to the public interest. Mr. Coward rightly points out in his address that in cases against the Crown the conduct of officials generally arises, and that where errors have been committed officials are not likely, without a struggle, to produce documents which are calculated in any way to weaken their case or to hold them up to censure or criticism. It is undoubtedly true that in Scotland and in some of the Dominions, whether or not special privilege exists is decided by the court, and much more confidence would naturally be felt in the decision of an impartial judge than in the opinion of a Minister or the permanent or acting head of the implicated department. It is to be hoped, however, that the Bill will not be wrecked on this rock, and that the much-overdue amendment of the law with reference to litigation between Crown and subject will be proceeded with without undue delay. Juries and Conciliation On the first day of the meeting Mr. J. W. Pickles of Halifax read a paper dealing with "The Jury System, Its Cause and Its Cure." We are not deeply impressed by some of the so-called diseases of the jury system quoted by the author from Holdsworth's History of English Law, namely, the absence of individual responsibility, the absence of reasons for the jury's verdict, their liability to be affected by the popular prejudices of the moment, their liability to intimidation, and their alleged bias in cases where a pretty woman or a railway company is a litigant. The first two of these-the absence of individual responsibility and the absence of reasons for the verdicts may be well described as imaginary diseases, and rather go to make for the efficiency of this method of trial than the reverse. The other alleged diseases may exist to some small extent, but have always been unduly exaggerated. In fact, it is the presence of corporate responsibility and the nonadherence to individual conclusions that makes the jury the satisfactory tribunal that it is in deciding questions of fact, and that being so, it is manifestly impossible that reasons for verdicts should be given. Two other points are urged by Mr. Pickles against the existing jury system: first, the inclusion of women, and secondly, the discontented frame of mind that exists where a juryman has been taken from his business to serve in a jury-box. So far as the first objection is concerned, we think that the leavening of the jury by the inclusion of women has proved eminently successful; and also that when an ordinary citizen enters the jury-box he does his duty to the best of his ability, even although he may consider service on juries as a misfortune. Clearly the cure suggested by Mr. Pickles, namely, of having professional jurymen at salaries provided by the State, will not bear a moment's consideration. It shows a complete misunderstanding of the whole system of trial by jury, and has only to be stated to be dismissed. Mr. J. J. Sprigge's paper dealt with a public conciliation system, and although the sentiments contained therein are excellent, the suggestions made can hardly be described as practical. Intestacy and Coroners' Law MR. D. GWYTHER MOORE makes an analysis of the principal features of the New Code of Intestate Succession contained in Part IV. of the Administration Third Sheet of Estates Act 1925. He discusses what he describes as the fierce encounter between the Law of Inheritance and the Statute of Distribution, and, after holding an inquest on the defunct portion of our ancient laws, deals with some of the new features contained in the legislation of 1925. Mr. J. A. Howard-Watson, of Liverpool, in Modern Changes in Ancient Coroner's Law, briefly sketches the history of the ancient office of the coroner; the scope of his duties, authority and privilege; and recent changes and reforms to bring it up to date with present-day requirements of efficiency with reasonable expedition. Company Law ON the second day of the meeting two papers were read of very considerable interest. In The Contemplated Changes in Company Law, by Mr. Charles L. Nordon, the author dealt with the Companies Bill 1927, and drew attention to the important changes thereby proposed, whilst indicating, in passing, other requirements that might usefully be introduced at the same time. We quite agree that the Bill introduces reforms of the greatest value, but more convenient arrangement of sections, and ease of reference, is undoubtedly necessary. We are to have a consolidating Bill after the present proposals have been placed on the Statute Book, and Mr. Nordon says: "a busy lawyer will find it highly inconvenient that the Act, consisting in its Bill form of 105 sections, is to be grafted by interlineations, substitution and addition upon the Companies (Consolidation) Act 1908, which consists of 296 sections." It is difficult to see how a company law code could be otherwise created, and, indeed, Mr. Nordon goes on to say: The only way to understand and fully appreciate the bearing of the forthcoming legislation is to take the 1908 Act and laboriously write against each clause the alterations or additions to be made by the new Act." And this is exactly what will be done, for under the Bill of 1927 it is provided that, except in the case of the "share-hawking" clauses, when the Bill becomes an Act it is not to come into operation except by Order in