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BRITISH LAW FIRE INSURANCE COMPANY, LIMITED. THE ordinary general meeting of the above company was held at the City Terminus Hotel, Cannon-street. E.C., on Wednesday, the 7th inst. The meeting was specifically called to receive the directors' report and accounts. Subsequently an extraordinary general meeting was held to approve and confirm certain alterations, in the articles of association.

Sir HENRY WATSON PARKER, chairman of the board of directors, presided.

Mr. H. FOSTER CUTLER, the manager and secretary, read the notice convening the meeting,

The report and statement of accounts were taken as read.

The CHAIRMAN, in moving the adoption of the report and accounts, said: It is a great pleasure to myself and to the directors, who take such a deep interest in your affairs, to meet you here to-day, and to render an account of our stewardship for the first year of our undertaking. (Hear, hear.) We invited you to join our undertaking because we felt that the time was ripe for launching a new Fire Office, under the management, and with the influence of the legal profession. (Cheers.) The great success which has attended the formation of the two other legal Fire Offices, established now more than a generation ago fully warranted the expectation that there was a large field remaining open for a new Law Fire Office, conducted upon the same safe lines. Gentlemen, the experience which we have had of the working of our undertaking for the past year, fully justifies the expectations which we foresaw. Out of a total proprietary of more than 1,000 shareholders, upwards of 600 are members of the legal profession, and every one of them should be a centre of business to our company. (Cheers.) With these influences at work we have been able to establish a valuable business during the first year of our existence, and we have succeeded beyond our most sanguine expectation. We could have done a much larger business, for a vast amount has been refused, but we preferred to adhere, as far as possible, to our original programme, and tɔ cover only the safer class of house risks. The effort to secure a large premium income by taking business abroad, and covering all classes of risks, has wrecked many a 'promising concern, and crippled and disabled others for years. With the valuable professional connection which we have a first-class business is secured to us, and we have no need to endeavour to increase our income by cultivating doubtful risks. (Hear, hear.) We study quality rather than quantity, and thus hope to build up gradually a prosperous company on solid foundations. But, gentlemen, insurance business is not built up in a year or in two years. (Hear, hear.) It takes time to develop, but meantime the property in the company is rapidly increasing in value. (Cheers.) It would be, I believe, unexampled in the history of insurance offices that there should be a dividend at the end of the first year, and I am confident that you did not expect one, but you have the satisfaction of knowing, as the result of our working for the year, that after paying all losses and expenses, including our preliminary expenses, we start the new year with the whole of our capital wellinvested, with a reserve of over £22,000, and a cash balance of over £5,000, and have established the goodwill of a business with a premium income of £14,000. (Hear, hear.) This income, if not doubled during the current year, will be most materially increased. No inconsiderable part of our success is due to the establishment of our local branches. We have thus tapped the provinces, as well as the metropolis, and we are the first of the Law Fire Offices to develop in this direction. You will see by the fly-sheet issued with the report that we established local boards and branches at Edinburgh, Manchester, Liverpool, Birmingham, and Bristol, and the names of the gentlemen who constitute those boards are a guarantee of their success. Such, gentlemen, has been the work achieved during our first year, and we are, I hope, justly proud of our success. We look upon the British Law Fire Office as established on a broad and solid basis, and upon its successful development as secured, and we regard our shares ia this company as a very valuable and rapidly improving property. Gentlemen, you have the report and accounts before you, and we invite any inquiry which you may desire to make, but before leaving the matter in your hands, I would desire to offer a few explanations on one or two items in the accounts. You will observe rents, rates, and taxes stand in the account at £2,340 16s. 8d. I should explain, that this includes the rent, and rates, and taxes of the west-end office and of our branches at Edinburgh, Manchester, and Birmingham. I explained fully at the general meeting of the company, held in June last year the terms upon which we held our head offices, and which met with general approval, but I will shortly repeat them for the information of those who were not present at that meeting. We hold the whole of the ground floor of the building which we occupy and the greater portion of the basement on lease for thirty years, determinable at our option at seven, fourteen, or twenty-one years at a rental of £200 per annum, we paying rates and taxes which amount to about £500 per annum. We have sub-let that portion of our building, which we do not at present require, at rents amounting, together to £900 per annum, we paying rates and taxes. The net rental therefore at which we stand at our head offices is £1,600 per annum. I took occasion to remind the shareholders present at that meeting last year, that, although our rent would form a considerable item in our first year's expenditure, it would not be out of proportion to our means as the undertaking progresses. We have a central position and accommodation at our offices, which are second to none in the

