STRANGE (Elizabeth Jane), Blandford, Dorset. March 9; Trevanion and Curtis, Poole. SMITH (Georgina Blanche), South Croydon. Feb. 18; Peard and Son, Croydon. SHEPHARD (George Westerman), Crouch Hill. Feb. 23; Windsor and Brown, 228, Bishopsgate, E.C. STACE (Richard), St. Leonards-on-Sea. March 1; Menneer, Idle, and Brackett, St. Leonards-on-Sea. SULLIVAN (Alfred), Balham. March 1; Taylor, Willcocks, and Co., 240, Lavender-hill, S.W. SPIERS (Solomon), West Hampstead. Feb. 19; Adler and Perowne, 46/47, London Wall, E.C. 2. SLACK (Percy), who practised in partnership with Edwin Joseph Ling as medical practitioners under style of Slack and Ling at Rotherham, and who died (thus dissolving the partnership) on Nov. 7, 1924. Claims either against the estate of the deceased or the aforesaid firm. Feb. 23; Oxley and Coward, Rotherham. TOWNSLEY (Samuel), Whitehaven. Feb. 3; J. G. Tyson, Whitehaven. TORR (Rev. Canon William Edward), Eastham. Feb. 28; Morecroft, Sproat, and Killey, Liverpool. TODMAN (George Frederick), Sydney, New South Wales. Feb. 28; Light and Fulton, 1, Laurence Pountney-hill, E.C. 4. TYE (William Kibbler), who traded under style of "W. Tye and Son." Redditch. Feb. 28; Browning and Co., Redditch. TYNDALL (Mary Lilian), Plymouth. Feb. 28; A. B. Bone and Son, Devonport. Tower-st, E.C. 3. WILSON (William Thomas), Heightington, Rock. Morton, Kidderminster. March 6; Eyres and Whitty, Feb. 17; Ivens, Morton, and WHITELEY (Eli), Halifax. Feb. 23; L. I. Dey, Halifax. WHITLIE (Benjamin), Newcastle-upon-Tyne. WAECHTER (Sir Max Leonard, Kt.), Richmond, Surrey. Feb. 20; Powell, Rogers, and Merrick, 17, Essex-st, Strand, W.C. 2. WILKIE (Frances Weston), Newquay, Cornwall. Feb. 27; Batchelor and Cousins, 2, Pancras-la, E.C. 4. WESTERMAN (George), Ossett. Feb. 23; A. M. Lawrence and Son, Ossett, Yorks. WATSON (John Edward), Marsh, Huddersfield. Feb. 9; Hirst, Smailes, and Downey, Huddersfield. WRAGG (Martha Annie), Ranmoor, Sheffield, and Hope Cove, Devon. Feb. 28; Watson, Esam, and Barber, Sheffield. WEST (Annie Alderton), Bromley, Kent. March 1; Atkey and Son, 12, Parkpl, St. James'-st, S.W. 1. WEST (Emily Elizabeth), Bromley, Kent. Park-pl, St. James's-st, S.W.1. March 1; Atkey and Son, 12, WILSON (John Muter), Withington. March 2; Deputy Public Trustee, Albertsq, Manchester. Sols. Minor and Co., Manchester. YOUNG (Arthur), Verulam-bldgs, Gray's-inn, W.C., and West Kensington. Feb. 23; J. W. Hives, 5, Verulam-bldgs, Gray's-inn, W.C. 1. BANKRUPTS THE BANKRUPTCY ACT 1914. BARNES, HENRY, Lewisham, builder. Ct. Greenwich. Jan. 20. BLAKE, CHARLES DUNKIN, St. Annes-on-the-Sea, secretary of a private company. COTTERILL, ELIZABETH, Stalybridge, grocer. Ct. Ashton-under-Lyne and Stalybridge. Jan. 20. CROSSMAN, WILLIAM BOARD, Bridgwater, grocer. Ct. Bridgwater. Jan. 20. CAPES, WILLIAM SMITH (trading as W. S. Capes and Co.), Kingston-upon-Hull, FIDDY, JOHN, Wallingford, butcher. Ct. Oxford. Jan. 19. FIELD, KING, Plymouth, watchmaker. Ct. Plymouth. Jan. 19. Ct. GARDNER, EDWARD STANLEY THOMAS, Guest Moor, smallholder. Ct. Leominster. Jan. 19. GUDGEON, ALICE MAUD MARY (trading as Gudgeon and Co.), Northwich, motor agent. Ct. Nantwich and Crewe. Jan. 21. HOLMES, JOSEPH, Norwich, vulcanizer. Ct. Norwich. Jan. 21. HADLEY, HARRY, Merthyr Tydfil, sports outfitter. Ct. Merthyr Tydfil. Jan. 19. HAYMAN, WILLIAM ALBERT, Liverpool, tobacconist. Ot. Liverpool. Jan. 19. HIELDS, THOMAS ALBERT, Leeds, late hairdresser. Ot. Lincoln and Horncastle. Jan. 19. HUGHES, WILLIAM (trading as W. Hughes and Son), Farnborough, corn merchant. Ct. Guildford. Jan. 20. HUDSON, JAMES VICTOR, late Goole, Humber pilot. Ct. Great Grimsby. Jan. 21. HORSFALL, SQUIRE ERNEST, Todmorden, blacksmith. Ct. Burnley. Jan. 19. HENLEY, RONALD NORTHINGTON, Arcade-house, Hampstead. Ct. High Court. Jan. 14. JONES, ARTHUR MELVILLE, Kenfig-hill, coal dealer. Ct. Bridgend. Jan. 19. KAPOVITCH, A. MORRIS (trading as A. Morris), Lambs Conduit-st, fruiterer. Ct. High