Council, and this provision naturally was inserted for the purpose of including the new and existing law in one measure. We, however, quite agree with Mr. Nordon that the arrangement of the subject-matter is unsatisfactory. At the present time the law on any particular point has to be sought from sections widely separated both in the principal and amending Acts, and no good reason whatever exists why, when the new consolidating Bill is introduced, great care should not be given to the arrangement of the subject-matter. Mr. Nordon has done well to draw attention to this point. The Property Acts THE Concluding paper of the meeting was read by Mr. Harold Potter, who is Reader in Law at the University of Birmingham, and who took for his subject Some Decisions on the Property Acts. It is a valuable contribution to the literature on the new legislation, and although it is not claimed to be exhaustive, the chief decisions on Trust for Sale and on Settlements under the Settled Land Act are carefully considered, and in what manner their application may affect conveyancers is discussed. ASSENTS ONE of the main objects of the draftsmen of the new real property legislation was to simplify the title to real estate and so to faci itate dealings in land. The means devised to this end was to keep beneficial interests off the title of the property. Under sect. 10 of the Law of Property Act 1925, where title is shown to a legal estate in land, it is no longer necessary or proper to include in the abstract of title any instrument relating only to interests or powers which will be overreached by the conveyance of the estate to which title is being shown. To carry out this scheme of simplification a radical alterat'on was introduced in dealing with land on death. In investigating a title, where the estate is traced through a deceased person, the purchaser is no longer concerned with the beneficial title to the estate. The grant of probate or of letters of administration, and an assent from the persons who are named in the grant as the personal representatives of the deceased is all that a purchaser need consider, and all that need be abstracted. The assent has become the vital link in a title traced through a deceased person. On it the purchaser can rely without investigating the will once he has seen the probate. A valid assent has thus assumed a new importance and its form and proper execution have been radically altered. Under the Land Transfer Act 1897, s. 3, a personal representative could assent by parol or by conduct to the legal estate vesting in the beneficiary interested. This power to assent informally to the vesting of the legal estate involved a purchaser in difficulties. He had, firstly, to assure himself who were the persons who were beneficially entitled to the property; and, secondly, to discover whether there had been such an assent as would operate to pass the legal estate from the personal representative. If there had been such an informal assent and the personal representative made title to the property by mistake the legal estate did not pass: (Wise v. Whitburn, 130 L. T. Rep. 655 ; (1924) 1 Ch 460). The position has been radically altered by the Administration of Estates Act 1925. Sect. 36 (7) of this Act provides that: "An assent or conveyance by a personal representative in respect of a legal estate shall, in favour of a purchaser, unless notice of a previous assent or conveyance affecting that legal estate has been placed on or annexed to the probate or administration, be taken as sufficient evidence that the person in whose favour the assent or conveyance is given or made is the person entitled to have the legal estate conveyed to him, and upon the proper trusts, if any, but shall not otherwise prejudicially affect the claim of any person rightfully entitled to the estate vested or conveyed or any charge thereon." The effect of this section is to give a purchaser from a person in whose favour an assent has been executed a practically unimpeachable title. The purchaser is not concerned to see that the person in whose favour the assent was executed was entitled to the property in equity. The assent is itself proof of the transaction's validity. For an assent to be such an effective document it must fulfil the requirements of sub-sect. (4), which provides that: an assent to the vesting of a legal estate shall be in writing, signed by the personal representative, and shall name the person in whose favour it is given and shall operate to vest in that person the legal estate to which it relates; and an assent not in writing or not in favour of a named person sha!! not be effectual to pass a legal estate. Under sub-sect. 5, a person in whose favour an assent has been executed has a right to have notice of the assent endorsed in the probate. Unless such a notice is annexed to the probate, if the personal representative states in writing that no assent has been made, a purchaser gets as good a title as if no previous assent had been made. Endorsement of notice on the probate is, therefore, an essentia step in safeguarding the assent, and if such notice is made, the assent as against a purchaser cannot be impugned. Such an assent must under sect. 2 (2) of the Act be signed by all the executors who prove the will. An assent under subsect. 