of this part of the Act or Bill? Can an owner appoint himself as his own surveyor in either case, whether he be a surveyor or whether he be not one? Can an owner appoint a builder as his surveyor? I would suggest the attention of the framers of the Bill to these questions.

Section 72, Sub-section 6, gives a building-owner, at any time after expiration of a month's notice, if the adjoining owner consent, a right to project footings and concrete foundation on the land of the adjoining owner. There

should be some limit of time for the exercise of this right; "at any time after" is extremely wide. As the Bill stands, the owner who may build on the verge of his land must have projecting footings on both sides of his wall, and, in some cases, projecting concrete; so that if he do not get the consent of the adjoining owner, or there be not an adjacent wall, he must set back his wall to obtain space for projecting the footings, &c. Where there is an adjacent wall the footings of the new wall abutting thereon may be omitted on that side. Query, whether this provision should not be extended to concrete also, and to new walls abutting on adjacent land where there is no adjacent wall; but the concrete so omitted should be extended on the buildingowner's side, and on that side it is desirable, for purposes of stability, that the footings should be of double width and double height.

Section 73. The present Act, Section 83, gives similar rights to this Section 73 of the Bill, viz., inter alia to pull down and rebuild party structures not in conformity with the regulations of the Act, and to rebuild the same in conformity therewith, charging a portion of the expenses on the adjoining owner. But the Act has a proviso which the Bill omits, that all such structures shall be deemed to be conformable with the Act if they are conformable with the two previous Building Acts. The omission of this proviso from the Bill may be the cause of great hardship and injustice, with regard to contribution of expenses, to owners of comparatively new walls. I would suggest that a proviso be inserted in the Bill, that buildings which are conformable with the provisions of the present Building Act shall, for the purposes of this part of the proposed new Act, be deemed to be conformable with the regulations of the proposed new Act.

Section 75, Sub-sections 1 and 8. There appears to be some discrepancy between these two sub-sections as to time

of notice for works to party walls: in one place it is two months, in the other three. Sub-section 4 limits the right to do works to a party wall to six months after service of the three months' notice. This limit of time is rather short: it should be six months after the expiration of the three months' notice, as frequently, in the absence of consent, the first three months is taken up in obtaining the award, without which the building owner has no rights.

Section 78 provides compensation to be paid by building owners to adjoining owners and occupiers for inconvenience as well as for damage occasioned by underpinning, and is crudely drawn. It is doubtful whether it is advisable to provide for such compensation in cases of underpinning only, whilst other operations of a far more serious nature, such as rebuilding the whole wall, carry no such liability. The best way of dealing with this section is to delete it; it can be readily evaded by those who choose to take the trouble of carefully reading the Bill as a whole.

Section 79. (Security to be given by building owner to adjoining owner, and by adjoining owner in certain cases to building owner.) This section is adopted from the present Act, but no provision is made in the Act or in this Bill to determine either the nature or sufficiency of such security.

PART X., Section 102, forbids building on certain lowlying lands without the consent of the London County Council. The building of dwellings which cannot be efficiently drained should, no doubt, be prohibited. There is, very properly, an appeal from the decision of the Council. Seeing that they are interested in purchasing such lands for recreation grounds, or aiding vestries to do so, it would be placing a most dangerous engine of depreciation in the hands of a would-be purchaser, were this appeal not provided. Those interested should keep a sharp look-out that the appeal clause is not quietly dropped.

PART XIII., to a very large extent, gives the Council power to repeal and amend the Act, by means of by-lawsand without further recourse to Parliament. This is a most unsatisfactory method; most of us would prefer to have the legislative and administrative functions kept always in separate hands. By this Part the penalties for infringement of the provisions of the proposed Act, and the by-laws to be made under it, are mostly more than doubled, and are made uniform, viz., not exceeding £50, and £5 per day for continuing the offence.

Section 136. Publication of By-laws.-I would suggest that, as well as exhibition at the principal office of the Council, they should be exhibited at the principal offices of the Metropolitan District Boards of Works and Vestries.

PART XIV. Tribunal of Appeal.-I am delighted to find here a proposal to extend the functions of the Tribunal, and wish that all matters now heard before police magistrates could be taken before such building magistrates as are here proposed. It is related of the late Lord Chief Justice COCKBURN that he said the builders made the Building Act, and they had better construe it, for he could not. The police magistrates often take a similar view.

Section 155. The Council are to fix the remuneration of the members of the Tribunal, with the approval of the Treasury. As the Council will be party to every case, it would be more decent if they had nothing to do with the remuneration of the Tribunal.

PART XV., Section 171. Plans, &c., submitted to the Council are to be retained by them. There should be a provision permitting those who submit the plans to take copies at the offices of the Council.

Section 174 provides that, if a contract for the construction of a building be made before the proposed Act becomes operative, the work is to be carried out with the