Court. Jan. 20. KING, ALBERT EDWARD (trading as Bert King), Newport, charabanc proprietor. Ct. Newport (Mon.). Jan. 20. LILLEY, THOMAS ARTHUR, late Wollaton, sub-postmaster. Ct. Nottingham. Jan. 20. MOSS, WILLIAM HENRY, Boston Spa, journeyman butcher. Ct. Harrogate. Jan. 20. MIDDLETON, LEICESTER, Warwick, builder. Ct. Warwick. Jan. 19. MASON, JOHN (late trading as the Hillside Burling and Mending Company), PHELPS, HERBERT HOWELL, Pontypool, ironmonger. Ct. Newport (Mon.). Jan. 19. PRATT, ERNEST FRED A., Henley-on-Thames, builder. Ct. Reading. Jan. 17. PARKER, HERBERT HOLLAND, Liverpool, stationer. Ct. Liverpool. Jan. 19. RYAN, THOMAS HAMPTON, Lyminge, auctioneers' clerk. Ct. Canterbury. Jan. 21. RANDELL, S., Askew-rd, Shepherd's Bush. Ct. High Court. Jan. 15. Ct. Liverpool. Jan. 21. SAXBY, LEONARD (late trading as Saxby and Co.), New Cross-rd, coal merchant. Ct. Greenwich. Jan. 20. STRIBLEY, JOHN HORACE, Kendal, sports coat manufacturer. Ct. Kendal. Jan. 19. THORNTON, WILLIAM GEORGE, Willey. Ct. Leominster. Jan. 20. TORN, GEORGE W., Thorpe-on-the-Hill, egg merchant. Ct. Lincoln and Horn- WOLFSON, WOLFE (otherwise known as Lazarus Wolfson), Leeds, tailor's manager. AHERN, THOMAS, Manchester, ladies' tailor. Ct. Manchester. Jan. 23. BIRKETT, DAVID, late Brocklesby, coal merchant. Ct. Great Grimsby. Jan. 22. BECKETT, H. GORDON (trading as the Provincial Touring Cinemas), Brighton, DORNAN, FREDERICK, late Worthing. Ct. Brighton and Lewes (at Brighton). FAYERS, W. SELBY, Birmingham, advertisement specialist. Ct. Birmingham. GRIGG, HARRY, Elgin-mansions, Maida Vale, director of a company. Ct. High Jan. 21. HANWAY RUBBER COMPANY, Arlington-rd, Mornington-cres. Ct. High Court. HOLLOWAY, JAMES (trading as Holloway and Knight), Bedford, motor engineer. HOPSON, ALFRED THOMAS, Filton, engineer. Ct. Bristol. Jan. 22. HILDRED, JOSEPH FREDERICK, Great Grimsby, late coal merchant. Ct. Great Grimsby. Jan. 22. JOHNSON, BENJAMIN, Oldham, grocer. Ct. Oldham. Jan. 23. JONES, WILLIAM RICHARD, late Capel Coch, farmer. Ct. Bangor. Jan. 24. JENNENS, LIONEL KERR, Devonshire Club, St. James-st, gentleman. Ct. High Court. Jan. 21. JONES, Rev. RUBEIN EUSTACE, Norwick-rd, Forest Gate, clerk in holy orders. KNAAP, ANTHONY, Park-pl, St. James. Ct. High Court. Jan. 21. LEGG, ANNIE EMILY (trading as J. D. and M. E. Slater), Bilston, grocer. Ct. LENNOX, GEORGE, Dunston, grocer's manager. Ct. Newcastle-upon-Tyne. Jan. 23. MANZ, JAKOB (late trading as Ever-Ready Spirit Measure Company), Charing Cross-rd, Swiss subject. Ct. High Court. Jan. 22. MARTIN, ALBERT EDWARD, Manchester, electrical engineer. Ct. Manchester. Jan. 24. MENNIM, FRANK (trading as the Jersey Street Manufacturing Company), Manchester, sheet manufacturer. Ct. Manchester. Jan. 22. MOXON, WALTER, Kingston-upon-Hull, motor 'bus proprietor. Ct. Kingston-uponHull and Patrington. Jan. 22. OLIVE, EDITH MAY South Shields, fish merchant. Ct. Newcastle-upon-Tyne. Jan. 19. PEARSON, JOHN, Marske-by-the-Sea, master joiner. Ct. Middlesbrough. Jan. 21. PLANT, ALBERT, West Hartlepool, painting contractor. Ct. Sunderland. Jan. 23. ROSE, BERTRAM GARDNER, Merthyr Tydfil, grocer. Ct. Merthyr Tydfil. Jan. 23. ROBINSON, WILLIAM PERCY, Maida Vale. Ct. High Court. Jan. 22. RUNGE, FRANK GATWOOD, Úxbridge-rd, motor engineer. Ct. High Court. Jan. 22. SHEINBERG, N., Scrutton-st, Finsbury, leather goods manufacturer. Ct. High Court. Jan. 22. SLIM, JOSEPH HOWARD, Leadenham, licensed victualler. Ct. Boston. Jan. 21. SCHOFIELD, HENRY (trading as H. Schofield and Co. and Gold Spoon Cereal Company), Burnley. Ct. Burnley. Jan. 22. SIDDLE, HANNAH (trading as Siddle and Holt), Bacup, milliner. Ct. Rochdale. Jan. 23. TUNGATE, DONALD GORDON, Leeds, manufacturers' agent. Ct. Leeds. Jan. 23. VALLELY, JAMES HENRY, Manchester, commission agent. Ct. Manchester. Jan. 22. WEBB, FRED, Hartpury, civil servant. Ct. Gloucester. Jan. 23. WHITE, DINAH LILLIE, Shepley, nursing home