2 relates back to the date of the death of the estate owner. There is now no means other than an assent in writing under sect. 36 of the Administration of Estates Act, or a conveyance for passing the legal estate in a deceased's property to those beneficially entitled to it; and if such an assent is not executed by an administrator in his lifetime, before the beneficiaries can deal with the property, a grant de bonis non will have to be · obtained, and the new administrator will have to assent in accordance with the formalities of the Act. Though an assent is in favour of a purchaser conclusive, it is not so when made in favour of a beneficiary. Under subsect. (9) the personal representative or other persons interested can recover the estate or interest to which the assent or conveyance relates, or can claim to be indemnified out of such estate against any duties, debt, or liability to which such estate would have been subject if there had not been any assent or conveyance. Under both sects. 26 and 27 of the Trustee Act 1925 a power is reserved to a grantor, lessee, or other person interested to follow the assets which the personal representative has properly distributed under the sections, and to assert any rights he may have. The assent confers an absolute title only in favour of a purchaser. As against a beneficiary in proper circumstances the transaction can be reopened. Further, a personal representative has under sub-sect 10 of sect. 36 power to require security for the discharge of any duty, debt, or liability as a condition of giving an assent or of making a conveyance. The form of the assent varies with the nature of the persons in whose favour it is made. As a purchaser is not concerned with the beneficial title to the property, the assent should contain no recital of the title of the devisee, but only of that of the deceased and of the state of the executorship. Forms of assent in favour of an absolute owner, and in favour of trustees for sale are Nos. 8 and 9 in Sched. V. of the Law of Property Act 1925. Where the land is settled land, the assent must contain all the requirements specified in sect. 5 of the Settled Land Act 1925, as being necessary for the validity of a principal vesting deed. A specimen of such a principal vesting assent is form No. 5 in Sched. I. of that Act. Where the persons or person beneficially entitled is an infant, the land is settled land, and the personal representatives can either retain the property and manage it under the powers conferred by sect. 39 of the Administration of Estates Act, or they may assent to its vesting in the trustees of the settlement under sect. 26 of the Settled Land Act. If the beneficiaries are tenants in common, the personal representative should assent to the land vesting in the trustees of the will for the purposes of the Settled Land Act, if any, and if there are no such trustees, they should assent to the property vesting in themselves upon the statutory trusts: (see the Law of Property Act, s. 34.) Where the land is registered land, the assent must be in the form prescribed by the Land Registration Act 1925, s. 41 (4). Sect. 36 of the Administration of Estates Act only applies to land; the old law therefore remains as to assents dealing with pure personalty. An assent subject to a condition subsequent still cannot be given in the case of personal estate; and such estate can only be safely distributed if the personal representative is satisfied that he is retaining sufficient assets to meet the deceased's debts and liabilities, or if he has given the notices mentioned in sect. 27 of the Trustee Act, when he can distribute and leave any persons of whose claims he had no notice to follow the assets after distribution. THE CONVEYANCER Acknowledgment of Right to Production of Probates and Letters of Administration THE practice as to giving a purchaser the usual statutory acknowledgment of right to production of probates of wills or letters of administration does not seem to be settled. Further, the law on the subject is doubtful. Until the passing of the New Law of Property Acts no such acknowledgment could be required, as those documents are matters of record. But by sect. 36 (5) of the Administration of Estates Act 1925 it is provided that “ any person in whose favour an assent or conveyance of a legal estate is made by a personal representative may require that notice of the assent or conveyance be written or endorsed on, or permanently annexed to the probate or letters of administration, at the cost of the estate of the deceased, and that the probate or letters of administration be produced, at the like cost, to prove that the notice has been placed thereon or annexed thereto." And sub-sect. (12) provides that sect. 36 applies to assents and conveyances made after the commencement of the Act, whether the testator or intestate died before or after its commencement. If, as is frequently, if not generally, the case, the General Conditions of 1925 are adopted, the purchaser can only require such an acknowledgment when the probate or letters of administration are granted after 1925, but in the absence of a special condition it seems reasonable that the acknowledgment should extend to all probates or letters of administration under which the purchaser immediately derives title. In Wolstenholme and Cherry's Conveyancing Statutes, i 11th edit., p. 