City of London (Cheers.) Again, our working expenses amount to £11,653 198. 2d., as appears by the accounts. This is a heavy item, but it must be borne in mind that the expenses of every large

undertaking during its first year of existence are necessarily considerable. (Hear, hear.) You have before you all the details of that expenditure. The item of £3,152 1s. 7d. is not given in detail, as it was not considered necessary to burden the accounts with the details, but I have the full details at hand in case any shareholder desires further information. I may mention that the cost of stationery and show-cards alone, which includes the cost of the voluminous books and records which we have to keep, amounts to upwards of £1,500, but this is an initial expenditure only, which will not recur in future years. The cost of establishing our branches and agencies has also been considerable. As stated in the report we have carried to capital account one-half of this expenditure, and to set against this item we have the goodwill of our valuable business. With these remarks, and at the same time inviting any inquiry which may seem necessary. I beg to move, "That the report and accounts be received and adopted and entered on the minutes." (Cheers.)

Mr. H. G. NORTON (deputy-chairman): I beg to second that. Mr. MITCHELL wished to know what success had attended the efforts of the directors to establish the business in the provinces. Had the business done been proportionate to the expense devoted to that purpose?

The CHAIRMAN, in reply, said that since the 7th May he might state that they had not quite doubled their premium income, but they had rapidly approached it. Of course he meant new business apart from renewals of the past year. With respect to the branches he might state that the branches opened had been of the greatest possible assistance to the company, and had done valuable business. Some of the branches had not been working many months, but none had been established for a year. The experience, however, that the directors had of them went to show that they would not only pay their way, but would eventually bring them good business. They had reinsured with other companies, and found it desirable to do so. They took limited lines themselves, and they also gave lines to other offices. That was a course which he thought was business-like and fair. (Hear, hear.)

The CHAIRMAN having then expressed his readiness to reply to any further questions, and no one rising, the motion, for the adoption of the report and accounts was put and carried unanimously.

The CHAIRMAN said the next business was the re-election of the retiring directors, Messrs. John G. Bristow, Holroyd Chaplin, Robert Cunliff, and Edward Gibson. Mr. George Woodyatt Hastings, M.P., owing to his parliamentary duties as chairman of the Permanent Private Bill Committee, felt compelled to resign.

A SHAREHOLDER, in moving the re-election of the retiring directors, said, in asking the shareholders to re-elect these gentlemen on the board, he was sure after what the chairman had said in regard to the business that had been done, it needed no words on his part to recommend these gentlemen to the goodwill of the meeting. (Cheers.) The first annual report and statement of accounts also spoke for themselves, and showed that those gentlemen had not only done their duty well, but also that each and all had done their utmost to further the best interests of the company. (Cheers.) He had great pleasure in proposing that these gentlemen be re-elected on the board. (Cheers)

Mr. WOODWARD had great pleasure in seconding the motion, which was at once cordially agreed to.

A SHAREHOLDER had great pleasure in proposing that Mr. Archibald Herbert James, of the firm of Messrs. Williams and James, of Norfolk House, Thames Embankment, be elected a director of the company. That gentieman was peculiarly qualified for the position. He was moderately young-(a laugh)-and in his (the speaker's) opinion he thought there should be an element of youth on the board. He, however, was able to say, and he was sure it would be confirmed by all who came into contact with that gentleman, that he was an exceptionally competent man of business. He felt sure, too, that he would bring to the office a larger volume of business than he had hitherto done. (Cheers.)

A SHAREHOLDER had great pleasure in seconding the resolution. In reply to a remark as to the number of directors, the CHAIRMAN pointed out they were making no addition to their number, but merely filling up a vacancy. The articles, he might further remind them, provided for 22. When the fees came to be divided into sixteen portions it was only £120 a year to each director.

A SHAREHOLDER thought the meeting should bear in mind that in recommending the election of Mr. James the company was not adding to the expenses of the directors. There was so much allowed for the remuneration of the directors, and there was therefore no additional expense. It must further be borne in mind that the directors of an insurance office were in the way of influencing business, and that a large amount of business was done by their personal influence.