proprietress. Ct. Huddersfield. WESTWOOD, WILFRED, Pensnett, haulier. Ct. Stourbridge. Jan. 16. ADJUDICATIONS. GAZETTE, JAN. 23. AXE, GEORGE ARTHUR (trading as Axe and Wright), Sheffield, cutlery manufacturer. Ct. Sheffield. Jan. 17. BECKWITH, EDWARD, Doncaster, fruiterer. Ct. Sheffield. Jan. 19. COTTERILL, ELIZARETH, Stalybridge, retail grocer. Ct. Ashton-under-Lyne and CROSSMAN, WILLIAM BOARD, Bridgwater, grocer. Ct. Bridgwater. Jan. 20. DE RAIS-BOUILLON, LEON AMAND JOSEPH, DUKE OF CHATEAU-THIERRY (described in Rec. Order as H.S.H. the Duke of Chateau-Thierry), late Lower Belgravest. Ct. High Court. Jan. 20. EDWARDS, SAMUEL THOMAS (described in Rec. Order as S. T. Edwards), Watlingst. Ct. High Court. Jan. 21. EISLER, ROBERT, Romola-rd, Herne Hill. Ct. High Court. Jan. 20. · GARDNER, EDWARD STANLEY THOMAS, Guest Moor, small holder. Ct. Leominster. GUDGEON, ALICE MAUD MARY (trading as Gudgeon and Co.), Northwich, motor agent. Ct. Nantwich and Crewe. Jan. 21. HOLMES, JOSEPH, Norwich, vulcanizer. Ct. Norwich. Jan. 21. HUGHES, FRANK, St. Annes-on-Sea, estate agent. Ct. Manchester. Jan. 19. HADLEY, HARRY, Merthyr Tydfil, sports outfitter. Ct. Merthyr Tydfil. Jan. 19. HIELDS, THOMAS ALBERT, Leeds, late hairdresser. Ct. Lincoln and Horncastle. Jan. 19. HAYMAN, WILLIAM ALBERT, Liverpool, tobacconist. Ct. Liverpool. Jan. 19. HUDSON, JAMES VICTOR, late Goole, Humber pilot. Ct. Great Grimsby. Jan. 21. HUGHES, WILLIAM (trading as W. Hughes and Son), Farnborough, corn merchant. Ct. Guildford. Jan. 20. HORSFALL, SQUIRE ERNEST, Todmorden, blacksmith. Ct. Burnley. Jan. 19. JACKSON, MARGARET BEATRICE, late Elm-rd, Wembley. Ct. High Court. Jan. 21. LILLEY, THOMAS ARTHUR, late Wollaton, sub-postmaster. Jan. 20. Ot. Nottingham. MEREDITH, HERBERT HENRY, Hartpury, farmer. Ct. Gloucester. Jan. 19. MURRAY, OSWALD PERCIVAL (described in Rec. Order as Percival Murray), late REECE, RICHARD, Denton, coal merchant. Ct. Ashton-under-Lyne and Stalybridge. Jan. 21. RYAN, THOMAS HAMPTON, Lyminge, auctioneer's clerk. Ct. Canterbury. Jan. 21. ROBERTS, HENRY (late trading as H. C. Morton Michaels), Walsall, newsagent. Ct. Walsall. Jan. 17. RANDELL, SAMUEL (described in Rec. Order as S. Randell), Askew-rd, Shepherd's RAYMOND-MURRAY, GILBERT EVERARD (described in Rec. Order as Raymond STRIBLEY, JOHN HORACE, Kendal, sports coat manufacturer. Ct. Kendal. Jan. 19. WINSTANLEY, JAMES, Urmston, poultry farmer. Ct. Salford. Jan. 17. WILSON, EZRA (trading as E. Wilson and Sons), Halifax, coal dealer. Ct. Halifax. WOLFSON, WOLFE (otherwise known as Lazarus Wolfson), Leeds, tailor's manager. Amended notice substituted for that in Gazette, Aug. 15, 1924. LIPSCHITZ, MAURICE (described in Rec. Order as M. Louvain) (trading as M. and D. Ehrlich), Hounsditch, importers. Ct. High Court. Aug. 11. GAZETTE, JAN. 27. ARDERN, THOMAS REGINALD, Nelson, draper. Ct. Burnley. Jan. 23. BIRKETT, DAVID, late Brocklesby, coal merchant. Ct. Great Grimsby. Jan. 22. Jan. 22. Ct. Wakefield. Jan. 23. SCHOOLING, JOHN, Plough-rd, Battersea, baker. Ct. Wandsworth Jan. 22m2 DISNEY. On the 16th inst., Henry William Disney, Metropolitan Police Magistrate, of 8A, West Hill-road, S.W. 18. HENDERSON. On the 11th inst., at Toronto, Canada, Robert B. Henderson, K.C., aged 58. HOLMES. On the 6th inst, at Bodley, Parracombe, North Devon, Alfred Henry Holmes, solicitor, formerly of 32, King-street, Cheapside, London, E.C., and Amersham-road, New Cross, S. E., aged 83. HOPE. On the 20th inst., at Crix, Hatfield Peverel, Essex, Alice Therese, wife of Collingwood Hope, K.C. SHELLEY-THOMPSON.-On the 17th inst., at Westcliff-on-Sea, A. J. ShelleyThompson, barrister-at-law, Advocate and Solicitor, of the Straits Settlements and Johore. STOREY. On the 18th inst., at Southill, near Chester-le-Street, suddenly, Samuel Storey, D.L., aged 85. Jan. 23. Five lines of 30 words or less than 30 words in body type additional line (7 words) 0 5 0 0 1 0 Facing first text, whole page (and pro rata).. 