784, note, it is suggested that the words "granted after 1925 in the thirty-fourth General Condition might be struck out, as under the aforesaid sect. 36 of the Administration of Estates Act 1925 notices of assents and conveyances will be endorsed on the grant, whether it is granted before 1926 or after 1925, though the obligation to endorse only applies to assents and conveyances made after 1925. It must be borne in mind, however, that before the New Law of Property Acts notices of legal proceedings and other matters affecting the estate were frequently endorsed on probates, nevertheless an acknowledgment of right to production of them could not be required. Capital Money-Conversion 66 It will be remembered that prior to the Settled Land Act 1925 a declaration that personalty should devolve on persons successively as real estate was not effective, and a bequest of personalty on trust for sale, and to hold the net proceeds upon the trusts and in the manner upon and in which the same would be held and applicable if they had arisen from a sale of freehold hereditaments devised by the same will in settlement under the Settled Land Act " was not an imperative trust to buy land. Therefore in such a case the tenant in tail of the freeholds took an absolute interest in the personal estate so settled (Re Walker; Macintosh v. Walker, 99 L. T. Rep. 469; (1908) 2 Ch. 705; and see Aspinall v. Aspinall, 113 L. T. Rep. 1195; (1916) 1 Ch. 15; and Re Twopenny's Settlement; Monro v. Twopenny, 130 L. T. Rep. 816; (1924) 1 Ch. 522). This, however, is no longer So. Sect. 78 of the Settled Land Act 1925 (as amended by the Law of Property (Amendment) Act 1926) provides that "where money or securities or the proceeds of sale of any property is or are by any instrument coming into operation either before or after the commencement of this Act directed to be held on trusts declared by reference to capital money arising under this Act from land settled by that instrument or any other instrument, the moneys securities or proceeds shall be held on the like trusts as if the same had been or represented money which had actually arisen under this Act from the settled land." This sub-section operates without prejudice to the rights of any person claiming under a disposition for valuable consideration of any such money securities or proceeds made before the commencement of this Act. And sect. 75 (5) shows how money which has actually arisen from settled land is to be treated by providing that " capital moneys arising under this Act while remaining uninvested or unapplied, and securities on which an investment of any such capital money is made shall for all purposes of disposition, transmission and evolution be treated as land, and shall be held for and go to the same persons successively, in the same manner and for and on the same estates interests and trusts as the land wherefrom the money arises would, if not disposed of, have been held and have gone under the settlement." It will be observed that sect. 78 is retrospective, without prejudice to the rights of persons claiming under { dispositions for valuable consideration made before the commencement of the Act. Conveyances by a Tenant for Life, subject to a Mortgage affecting the Fee Simple UNTIL the passing of the Settled Land Act 1925 there was a difference of opinion as to the proper way of dealing with the purchase money when property, which was subject to a mortgage in fee simple, was sold by the tenant for life of the equity of redemption. Some practitioners thought that the purchase money, or part of it, according to circumstances, could be paid direct to the mortgagee by direction of the tenant for life, while others thought that the whole purchase money ought to be paid to the trustees of the settlement, they paying the same, or part of it as may be, to the mortgagee. In Re Norton and Las Casas (100 L. T. Rep. 885; (1909) 2 Ch. 59) it was decided by Mr. Justice Neville, that under such circumstances as aforesaid the purchaser was not justified in paying his purchase money direct to the mortgagees by the direction of the tenant for life, and that the purchaser could only get a good discharge by paying his purchase money to or by the direction of the trustees, or into court, and that the absence of such a discharge would prevent the purchaser from making a good title upon a subBut sect. 21 of the Settled Land Act 1882 sequent sale. directs that capital moneys arising under the Act subject to payment of claims properly payable thereout, and to the application thereof for any special authorised object for which the claim was made, shall when received be invested or otherwise applied as therein mentioned. That section seems to justify the direct payment to a mortgagee of the inheritance of the amount due on the mortgage. No doubt sect. 22 (1) of the Act provides that capital money arising under the Act shall, in order to its being invested or applied, be paid either to the trustees or into court, but the land is settled subject to the mortgage, therefore the property subject to the settlement is the equity of redemption, which alone the tenant for life can sell. At any rate, if the whole of the purchase money is paid to the trustees they can apply it, or part of it, as the case may be, in discharge of a mortgage on the fee. A form of conveyance of the