The motion was carried nem. con.

Mr. JOHN G. BRISTOW briefly returned thanks for his re-election. The retiring auditors, Messrs. Turquand. Youngs, Weise, Bishop, and Clarke, and Messrs. A. T, Hawkins, Wreford and Co. were reelected auditors of the company, at a remuneration of twenty-five guineas per annum to each firm.

This concluded the business of the ordinary general meeting. The meeting was then made special, in order that alterations might be made in the articles of association.

Votes of thanks having been passed to the chairman, board of directors, and the general manager and staff, the proceedings terminated.

THE SOLICITORS ANNUAL CERTIFICATE DUTY REPEAL ASSOCIATION.

This Society is being formed to give effect to the Resolution of the Chief Law Society in favour of Repeal adopted at a general meeting on the 12th inst.

This Society will also support the Irish Incorporated Law Society in connection with the Bill now before Parliament to abolish such duty. It is proposed to form branches of this Association in all large towns. The Chancellor of the Exchequer recently told a Deputation of Irish Solicitors that he did not like the tax, but waited for action to be taken in the matter.

It is proposed to hold a further meeting in London shortly of those who join the Association. All communications should be addressed

to the Hon. Sec. pro tem.

13th April, 1889.

CHARLES FORD,

The Outer Temple, London, W. .

£244,011 1 3

110,787 7 8 £133,223 13 7

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THE CAPITAL AND COUNTIES BANK, LIMITED.

Established 1834. Subscribed Capital, £3,500,000; Paid-up Capital, £700,000; Reserve, £500,000. Head Office-39, Threadneedle-street, London. Metropolitan Branches -35, King-street, Covent-garden; 50, Upper-street, Islington; 25, Ludgate-hill; 47 and 49, Newington-butts; 125, Oxford-street; 195, Edgware-road; 35, Piccadilly,

FIFTY-FIFTH ANNUAL REPORT of the Directors, presented to the Shareholders at the ANNUAL GENERAL MEETING, held at the Head Office of the Bank, at 39. Threadneedle-street, London, on Wednesday, the 24th day of July, 1889, at Twelve o'clock. Noon.

The Gross Profit for the Twelve Months, after making provision
for bad and doubtful debts. paying Income Tax. and deducting
Rebate at five per cent. on Bills current, amounts to.
From which has been deducted the General Expenditure of the
Company, including Directors' allowances and annuities to
retired officers, amounting to

Leaving a net profit of.

To which has to be added the balance of profit carried forward at 30th June, 1888

Together

From which there has been already deducted the dividend declared in January last at the rate of 18 per cent. per annum, free of income-tax

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2,619,248 13 10

5,207,182 18 10

4,891.510 47

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Bills discounted, loans, and other accounts
Liability of Customers for acceptances, as per contra
Banking premises in London and country

ASSETS

£819,542 5 5 .1,788,391 19 7

2,587,931 50

New 21 per Cent. Consols, and other British Govern.
ment Securities

1,148,027 8 11

63,000 0 0

Together

And appropriate towards the reduction of the cost of
Premises

Leaving to be carried forward to next account

5,000 0 0 131,000 0 0 10,041 8 11

141,041 8 11

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£10,484,974 12 2

E. B. MERRIMAN,

GAB. GOLDNEY, Directors.
JAMES A. STEEL

A. YOUNG, General Manager.

J. J. MACDONALD, Chief Accountant.

We have satisfied ourselves of the correctness of the Cash Balances, and have examined the Securities held against the Money at Call and Short Notice and representing the Investments of the Bank, and in accordance with the provisions of the Companies Act. 1879. we have examined the foregoing Balance-sheet and Profit and Loss Account with the Books of the Company, and beg to report that, in our opinion, such accounts are properly drawn up, so as to exhibit a true and correct view of the state of the Company's affairs as shown by the books of the Company. TURQUAND, YOUNGS, WEISE, BISHOP, and CLARKE, Auditors.

Net profits

Amount due on deposit and other accounts

Acceptances

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January dividend

£141,041 8 11

£63,000 00

Reduction of the cost of Premises

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TYPE-SETTING.