16 0 0 Special pages (and pro rata) 15 0 Ordinary pages (and pro rata) 12 0 Per inch (front page).. Per inch (ordinary). 0 0 0.10 BARNES, JOHN DANIEL DE FOE, Putney. Ct. Wandsworth. Jan. 23. DAVIES, PERCIVAL LEOPOLD LAWRENCE (late trading as Richards and Co.), Barnes, estate agent. Ct. Wandsworth. Jan. 22. FIELD, KING, Plymouth, watchmaker. Ct. Plymouth. Jan. 24. GILBERT, JAMES HENRY, Aberystwyth, charabanc proprietor. Ct. Aberystwyth. Jan. 21. GREEN, ALFRED, Sproughton, small holder. Ct. Ipswich. Jan. 17. HILDRED, JOSEPH FREDERICK, Great Grimsby, late coal merchant. Ct. Great Grimsby. Jan. 22. HOPSON, ALFRED THOMAS, Filton, engineer. Ct. Bristol. Jan. 22. HOLLOWAY, JAMES (trading as Holloway and Knight), Bedford, motor engineer. Ct. Bedford. Jan. 24. HEYWOOD, FREDERICK WILLIAM SHEPHERD, late Palace Hotel, Bloomsbury-st, LLOYD, EVA AGNES, Highworth, farmer. Ct. Swindon. Jan. 24. MOXON, WALTER, Kingston-upon-Hull, motor 'bus proprietor. Ct. Kingstonupon-Hull and Patrington. Jan. 22. MENNIM, FRANK (trading as The Jersey Street Manufacturing Company), Manchester, sheet manufacturer. Ct. Manchester. Jan. 22. MORRIS, ISAAC LLYWELYN, Abereynon, doctor. Ct. Pontypridd, Ystradyfodwg and Porth. Jan. 24. OGDEN, ARNOLD EDGAR (trading as W. Ogden and Son), Preston, taxicab proprietor. Ct. Preston. Jan. 23. PEARSON, JOHN, Marske-by-the-Sea, master joiner. Ct. Middlesbrough. Jan. 21. PLANT, ALBERT, West Hartlepool, painting contractor. Ct. Sunderland. Jan. 23. ROSE BERTRAM GARDNER, Merthyr Tydfil, grocer. Ct. Merthyr Tydfil. Jan. 23. SIDDLE, HANNAH (trading as Siddle and Holt), Bacup, milliner. Ct. Rochdale. Jan. 23. Each coooo 0 8 0 Post-Office Orders payable to THE FIELD PRESS LTD. 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The copyright of all contributions (including reports paid for, shali belong to the proprietors of the LAW TIMES, together with the right of republication in any form they may think desirable. Apart from any express agreement that may be made, contributions are only received and considered on these conditions. THE JOURNAL OF THE LAW AND THE LAWYERS of twelve out of a jury of fifteen are all questions Trial by Jury AT the special general meeting of the Law Society, held on Friday last week, which we report in another column, it was resolved that the Council should consider, and if it be deemed expedient, report upon the system of trial by jury as at present conducted in this country.' Wide in scope but indefinite in expression, it seems a great pity that the motion was not framed in such a form that the meeting could define clearly and decisively their attitude with regard to this important matter. The chief question that will arise when the Administration of Justice Bill comes up for consideration is, Shall the right to trial by jury in civil causes as it existed before the War, be restored? And to that there can be one answer. The Act of 1920 and the Bills of 1923 and 1924 all contain a "discretion," to refuse a trial by jury save in the few enumerated actions. Both in the High Court and in the County Courts the pre-war rights of litigants must be restored and it must not be in the power of any court or judge to curtail that right. Apart Apart from this vital question there are many subsidiary matters concerning the jury system in civil cases to which attention might be profitably directed. At the present time the difference between the special and the common jury is inappreciable. Payment of jurors' reasonable expenses; the method of summoning; the majority verdict or the verdict Second Sheet well worthy of serious consideration. How far the council will deem it expedient to report we do not know. But this fact remains, that since the "discretion," under the Act of 1920 and the Rules, has been exercised more freely in favour of trial by jury, the special and common jury lists have largely increased. In the coming legislation, however, decision as to the "fitness" of the action must be for the litigants and not for the court. Delay in the Admiralty Court We fully appreciate the concern which shipping, commercial, and other interests feel at the congestion that now exists in the Admiralty Court, but this Division is merely feeling what has obtained in the King's Bench Division for years past, and is due to the parsimony shown by Parliament towards the appointment of an adequate Bench for the needs of the nation. At a recent meeting of shipping and commercial associations, including the Chamber of Shipping, Lloyd's, the Association of British Chambers of Commerce, the Federation of British Industries, and also the Law Society, a resolution was unanimously passed that- In the opinion of this meeting it is essential that two judges should give priority to the Admiralty work, and they should only be employed on other work when there is no immediate Admiralty work to be done. The committee that was formed to lay the position before the Government and Parliament has issued a letter to the Press in which they point out that "the President and one other judge are responsible for dealing with the whole of the work of this mixed Division--Admiralty, Divorce, and Probate." This is hardly correct, as, for a good many years, a King's Bench judge has been detailed for Divorce work in London, and for nearly eighteen months undefended and pauper divorce cases have been tried at assizes. We do not desire to dispute the statement that "It is essential that there should be two judges with special qualifications for Admiralty work always giving priority to Admiralty cases; there is no other way of avoiding delay. To do this the immediate appointment of an additional judge is required." But it must be remembered that in addition to the judge or judges dealing with Admiralty matters, the interests concerned are provided with continuous sittings in the Commercial Court presided over by another King's Bench judge; and again, that although the general common law work of the country may be reduced to absolute stagnation, the sittings of that court and of an Admiralty judge are always assured. The distinguished signatories to the letter may be amply justified in stating We are very proud of our court, which is so good that it has become almost an international court; ships of many nations resorting to it voluntarily for the decision of important collision actions. As we write, a collision between a Norwegian and a Spanish ship off the coast of South America is being tried there by agreement between the respective owners an instance typical of what is now quite common. But when all is said and done surely the British litigant has the right to prior consideration. It is quite impossible to deal piecemeal with the two Divisions of the High Court which are concerned with business disputes. Lord Cave was quite right when he pointed out in December last that the time has come for a committee to consider what the judicial staff of the King's Bench, and the Probate, Divorce, and Admiralty Divisions should be, and whether the present allocation of work between the Divisions is that which it ought to be. The whole root of the evil and avoidable delay in the administration of justice is a very great evil for the community---lies in the insufficiency of judges. A margin of safety is imperative, for illness is an ever-present risk, but is an easily insurable one. Law Society Centenary THIS year the Law Society completes its existence for 100 years, having been founded on the 2nd June 1825, pursuant to resolutions passed at a meeting of the Profession in the preceding March. We understand that it is proposed to hold a meeting to celebrate this notable event at the beginning of the Michaelmas Term, and should this be so, that time of the year will be well chosen. It would be naturally impossible to hold both the centenary and provincial meetings within the period of a few