kind will be found in the Encyclopædia of Forms and Precedents, 1st edit., vol. 12, p. 712. The question will not arise in future, as sect. 95 of the Settled Land Act 1925 provides that "the receipt or direction in writing of or by the trustees of the settl ment, or where a sole trustee is a trust corporation of or by that trustee, or of or by the personal representatives of the last surviving or continuing trustee, for or relating to any money or securities paid or transferred to or by the direction of the trustees, trustee, or representatives, as the case may be, effectually discharges the payer or transferor therefrom, and from being bound to see to the application, or being answerable for any loss or misapplication thereof, and in case of a mortgagee or other person advancing money from being concerned to see that any money advanced by him is wanted for any purpose of this Act, or that no more than is wanted is raised." That section enables the trustees of the settlement to direct how the purchase money shall be applied under the circumstances hereinbefore referred to. LAW LIBRARY BOOKS RECEIVED McKendrick on Medico-Legal Injuries. Edward Arnold and Co., 41 and 43, Maddox-street, W. 1. Price 18s. net. Needham's Annual Summary of Tax Cases 1926. Vol. 4. Gee and Co. (Publishers) Limited, Kirby-street, Hattongarden, E.C. 1. Price 10s. 6d. net. Pilgrim Scrip: More Random Reminiscences. By the Right Hon. Sir John Ross. Herbert Jenkins Limited, 3, York-street, St. James's, S.W. 1. Price 18s. net. Allen on Law in the Making. Oxford University Press. Amen House, Warwick-square, E.C. 4. Price 21s. net. Misleading Cases. By A. P. Herbert. Methuen and Co. Limited, 36, Essex-street, W.C. 2. Price 5s. English and Empire Digest. Vol. 35. Butterworth and Co. (Publishers) Limited, Bell-yard, Temple Bar, W.C. 2. Reports of Tax Cases. Vol. 12, Part 11. H.M. Stationery Office, Adastral House, Kingsway, W.C. 2. Price 1s. net. CRIMINAL LAW BOROUGH QUARTER SESSIONS Abingdon, Thursday, Oct. 20, at 11.30. Berwick-upon-Tweed, Friday, Oct. 21. Bridgnorth, Wednesday, Oct. 5, at 10. Bury St. Edmunds, Monday, Oct. 10. Carlisle, Wednesday, Oct. 12, at 10.30. Chichester, Thursday, Oct. 6. Croydon, Thursday, Oct. 27, at 10.30. Derby, Thursday, Oct. 13, at 10. Huddersfield, Thursday, Oct. 6, at 10.30 King's Lynn, Thursday, Oct. 20. Kingston-upon-Hull, Tuesday, Nov. 22. Lincoln, Saturday, Oct. 15, at 10. Liverpool, Thursday, Oct. 6. Ludlow, Friday, Oct. 21. Maidstone, Saturday, Nov. 26. Merthyr Tydfil, Wednesday, Nov. 2. Newark, Monday, Oct. 10. Newcastle-under-Lyme, Friday, Oct. 7. Plymouth, Friday, Oct. 7. Portsmouth, Tuesday, Oct. 4, at 10. Richmond (Yorks), Tuesday, Oct. 11, at 12. Rochester, Thursday, Nov. 10. Rotherham, Friday, Oct. 7. Saffron Walden, Wednesday, Oct. 12. LEGISLATION THE PARLIAMENTARY RECORD In the early days of February the third session of the present Parliament was opened with the customary pageant, and it found itself at once faced with difficulties of great magnitude alike in foreign and home affairs. The entry of Germany into the League of Nations was a bright spot in the furtherance of more normal relations with our neighbours, but on the other hand the anti-British agitation in China had compelled the authorities to send overseas adequate forces, and there were raised at once strong objections to this decision. Turning to more domestic issues, the session commenced and continued almost without interruption in the atmosphere of distrust occasioned by the great industrial upheavals of last year. These events demanded legislation open to grave controversy, but as the year progressed it became increasingly evident that there was behind the policy of the Government a considerable volume of support on the part of those whose industrial interests were primarily concerned. The Speech from the Throne adumbrated, in addition to this special matter, a series of measures proposed to deal with matters relating to cinematograph films, leasehold premises, insurance against unemployment, companies, and agriculture. The national Budget was anticipated with serious misgivings by the whole commercial community having regard to the losses resulting from the stagnation of trade. The ingenious devices adopted by the Chancellor of the Exchequer were admittedly such as could only be justified under the special circumstances of the situation, but they found support on all sides as matters stood. The chief addition to the official programme of work was a measure dealing with moneylending, a subject which has received attention in both Houses on previous occasions, and will, it may be anticipated, as from next January, be brought under more effective control. The Public Works Loans Act appears as cap. 1, and it is a measure of no special interest. It merely grants for the purposes indicated a sum of money not to exceed forty million pounds and enables certain specified loans to be left out of reckoning as assets of the fund. It is also unnecessary to deal at any length with cap. 2, which is entitled the Consolidated Fund (No. 1) Act, by which there are applied certain sums for the service of the years ending the 31st March 1926, 1927, and 1928. The measure gave the opportunity for general discussions on policy, and this year the subjects selected for attack were education and agriculture. Cap. 3 