of deterioration in the goods necessarily incident to the course of transit.

41. Buyer's right of examining the goods.-(1.) When goods are delivered to the buyer, which he has not previously examined, he is not deemed to have accepted them until he has had a reasonable opportunity of examining the goods for the purpose of ascertaining whether they are in conformity with the contract.

(2.) Unless otherwise agreed, when the seller tenders delivery of goods to the buyer, he is bound, on request, to afford the buyer a reasonable opportunity of examining the goods for the purpose of ascertaining whether they are in conformity with the

contract.

42. Acceptance.-The buyer is deemed to have accepted the goods when he intimates to the seller that he has accepted them, or when the goods have been delivered to him, and he does any act in relation to them which is inconsistent with the ownership of the seller, or when, after the lapse of a reasonable time, he retains the goods without intimating to the seller that he has rejected them.

43. Buyer not bound to return rejected goods.—Unless otherwise agreed, where goods are delivered to the buyer, and he refuses to accept them, having the right so to do, he is not bound to return them to the seller, but it is sufficient if he gives notice to the seller that he refuses to accept them.

44. Liability of buyer for neglecting or refusing delivery of goods.-When the seller is ready and willing to deliver the goods, and requests the buyer to take delivery, and the buyer does not within a reasonable time after such request take delivery of the goods, he is liable to the seller for any loss occasioned by his neglect or refusal to take delivery, and also for a reasonable charge for the care and custody of the goods. PART IV.-RIGHTS OF UNPAID SELLER AGAINST THE GOODS 45. Unpaid seller defined.-(1) The seller of goods is deemed to be an "unpaid seller" within the meaning of this Act(a.) When the whole of the price has not been paid or tendered; (b.) When a bill of exchange or other negotiable instrument

has been received as conditional payment, and the condition on which it was received has not been fulfilled by reason of the dishonour of the instrument or otherwise. (2) In this part of this Act the term "seller" includes an agent of the seller to whom the bill of lading has been endorsed, and also a consignor or agent who has himself paid, or is directly responsible for, the price.

46. Unpaid seller's price.-Subject to the provisions of this Act, and of any statute in that behalf, and unless otherwise agreed, the unpaid seller of goods, as such, has—

(1.) A lien on the goods for the price while he is in possession of them;

(2.) In case of the insolvency of the buyer, a right of stopping the goods in transitu after he has parted with the possession of them :

(3.) A right of re-sale as limited by this Act.

Unpaid Seller's Lien.

47. Seller's lien.-(1.) Subject to the foregoing provisions of this Act, the unpaid seller of goods who is in possession of them is entitled to retain possession of them until payment or tender of the price in the following cases, namely:

(a.) When the goods have been sold without any stipulation as to credit;

(b.) When the goods have been sold on credit, but the term of credit has expired;

(c.) When the buyer becomes insolvent.

(2.) The seller may exercise his right of lien notwithstanding that he is in possession of the goods as agent or bailee for the buyer.

48. Part delivery.-(1.) Where an unpaid seller has made part delivery of the goods, he may exercise his right of lien on the remainder unless such part delivery has been made under such circumstances as to show an intention of waiving the lien. 49. Termination of lien.—(1.) The unpaid seller of goods

loses his lien thereon

(a). When he delivers the goods to a carrier or other person for the purpose of transmission to the buyer without reserving the right of disposal of the goods;

(b.) When the buyer or his agent obtains possession of the goods, unless there be an agreement to the contrary; (c.) By waiver thereof.

(2.) The unpaid seller of goods, having a lien thereon, does not lose his lien by reason only that he has obtained judgment for the price of the goods.

Stoppage in Transitu.

50. Right of stoppage in transitu.-Subject to the foregoing provisions of this Act, when the buyer of goods becomes in solvent, the unpaid seller who has parted with the possession of the goods has the right of stopping them in transitu; that is to say, he may resume possession of the goods as long as they

are in course of transit, and may retain them until payment or tender of the price.

51. Duration of transit.—(1.) Goods are deemed to be in course of transit from the time when they are delivered to a carrier by land or water, or other bailee, for the purpose of transmission to the buyer, until the buyer, or his agent in that behalf, takes delivery of them from such carrier or other bailee. (2.) If the buyer or his agent in that behalf obtains delivery of the goods before their arrival at the agreed destination, the transit is at an end.