months, and their amalgamation in one great gathering in London, and that after the commencement of the sittings, should ensure a complete success. How far universal membership of the Society by all solicitors is possible remains to be seen, and it should not be beyond the realm of practical professional politics, but it must be brought about by general consent of the whole body of practitioners. BANKRUPTCY AMENDMENT THE Committee appointed by the Board of Trade" to consider and report what amendments of the Bankruptcy Act 1914 recent experience has shown to be desirable, more particularly in regard to the provisions for the discovery and punishment of offences,' of which Mr. E. W. Hansell was chairman, has now issued their report, and in addition to their recommendations for dealing more effectively with fraudulent bankruptcy, they make a few very useful suggestions for the amendment of the Act of 1914. We think that the committee is correct in its conclusion, that, apart from that portion of the statute which relates to criminal responsibility, in the main, the Bankruptcy Act 1914, and the procedure thereunder, have proved satisfactory. To deal first with the recommendations relating to the Act in general. It certainly would be of advantage if the law were altered so as to provide that the court shall pronounce on the discharge of every bankrupt on a date to be fixed as soon as may be after the granting by the Board of Trade of the trustee's release (unless the bankrupt has himself already applied for his discharge), but not later than two years after the close of the public examination, if the trustee has not been released by that time; the court to have the power to require the bankrupt's attendance at the hearing. The affairs of undischarged bankrupts should not be allowed to slip into the limbo of forgetfulness, but should be brought up for final judicial consideration. Also the existing statutory minimum period of suspension of discharge imposed by sect. 26 (2) (ii.) might well be abolished, leaving it to the court to exercise its discretion in each particular case. Two other recommendations relate to the amendment of sect. 39, which contains provisions as to second bankruptcies. It is suggested that the law should be altered by the insertion in sub-sect. (I.) of the words "which is followed by an order of adjudication after the words "receiving order"; and that all the modes of administration of the estate of a bankrupt or insolvent who has previously been bankrupt should be placed on the same footing, i.e., sect. 39 should be made to apply to a second or subsequent receiving order followed by the acceptance or approval of a composition or scheme and also where a prior bankruptcy is followed by an administration order under sect. 130 (administration of a deceased insolvent's estate), and with this there will be general agreement. It was fraudulent trading and bankruptcy, which has largely increased since the War, that caused the appointment of the committee, and, naturally, to the discovery and punishment of offences of this type, they directed principally their attention. It is not surprising that, with regard to the provisions of the Act relating to the discovery of offences, the committee are of opinion that no amendment is required. The present system of investigation of the conduct of a debtor is searching, and full powers already exist for thorough examination and discovery. With regard | to bankruptcy offences the committee summarise their recommendations as follows: Sub-sections (4), (5), (9), (10), (11), (12), (13), (14), and (15) of section 154 should be amended so as to provide that the acts and the defaults of a debtor, which by those subsections are made criminal offences, if done or committed within six months of the presentation of a bankruptcy petition by or against him, on which a receiving order is made, shall be made criminal offences if done or committed