is yet another Act upon which it is needless to dilate at length. In it we find the Poor Law Emergency Provisions (Scotland) Act. It is, as the title plainly indicates, a measure of no practical importance to professional men on this side of the border. It was called for by reason of certain difficulties in poor law administration which had been brought to light, and by a decision that certain expenditure on the relief of dependants of those affected by the coal dispute had been illegal. The main operative clause has effect as from the 30th April 1926 and expires on the 31st Dec. 1928. The Royal and Parliamentary Titles Act is cap. 4. Here we get legislation of a very different type. Initiated by the Home Office, this Act is a sequel to discussions in last year's Imperial Conference, and it is further necessitated by the changes which the years have brought about in this country's relationships to Southern Ireland. Parliament is under this Act hereafter to be known and styled as the Parliament of the United Kingdom of Great Britain and Northern Ireland, and numbered accordingly, and His Majesty, by Royal Proclamation under the Great Seal of the Realm, is empowered to alter the Royal Title. It was announced on the secondreading stage that the same would become "Geo. V. by the Grace of God of Great Britain, Ireland, and the British Dominions beyond the Seas, King, Defender of the Faith, Emperor of India." A curious and rather interesting point of law arose out of the expression Great Seal of the Realm,' and it is one open to a little criticism, but it appeared that it had been used as far back as the time of Henry VIII. as an alternative for the "Dominions of the Crown.” The next chapter carries the reader from the region of State and style, affecting the few, to one of great consequence to the many. The Sale of Food and Drugs Act was a private member's effort, the purpose of which is to give effect to certain recommendations of a departmental committee in regard to preservatives and colouring matters in food, and it carries yet another stage onwards the anxious legislation by which is safeguarded the health of the people. Where regulations matter. are made under the Public Health (Regulations as to Food) Act 1907 (as amended by subsequent Acts), and the composition of any article of food or drink is prescribed, or there is imposed some prohibition or restriction in regard to the addition of preservatives or other ingredients or materials, the buyer of the article, unless the contrary is proved, is to be deemed to have demanded an article complying with the regulations and any contravention of them will, for the purposes of the Food and Drugs Act 1875, be deemed to render that article injurious to health. Similarly the addition of a preservative, ingredient, or material beyond a stipulated amount is also to be deemed to render the article injurious to health. This Act came into immediate operation. Cap. 6, the Forestry Act, gives again an abrupt change of subjectThere has been for some time a recognition that the policy of afforestation was not being pursued quite satisfactorily, and last year a measure like that now given statutory force was brought forward, but was not pushed to completion. One result, and that not one very desirable in itself, is to increase the number of commissioners to ten. It remains to be seen whether the increase will be reflected in the promotion of employment and in the spread of the acreage under timber. The powers now given to make and enforce by-laws in respect of land vested in them or under their control or management to which the public have access were urged as needful to secure the preservation of the timber, and for the prohibition of injury or disfigurement of the land and its amenities. They raised, however, some controversy, as it was feared that they could easily be so administered as to infringe public rights, and in particular there was some dispute as to what was happening in the case of the New Forest and the Forest of Dean. The Act contains a section which will give the verderers of these beauty spots further powers, including power to inquire into offences and to act as courts of summary jurisdiction, and the provisions of the Acts relating to those courts are made applicable. There is a proviso ensuring that by-laws are not to injuriously affect any estate, interest, right of common or other right of a profitable or beneficial nature except with the consent of the persons concerned. The Army and Air Force (Annual) Act forms cap. 7, and is the usual annual piece of legislation. The whole subject during the year has aroused more anxious attention than has been the case since the Armistice heralded the diminution of the numbers of men on the establishment. The body of land forces was in 1926 fixed at 159,400, and that of the Air Force at 35,500. This year the Act provides for an army of 166,500 men and an air force 33,000 strong. The increase in the Army was mainly due to the dispatch of forces to China for the protection of vital British interests, but on the other hand there is apparently a decrease in the numbers of the Regular Army due to reorganisation. The usual debate took place on the death penalty in the case of cowardice and desertion on active service, and an amendment in this direction was negatived by a large majority. The