(3.) If, after the arrival of the goods at the agreed destination, the carrier or other bailee attorns to the buyer, or his agent, and continues in possession of them as bailee for the buyer, or his agent, the transit is at an end, and it is immaterial that a further destination for the goods may have been indicated by the buyer. (4.) If the goods are rejected by the buyer, and the carrier or other bailee continues in possession of them, the transit is not deemed to be at an end, even if the seller has refused to receive them back.

(5.) When goods are delivered to a ship chartered by the buyer it is a question depending on the circumstances of the particular case, whether they are in the possession of the master as a carrier, or as agent to the buyer.

(6.) Where the carrier or other bailee wrongfully refuses to deliver the goods to the buyer, or his agent in that behalf, the transit is deemed to be at an end.

(7.) Where part delivery of the goods has been made to the buyer, or his agent in that behalf, the remainder of the goods may be stopped in transitu, unless such part delivery has been made under such circumstances as to show an intention of giving up possession of the whole of the goods.

(8.) The right of stoppage in transitu may be determined by waiver thereof on the part of the unpaid seller.

are.

52. How stoppage in transitu is effected.-(1.) The unpaid seller may exercise his right of stoppage in transitu either by taking actual possession of the goods, or by giving notice of his claim to the carrier or other bailee in whose possession the goods Such notice may be given either to the person in actual possession of the goods or to his principal. In the latter case the notice, to be effectual, must be given at such time and under such circumstances that the principal, by the exercise of reasonable diligence, may communicate it to his servant or agent in time to prevent a delivery to the buyer.

(2.) When notice of stoppage in transitu is given to the carrier, or other bailee in possession of the goods, he must redeliver the goods to, or according to the directions of, the seller.

Re-Sale by Buyer or Seller.

53. Effect of sub-sale or pledge by buyer.-The unpaid seller's right of lien or stoppage in transitu is not affected by any sale, pledge, or other disposition of the goods which the buyer may have made, unless the seller has assented thereto; provided that

(1.) When the buyer or his agent has obtained possession of the documents of title to the goods from the seller or his agent, any sale, pledge, or disposition of such goods or documents by such buyer so in possession, or by any other person or agent entrusted by the buyer with the documents of title, is as effectual as if such buyer or other person were an agent or person entrusted by the seller with the documents of title, provided the person to whom the sale, pledge, or other disposition is made has not notice of any lien or other right of the seller in respect of the goods.

(2.) Where a bill of lading or other document of title has been lawfully indorsed or otherwise transferred to any person as a buyer or owner of the goods, and such person transfers such document by indorsement (or by delivery, where the document is by custom, or by its express terms transferable by delivery or makes the goods deliverable to the bearer) to a person who takes the same in good faith and for valuable consideration, then such last-mentioned transfer is as effectual as if it had been made by the authority of the seller, and he can only exercise his rights as unpaid seller, subject to the rights of the transferee.

subject to the provisions of the Factors Act. (3.) The provisions of this section shall be construed with and

54. Sale not generally rescinded by lien or stoppage in transitu. -(1.) Subject to the provisions of this section, a contract of sale is not rescinded by the mere exercise by an unpaid seller of his right of lien or stoppage in transitu.

(2.) Where an unpaid seller who has exercised his right of lien or stoppage in transitu resells the goods, the buyer acquires a good title thereto as against the original buyer.

(3.) Where the goods are of a perishable nature, or where the unpaid seller gives notice to the buyer of his intention to resell, and the buyer does not within a reasonable time pay or tender the price, the unpaid seller may resell the goods and recover from the original buyer damages for any loss occasioned by his breach of contract.

(4.) Where the seller expressly reserves a right of resale in case the buyer should make default, and on the buyer making default, resells the goods, the original contract of sale is thereby rescinded.

PART V.-ACTIONS FOR BREACH OF THE CONTRACT.

Remedies of the Seller.

55. Action for price.-(1.) Where, under a contract of sale, the property in the goods has passed to the buyer, and the buyer wilfully neglects or refuses to pay for the goods according to the terms of the contract, the seller may maintain an action against him for the price of the goods.

(2.) Where, under a contract of sale, the price is payable on a day certain irrespective of delivery, and the buyer wrongfully neglects or refuses to pay such price, the seller may maintain an action for the price, although the property in the goods has not passed, and the goods have not been appropriated to the contract..

56. Damages for non-acceptance.-(1.) Subject to the foregoing provisions of this Act, when the buyer wrongfully neglects or refuses to accept the goods, the seller may maintain an action against him for damages for non-acceptance.