within twelve months before the presentation of such petition. The law should be altered so as to provide, either by a new sub-section to Section 154 or by amendment of Section 156, sub-section (b) (if not already sufficiently wide), that a collusive execution suffered or permitted by the bankrupt should subject him to liability to criminal proceedings. Section 158 should be amended so as to make failure to keep and preserve proper books of account criminal in the case of a first bankruptcy, subject to the following conditions: (a) The present proviso to sub-section (1) of Section 158 of the Act, with the substitution of five hundred pounds for one hundred pounds, should be retained as a protection to the honest retailer selling goods in the ordinary course of his business. (b) The law should further define the books to be kept, so that they shall include accounts of all goods sold and bought, and sufficient details of such goods, and of the buyers and sellers thereof, respectively to enable the goods and the buyers and sellers thereof to be identifiable. (c) No prosecution for this offence should take place before two years after the passing of the Act. The proviso to Section 161 should be repealed, and after the words in the section "if it appears to the court that there is a reasonable probability that the debtor will be convicted" there should be inserted the words "and that the circumstances are such as to render a prosecution desirable." Section 163 should be repealed. The law should be altered so as to give courts of summary jurisdiction power to inflict up to twelve months' imprisonment for a bankruptcy offence, instead of only six months as at present. The law should be altered so as to provide that as regards sub-sections (13), (14), and (15) of Section 154, the maximum punishment should be five years' penal servitude. The law should be altered so as to provide that it shall be a criminal offence to receive property unlawfully obtained contrary to the provisions of sub-sections (13), (14), and (15) of Section 154. The law should be altered to embody a provision regarding venue similar to that in Section 39 (1) of the Larceny Act 1916, which provides that "a person charged with any offence against this Act may be proceeded against, indicted, tried and punished in any country or place in which he was apprehended or is in custody as if the offence had been committed in that country or place and for any purposes incidental to or consequential on the prosecution, trial, or punishment of the offence, it shall be deemed to have been committed in that country or place." The only criticism we have to make upon these recommendations, which will be generally approved, relates to the amendment of sect. 158, defining the contents of the books to be kept. We are aware that under the proviso a person is not to be convicted "if he proves that in the circumstances in which he traded or carried on business the omission was honest and excusable," but retail cash sales should be provided for, especially as the section should rightly be extended to first bankruptcies. It was suggested that limitations should be placed on deeds of assignment as constituting acts of bankruptcy, but the committee considered that sect. 24 of the Deeds of Arrangement Act 1914 was sufficient, and no alteration of the law in this respect is required. Three other matters upon which evidence was given the committee considered outside the scope of their inquiry, but indicated their views thereon. They expressed themselves very sensible of the evils caused by the use of the "one man company " by the fraudulent trader; and considered that with proper limitations to exclude from its operation aliens who have been established in this country for a period of years, a power to recommend alien bankrupts for deportation would be useful. They also think that the subject of the registration of High Court judgments, on the lines which