cost of billeting, according to the Schedule in the Act of 1926, and in that of this year, remains identical, as might be expected from the high level of costs of living being still maintained. The subject of armed force is continued in cap. 8, the Government of India (Indian Navy) Act. It recognises the sentiment of India and also it recognises certain very definite needs. While facilitating the re-creation of a navy in India, a force which was started shortly after 1613 by the East India Company, and while attracting the notice of young Indians to a larger career, the Act provides that the revenues of India are not to be applicable, without the consent of Parliament, to defray the expenses of forces and vessels not employed on Indian naval defence. It is provided that they are to be used for Indian purposes alone, unless the GovernorGeneral declares that a state of emergency exists. Thereupon the Admiralty can take control. This is a practical and obvious provision designed to put the Indian Army and Navy on a similar basis and at the same time to secure that the Navy should be as available as those of Australia and New Zealand. The Pacific Cable Act (cap. 9) implements agreements reached during the Imperial Conference, and it is in part consolidatory and in part an amending measure covering the Acts 1901 to 1924. The partner Governments in this country, Canada, Australia, and New Zealand, have arranged for a reconstitution of the Board, and the readjustment of the financial provisions. The repayments of money borrowed are ultimately to fall for division in the proportions five-eighteenths, five-eighteenths, six-eighteenths, and two eighteenths in the case of the four partners respectively. The first three mentioned partners have two representatives on the Board, whilst New Zealand is entitled to one representative. The Chairman may be a member of the Board. Amongst the subsidiary powers it is interesting to note that the possibilities of wireless are not deemed beneath the attention of so august a cable enterprise. The Board is enabled to undertake, as agents for and at the expense of the Governments of any parts of the Dominions, any work in connection with telegraphic communication, whether by means of cables or by means of wireless telegraphy within the sphere of their operations or within the Caribbean area, but the accounts of such work have to be kept separate and distinct from all the other financial statements. The Board can also do some news service in the West Indies so long as they undertake work in connection with telegraphic communication in that area. Cap. 10 introduces the Finance Act. In this case we have dealt with some fullness with the main points as the Bill passed through its various stages, and we therefore will occupy no unnecessary space in covering the ground again. The Chancellor of the Exchequer had, in introducing his Budget, indicated that the process of filling up the loopholes left to the tax-dodger would involve clauses couched in terms of the greatest complexity. There can be no two opinions that the expectation has been most completely fulfilled. The catena of sections dealing with relief where losses have been met with in transactions, the profits of which would have been chargeable under Sched. D, case VI., and relief where losses have been sustained in a business started after the 6th April 1923, and where a business has been transferred to a company, are complicated enough, but they are light reading compared to sect. 31. This section is five pages long, and relates to super-tax, and it adds new provisions to sect. 21 of the Finance Act 1922, and deals with sums available for distribution amongst the members of a company. The status of the subsidiary company falls into the purview of this same section, and a company is to be deemed such if by reason of the beneficial ownership of its shares its control is in the hands of a company not being one to which the section applies. The following sect. 32 deals with another description of enterprise, the inter-connected companies, and here again there are difficulties of interpretation which will call for the consideration of a bewildered company secretary whose directors may seek some enlightenment from him. The tax-dodging by sales of stocks cum div. is to be checked, or at any rate rendered less popular, by the power given to the Special Commissioners to call upon an individual for a statement and particulars relating to any assets in which he has had a beneficial interest and in respect of which he has received no income or an income less than that which he would have received if it had accrued from day to day. There is some relief given from super-tax where purchases are made cum div., but only where the amount payable by way of tax is more than 10 per cent. in excess. Part 3 deals with the method of charging the additional income tax for the years 1928-29 and thereafter and herein appears the new expression "sur-tax" which is employed to denote the difference between the amount of tax payable in respect of a total income and the amount payable in respect thereof if tax had been chargeable at the standard rate. Another section of portentous length is sect. 55, which gives relief from capital and transfer stamp duty where companies amalgamate or undergo reconstruction. It occupies