(2.) The measure of damages is the estimated loss directly and naturally resulting from the buyer's breach of contract.

(3.) Where there is an available market for the goods in question the measure of damages is prima facie to be ascertained by the difference between the contract price and the market or current price at the time or times when the goods ought to have been accepted, or, if no time was fixed for acceptance, then at the time of the refusal to accept.

Remedies of the Buyer.

57. Damages for non-delivery.-(1.) Where the seller wrongfully neglects or refuses to deliver the goods to the buyer, the buyer may maintain an action against the seller for damages for non-delivery.

(2.) The measure of damages is the estimated loss directly and naturally resulting from the seller's breach of contract.

(3.) Where there is an available market for the goods in question the measure of damages is prima facie to be ascertained by the difference between the contract price and the market or current price of the goods at the time or times when they ought to have been delivered, or, if no time was fixed, then at the time of the refusal to deliver.

58. Trover or detinue.-Subject to the provisions of this Act, where, under a contract of sale, the property in the goods has passed to the buyer, and the seller wrongfully neglects or refuses to deliver the goods, the buyer may maintain an action for damages for detention of the goods against the seller or any other person in possession of the goods, or (after demand and refusal) an action for the conversion of the goods against the seller or any other person who has dealt with the goods under such circumstances as to amount to a conversion thereof.

59. Specific performance may be decreed.-In any action for breach of contract to deliver specific goods for a price in money, on application of the plaintiff and by leave of the judge before whom the action is tried, the jury shall, if they find the plaintiff entitled to recover, find by their verdict (or, if there be no jury then the judge shall find) what are the goods in respect of the non-delivery of which the plaintiff is entitled to recover and which remain undelivered; what, if any, is the sum which the plaintiff would have been liable to pay for the delivery thereof; what damages, if any, the plaintiff would have sustained if the goods should be delivered under execution as thereinafter mentioned; and what damages if not so delivered; and thereupon, if judgment shall be given for the plaintiff, the judge, in his discretion, on the application of the plaintiff, shall have power to order execution to issue for the delivery, on payment of such sum, if any, as shall have been found to be payable by the plaintiff as aforesaid, of the said goods without giving the defendant the option of retaining the same upon paying the damages assessed.

For the purposes of this section "judge" includes court, and "plaintiff includes a defendant who counter-claims for delivery of the goods.

60. Breach of warranty of quality, fitness, or condition. (1.) Where, under a contract of sale, there is a warranty of the quality, fitness, or condition of the goods, and the goods do not fulfil the warranty, the buyer may reject the goods, unless he has accepted them, or unless the contract was for the sale of specific goods, and the preperty in the goods has passed to the buyer.

(2.) Where the buyer has accepted the goods, or where the contract was for the sale of specific goods and the property therein has passed to the buyer, the buyer is not entitled to reject the goods unless there was an express stipulation in the contract to that effect; but he may

(a.) set up against the seller the breach of warranty in diminution or extinction of the price; or

(b.) maintain an action against the seller for damages for the breach of warranty.

(3.) The measure of damages for breach of warranty of quality, fitness, or condition is prima facie the difference between the actual value of the goods at the time of delivery to the buyer

and the value they would have had if they had answered to the warranty.

(4.) The fact that the buyer has set up the breach of warranty in diminution or extinction of the price does not prevent him from maintaining an action for the same breach of warranty if he has suffered special damage..

61. Interest and special damages.-Nothing in this Act shall affect the right of the buyer or the seller to recover interest or special damages in any case when by law interest or special damages may be recoverable, or to recover money paid where the consideration for the payment of it has failed.

PART VI.-SUPPLEMENTARY.

62. Contract of exchange of goods.-(1) Where the consideration for the transfer of the property in goods from one person to another consists of other goods the contract is called a contract of exchange of goods.

(2.) If the consideration for such transfer consists partly of goods and partly of money the contract is deemed to be a contract of sale and not a contract of exchange of goods.

(3.) Except as otherwise provided by this Act, the provisions of this Act relating to contracts of sale apply, with any necessary modifications, to contracts of exchange of goods.

63. Implied duties, &c., may be expressly excluded.—Where any right, duty, or obligation arises, under a contract of sale, by implication of law, it may be negatived or varied by express agreement, or by usage, if the usage be such as to bind both parties to the contract.

64. Rights and duties under Act enforceable by action.—Where any right, duty, or liability is declared by this Act, it may, unless otherwise by this Act provided, be enforced by action. 65. Auction sales.-In the case of a sale by auction(1.) Where goods are put up for sale by auction in lots, each lot is prima facie deemed to be the subject of a separate contract of sale.