now obtain with regard to judgments in the county courts over £10, is worthy of consideration. With all of which we agree. No one can read the report without being impressed by the eminently judicial consideration that has been given to all evidence offered. Legislation in order to relieve traders from taking ordinary business precautions when credit is sought is clearly impossible, and other suggestions put forward by witnesses which might well have the effect of seriously interfering with the ordinary course of business were not accepted by the committee. THE CONVEYANCER Long Leases under the Rent Restrictions Acts SOMEHOW persons discussing these Acts regard every leaseholder as a tenant, but Lord Darling in Jenkinson v. Wright (132 L. T. Rep. 157; (1924) 2 K. B. 645) said: I cannot think that the test whether or not a person is the landlord of a dwelling-house depends upon whether he is the owner of the house in fee simple as opposed to the holder of a term of years. I have therefore come to the conclusion, there being a substantial portion of the term unexpired, that the plaintiff is a landlord within the meaning of the Rent Restrictions Acts." Apart from the strange fact that a long term of years is in the eyes of our law only a chattel, whereas the life estate of an old man of ninety is a freehold, and the long term could be merged in the latter, it would appear to anyone that the owner of a long leasehold interest is practically the owner of the property. For the sake of ensuring the observance of covenants it is better to let property for a term of 999 years at a large premium and a nominal rent than to sell the fee simple for a lump sum, but the lessee in effect owns the property. Under the provisions of certain Acts the leaseholder is treated as the owner. Jenkinson v. Wright the matter was slightly complicated by the fact that the purchaser of the long lease had mortgaged it and attorned tenant to the mortgagee at a peppercorn rent. This, according to the County Court judge, made the leaseholder a tenant of the mortgagee, but he must have forgotten sub-sect. 7 of sect. 12 of the Act of 1920 which provides that "where the rent payable in respect of any tenancy of any dwelling-house is less than two-thirds of the rateable value thereof, this Act shall not apply to that rent or tenancy." The sub-section was no doubt inserted to permit ground landlords who have been enjoying only a small ground rent to increase their rents when the ground lease expires or to recover possession, but it also applies where there is merely a peppercorn rent, so that even if the mortgagor were a tenant of the mortgagee she was entitled to possession of the premises. Settled Land-Tenant for Life-Possession In THE decision of Mr. Justice Russell in Re Earl of Stamford and Warrington; Payne v. Grey (158 L. T. Jour. 469) confirms the rule that a tenant for life is not entitled, as a matter of course, to be let into possession of the settled estate. It is a question for the court, in the exercise of its judicial discretion, having regard to the circumstances and taking into consideration whether that is the best way of dealing with the property. The facts will be found in our report. Suffice it to say that the life estate, in the case under notice, was subject to a term of 1000 years for paying off incumbrances. The trustees also had wider powers of management than those conferred on a tenant for life under the Settled Land Acts, including power, at their discretion, to contribute to charitable purposes, and to pay pensions and gratuities to servants and tenants of the estate. The learned judge held that the most beneficial way of dealing with the estate in question was to allow the trustees to continue to manage the same, and that the tenants for life should not be let into possession, but that they were entitled to exercise the powers conferred on a tenant for life by the Settled Land Act 1882. |