some five pages. The following section provides that powers of attorney are not chargeable with duty more than once by reason only that more persons than one are named in the instrument as donors or donees, or that the powers relate to more than one matter. It will be extremely interesting to learn what results may flow in due course from the labours of the committee of lawyers, the appointment of which the Chancellor of the Exchequer announced on the 30th June, for the purpose of consolidating and rewriting the income tax laws. They are truly barbarous in point of form, and at present a perpetual annoyance to the tax-payer, who can make neither head nor tail of them. Criticism this year has not been confined to mere matters of form, but as we have shown in our comments there have been and still are points of principle in regard to which there is abundant ground for dissatisfaction. (To be continued.) Mr. David Davies, solicitor, of Cardigan, left estate of the gross value of £21,059, with net personalty £19,426. Mr. William Henry Hazard, solicitor, left estate of the gross value of £5996 (net personalty £1445). OCCASIONAL NOTES Mr. Justice MacKinnon will sit for the last time as Long Vacation judge in the Lord Chief Justice's court on Wednesday next, the 5th inst. He will also sit for the last time in King's Bench Judges' Chambers, to hear applications and summonses on Tuesday next, the 4th inst., at 10.30. The commission days for Bristol and Winchester on the Western Circuit will not be fixed before the commencement of the Michaelmas term. Master Simner will sit in Masters' Chambers on Monday next to assist Master Whateley, the Long Vacation master, and will so sit to the end of the vacation. The October session at the Central Criminal Court will commence on Tuesday, the 11th inst., at the Old Bailey, at 10 o'clock. The first meeting of the Hardwicke Society for the 1927-1928 session will be held in the Middle Temple Common Room on Friday, the 14th inst., at 8 o'clock p.m. The Union Society of London will hold their first meeting of the 1927-1928 session on Wednesday next, the 5th inst., in the Middle Temple Common Room, at 8 o'clock p.m. The president of the society for the ensuing year is Mr. D. F. Brundet, and the vice-president is Mr. A. Sandilands. The hon. treasurer is Mr. J. M. Symmons, and the hon. secretary is Mr. D. W. A. Llewellyn, 1, Essex-court, Temple. The Temple Church will re-open to-morrow morning for Divine Service at 11 o'clock, after having been closed for the Long Vacation. Lincoln's Inn Chapel, having been closed, will reopen for Divine Service to-morrow morning at 11 o'clock. Gray's Inn Chapel, having been closed for the Long Vacation, will reopen for Divine Service to-morrow morning at 11 o'clock. A writer in The Times, who appears to have been making various pilgrimages to places of historic and literary interest in the South of Scotland, gave an interesting account in his last week's article of a visit paid to Gretna Green, and in particular to the blacksmith's shop there, now converted into a kind of museum, containing, among other things, an anvil bearing the legend: "The famous blacksmith's anvil where marriages were and still are performed over." Here, and in neighbouring cottages, were celebrated those irregular, although perfectly valid, marriages which made Gretna Green a name to conjure with by the novelist of the past. There was no particular reason why runaway matches should have been celebrated at Gretna Green any more than in other towns and villages in Scotland save that it was one of the nearest places to the border, for, of course, they were English couples who patronised the blacksmith and the others who made a lucrative business by officiating at these weddings. To many the Scots law of marriage has always seemed dangerously lax; as Lord Neaves laid it down in his "Tourist's Matrimonial Guide through Scotland": "This maxim itself might content ye, And marriage is really what's meant ; and so, if a man and woman agree to take each other for husband and wife that is enough, although it is certainly advisable, for evidential purposes, that this mutual arrangement should be acknowledged before witnesses. Irregular marriages may still competently be contracted at Gretna Green as elsewhere in Scotland, but a great blow was directed at the local industry when, at the instigation of Lord Brougham, Parliament enacted by 19 & 20 Vict. c. 96, "that after the 31st Dec. 1856 no irregular marriage shall be valid in Scotland unless one of the parties has lived in Scotland for the twentyone days next preceding the marriage, or has his or her usual residence there at the time, any law, custom or usage to the contrary notwithstanding." Quite recently in Bach v. Bach (43 Times L. Rep. 493) a decree of nullity was pronounced in the case of two persons who travelled to Gretna Green from Birmingham and there went through a form of marriage on the following day. As Mr. Justice Hill said, it was quite clear that there had been no marriage, the ceremony being carried out directly in the teeth of the Act. A much more difficult case was one of the earliest that came before the courtLawford v. Davies (39 L. T. Rep. 111 ; 4 P. D. 61). There two persons domiciled in England arrived in Scotland about 4 a.m. on the 1st July 1870, remained there until the 21st |