(2.) A sale by auction is deemed to be complete when the auctioneer announces its completion by the fall of the hammer, or in other customary manner. Until such announcement is made any bidder may retract his bid. (3.) When a sale by auction is stated to be without reserve, it shall not be lawful for the seller to bid himself or to employ any person to bid at such sale, or for the auctioneer knowingly to take any bid from the seller or any such person: Any sale contravening this rule shall be voidable at the option of the buyer.

(4.) A sale by auction may be subject to a reserved price, and a right to bid may also be reserved expressly, by or on behalf of the seller.

When a right to bid is expressly reserved, but not otherwise, the seller, or any one person on his behalf, may bid at the auction in such manner as he may think proper.

66. Sale of horses.-With respect to contracts for the sale of horses the rules in the first schedule to this Act shall be observed and shall have effect as being enacted by this Act.

67. Repeals.-The enactments mentioned in the second schedule to this Act are hereby repealed as from the commencement of this Act to the extent in that schedule mentioned.

Provided that such repeal shall not affect anything done or suffered, or any right, title, or interest acquired or accrued before the commencement of this Act, or any legal proceeding or remedy in respect of any such thing, right, title, or interest.

68. Savings.-(1) The rules in bankruptcy relating to contracts of sale shall continue to apply thereto notwithstanding anything in this Act contained.

(2.) The rules of the common law, including the law merchant, save in so far as they are inconsistent with the express provisions of this Act, shall continue to apply to contracts for the sale of goods.

(3.) Nothing in this Act or in any repeal effected thereby shall affect the enactments relating to bills of sale, or any enact ment relating to the sale of goods which is not expressly repealed by this Act.

FIRST SCHEdule.

Rules as to the Sale of Horses.

1. The sale of any horse, whether in market overt or other. wise, shall be void as against the true owner thereof, unless such sale be made in accordance with the following rules :

2. When a stolen horse has been sold in market overt, and in accordance with these rules, the true owner may recover the same if he make claim thereto within six months of the theft, on tendering to any person who may have bought it in good faith, the price which he gave for the same.

3. The market authority in every horse fair or market shall cause a special open place to be marked out for the sale of horses.

4. There shall be a toll-keeper appointed for such place, who hall take tolls and keep the place from ten before noon until sunset of each market day, and no tolls shall be taken except between the aforesaid hours.

(To be continued.)

PUMP COURT.

The Temple Newspaper and Solicitors' Review.

EDITORIAL, ADVERTISEMENT, AND

PUBLISHING OFFICES, 33, Exeter Street, Strand, W.C.

JULY 10, 1889.

Pro Lege.

AUCTION LAW.-IV.

CONDITIONS OF SALE

THE auctioneer and estate agent has in general less to do with the preparation of conditions of sale than with the preparation of particulars. It will indeed seldom, if ever, be prudent for him to attempt to dispense with legal assistance in preparing conditions of sale where the subjectmatter consists of land; and certainly he should never do so-for, as we have seen, he may risk the loss of his commission without the authority of his principal, and obtaining the latter's express assent to the conditions under which he proposes to sell. Again, we propose (as in dealing in our last article with particulars) to pass, with a very brief notice of sales of chattels, to sales of land. For sales of goods are simple matters by comparison, the needful conditions simple and well known, the necessity for special conditions rare. One question, however, which has arisen more than once in such cases requires a brief notice. This question arises from the mode in which such sales are sometimes conducted. Very frequently the conditions are printed on a leaf of the catalogue; at other times they are affixed to a board in the room, and the auctioneer will announce them, and state that the sale is made subject to them. In other cases, again, as in Bywater v. Richardson, 1 Adol. and Ell. 508, they may consist of rules painted on the walls of a repository. The question which will then arise is whether the purchaser had notice of the conditions, or whether they are incorporated into the contract. In the recent case of Watkins v. Rymill, 10 Q.B.D. 178, this point arose for decision. The defendant kept a repository for the sale on commission of horses and carriages. The plaintiff delivered to him a waggonette to be sold, and took from him a printed form, which contained a receipt for the waggonette, followed by the words, "Subject to the conditions as exhibited upon the premises." These conditions were printed, exhibited in conspicuous positions in many parts of the premises, and by one of them the defendant had power to sell any property sent to their repository which remained over a month, unless all expenses were previously paid. The plaintiff did not read this receipt, but put it in his pocket without noticing it. The defendant having sold the waggonette in the exercise of the power of sale in the conditions, the plaintiff brought an action to recover its value; the judge misdirected the jury, who in the result found for the plaintiff; but a Divisional Court (consisting of Hawkins, Stephen, and Watkin Williams, JJ.), after holding that the judge had misdirected the jury, decided that the condition was not unreasonable, and that in the circumstances there was nothing to take the case out of the general rule, that if a

document in a common form is delivered by one of two contracting parties to, and accepted without objection by, the other, it is binding upon him, whether he informs himself of its contents or not, and that judgment ought to be entered for the defendant without a new trial, for there was no evidence on which the jury could have properly found for the plaintiff.

The same question can, of course, occur in cases of sale of land, and a recent instance is furnished by Rishton v. Whatmore, 8 Ch. Div. 467. Turning to conditions as affecting sales of land, we come to a complex and difficult subject, on which difficulty will continue to be experienced until the problem, hardly likely to meet with speedy solution, of how to render land transfer as simple and expeditious as the transfer of "portable property," has ceased to perplex legislators, and to be the panacea of stump orators. Now it is important to consider that we have in the first place certain principles of law regulating sales, then conditions, varying with the different needs of diverse times, then rules of interpreting and applying and defining the meaning of these, and lastly we have a chain of statutes incorporating with such contracts, unless excluded, a number of provisions and stipulations in derogation of normal rights existing under open contracts, though based on practice prevailing where the contract was not an open one. Further, it is desirable to bear in mind the principles which should influence the draughtsman when determining the conditions he shall employ. He should omit all unnecessary and insert all necessary conditions; he should remember that while special conditions should never be resorted to unless there is need for them, yet troublesome and expensive inquiries should be guarded against by reasonable conditions, and that all conditions will be construed strictly against the vendor, and cannot be varied by parol statements at the time of sale. Reverting then to the rights of purchasers, subject to statutory provisions and stipulations excluding such rights in the contract, the purchaser is entitled to have a good title and an estate free from all incumbrances, and conditions which derogate from either being "in restraint of a legal right" must be expressed "with reasonable clearness, and in the case of sales by auction, so as to convey clear information to the class of persons who ordinarily frequent auctions." Moreover, the Court requires good faith in conditions of sales, and will never allow a vendor to avail himself of them for the purpose of acting fraudulently. Nothing has, perhaps, caused more difficulty than the contest between freedom of contract on the one hand and the recognition by equity of the fact that the contracting parties are not in point of knowledge of the subject-matter on an equal footing, and the consequent application of some measure of fairness in adjusting the liabilities and rights under the contract. In Hyde v. Dallaway, 1 Bear. 606, this was well put by Lord Langdale, M.R., who pointed out that while it was hard to say that persons should not enter into any contracts they please, yet on the other hand the conditions might be of such a nature that it was hardly possible to carry them into execution consistently with the settled principles of Courts of Equity.

It would not be practicable for us to discuss now the force and effect of different conditions generally used according to the interpretation placed upon them by the Courts, and we propose to enumerate the principal Acts which have of late years regulated the contract of sale of land. In the Sale of Land by Auction Act, 1867 (30 and 31 Vict., c. 48), we have the first step. By that Act it is declared, amongst other provisions, that whenever a sale by auction of land would be invalid at law by reason of the employment of a puffer, it should be invalid in equity as well as at law. Particulars or conditions of sale by auction of any land were required to state whether such land would be sold without reserve or subject to a reserve price, or whether a right to bid was reserved; and the statute provides that if the land be sold without reserve, it is not lawful for the seller to employ any person to bid bid at such sale, or for the auctioneer to take knowingly any bidding from any such person. "In the event of the land being sold subject to a reserved price," the Act is silent, but it has been held "that in the absence of express stipulation, it is not lawful to employ any person to bid up to the reserved price." Gilliat v. Gilliat, L.R. 9 Eq. 60; see Fry on Specific Performance. If, however, the seller reserves a right to bid, he or any one person in his behalf may bid at such

In

auction in such manner as he may think proper. By far more important are the provisions of the Vendor and Purchaser Act, 1874 (37 and 38 Vict., c. 78). By its provisions forty years were substituted as the period of commencement of title which a purchaser might require in place of sixty years. Earlier title, however, than forty years might be required in cases similar to those in which earlier title than sixty years might have been previously required. The cases in which before the Act title earlier than sixty years could be required were advowsons, long leaseholds, tithes, and reversionary interests. the completion of any contract for sale of land, subject to any stipulation to the contrary in the contract, the obligations and rights of vendor and purchaser 'were to be regulated by several rules, which were as follows:-Under a contract to grant or assign a term of years, whether derived or to be derived out of a freehold or leasehold estate, the intended lease or assign should not be entitled to call for the title to the freehold; recitals, statements, and descriptions of facts, matters, and parties contained in deeds, etc., twenty years old at the date of the contract should, unless proved to be inaccurate, be taken to be sufficient evidence of the truth of such facts, matters, and descriptions; the inability of the vendor to furnish the purchaser with a legal covenant to produce. and furnish copies of documents of title should not be a ground for objection if the purchaser would, on completion, have an equitable right to production of the documents; such covenants for production as the purchaser could require should be furnished at his expense, and the vendor should bear the expense of perusal and execution on behalf of himself and necessary parties other than the purchaser; and where the vendor retained any part of an estate to which any document of title related, he should be entitled to retain such documents. Then came the statutory conditions introduced by the Conveyancing Act, 1881, sects. 3 and 13; the Conveyancing Act, 1882, sect. 4; and lastly, the Trustee Act, 1888, sect. 3, the last of which (inter alia) protected sales made by trustees from being impeached on the mere ground that any of the conditions, subject to which the sale was made, may have been unnecessarily depreciatory. But though the sections to which we have made reference are the more important, they are by no means the only ones, nor are the statutes in which they occur the only statutes which contain provisions regulating the terms of the contract of sale. For instance, the "Customs and Inland Revenue Act, 1888" (51 Vict., c. 8, sec. 20), declares that what was formerly a very usual condition, viz., a condition precluding objection or requisition on the ground of absence or insufficiency of stamp on any instrnment if executed after the passing of that Act, and every contract, etc., for assuming liability on account of absence or insufficiency of stamp upon any such instrument, shall be void.

It will be observed that in 1886 the policies declined or not completed amounted to £51,950, in 1887 to £98,741, and in 1888 to £208,242. No more conclusive evidence than this could be forthcoming to prove the discrimination and caution exercised in the acceptance of proposals. Notwithstanding this discrimination, the progress is marvellous and unmistakable, and points to the inherent strength and capabilities of the society. The income of the year was £214,063, against £205,736 in 1887, and the assurance fund, after making provision for every outstanding liability, amounted at the close of the year to £1,644,937, exclusive of the Amicable Fund of £180,198. The average rate of interest earned on the funds, invested and uninvested, was £4 2s. 10d. per cent., against £4 1s. 2d. in 1887. A special finance committee examines in detail all proposed loans or other investments, and gives constant attention to existing securities, the results of the committee's labours being fully reported to the succeeding board meeting. The funds of the society are evidently guarded with the utmost care and watchfulness by the directors, and it is satisfactory to find that the rate of interest is not only well sustained, but has increased. During the year 278 policies became claims by death, and six by survivance, the total amount payable by the society in respect thereof being £158,797, excluding £37,505 bonus additions. This heavy mortality has occurred mainly at the higher ages, where the reserves are very large, so that the society has actually been relieved of a correspondingly heavy liability. The management expenses continue in a moderate ratio, and assuming by the new and proper mode of computation that the new premiums are absorbed in expenses, the following figures will show the renewal premiums and the expenses applicable thereto for each of the last three years:

Norwich Union Life Insurance

Society.

INSURANCE.

THIS is a very well-known office, having been in active operation for considerably more than three-quarters of a century. Although it has always enjoyed an honourable name, and maintained its prestige with undimmed lustre, prior to the advent of the present management, some three or four years ago, the business of the society had not progressed for many years-in fact, some lee-way has had to be made up. In 1871 the premium income was £151,318; in 1876, £143,400; and in 1886, £140,126. In In the the following year, however, the first report of the new secretary and actuary showed an increase to £142,462. In the present report for 1888 the premiums are £148,679. A strenuous effort must have been made to have put up the new business to an amount that has been considerably more than equal to the waste by deaths, lapses, and surrenders necessarily constantly taking place in the case of an old office. Twenty-three years ago the Norwich Union took over the business of a very ancient society-the Amicable, founded by Royal Charter in the reign of Queen Annewhose accounts are kept distinct, and exhibit a surplus. During the past year the Norwich Union issued 1,248