THE THORNE COMBINED COMPOSING AND DISTRIBUTING MACHINE IS THE BEST.

Its practicability is now being demonstrated in Europe by the Type-setting Syndicate, Limited, as has been done in the United States, where a saving of about 50 per cent, in expense of working over hand labour

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This machine sets up type equal in every respect to the best hand work, and also distributes the type after use, and is adapted for the finest book as well as newspaper work.

The Thorne Machine Company have more orders than they can execute in the next six months.

This machine requires no mixing and melting of metals, involving technical knowledge and considerable expense and loss, but can be operated by workmen of average intelligence.

The Type Setting Syndicate is prepared to guarantee the work of the Thorne Machine to be superior to that of any other in the market, and as cheap. The Syndicate not having to pay a dividend on a capital of £1,000,000, does not propose to charge the extravagant Royalty of £80 per annum, and a deposit sufficient to cover the cost of the machine, but to sell the machines outright at a reasonable price.

ON VIEW at Messrs. Allen, Scott, and Co., 30, Bouverie-street, Fleet-street, E.C.; also at the Paris Exhibition (Edison's Bureau), and Printing House-square, where pamphlets and full particulars can be obtained.

LONDON AND LANCASHIRE FIRE INSURANCE COMPANY.

Head Office: 11, DALE STREET, LIVERPOOL.
London Office: 74, KING WILLIAM STREET, E.C.

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The Company does a Fire Business only. Having no Life Business, the Funds can only be used for Fire Losses. Not being a mutual Company, the policy holders incur no liability of partnership. CHAS. G. FOTHERGILL, Manager. J. B. MOFFAT, Sub-Manager.

THE LONDON AND LANCASHIRE FIRE INSURANCE COMPANY, which transacts Fire business only, invites applications for Agencies from gentlemen representing Life companies.

Printed and Published for the PROPRIETORS by C. BRETT, at the Offices of "PUMP COURT," No. 33, Exeter Street, Strand, London, W.C.

VOL. IX.

Pump Court

LONDON, WEDNESDAY, AUGUST 21, 1889.

PUMP COURT.

The Temple Newspaper and Review.

CURRENTE CALAMO

De Lege; de Omnibus Rebus et Quibusdam Aliis.

:0:

In view of the renewed agitation for the appointment of a Criminal Court of Appeal, we think it right to direct the attention of our new readers and subscribers to the fact that there appeared in PUMP COURT, some time ago, an able article on the subject, by the most experienced and astute criminal lawyer in the country, Mr. H. B. Poland, Q.C. There are still a few copies of that issue remaining.

It is useless for people to talk of a Court of Appeal in vague terms. Let them produce a Bill which even on the face of it is workable. Aspiration is not inspiration. Why has not that eminent and able lawyer, Lord Esher, produced a Bill? If he tries in this way to give effect to his aspirations and wishes, he will soon find the difficulties and objections crowd around him. It is astonishing how pen and ink and a blank sheet of paper tames the fancy, and it is only when you submit your vague longings to the test of formulating them that you begin to know what it is even you yourself really want.

MEANTIME we recommend people to read the masterly article of Mr. Poland, herein before referred to; the Bill on the subject introduced by Sir John Holker, when AttorneyGeneral; the speech of Sir John Cornewall Lewis, when Home Secretary. There was also a Bill introduced, we believe, by Sir Henry James, during the Home Secretaryship of Sir William Harcourt, providing for a Court of Appeal in murder cases only.

THE trial in the street of the Maybrick case still proceeds, and the imagination of every writer to the papers is straightway accepted as evidence. One person writes that probably there was a closet near where the beef juice was kept, and very probably the drains were out of order, in which case ptomaines would be apt to be engendered, which would make the otherwise harmless beef juice an irritant sufficient to produce gastritis. After a time he quite forgot that he was dealing with possibilities and probabilities, and he winds up as if it were conclusively proved that ptomaines caused the death, or may have caused the death. People like this have a singular notion of the meaning of "doubt." On the same reasoning we could show that the man may have died from a cut finger.

No. 149.

Another numerous body of people are making, singularly enough, a strong point of the mysterious John. Their argument takes somewhat this course. John was an intimate friend of Mrs. Maybrick and her family of long standing, so he could not have committed adultery with her, for of course women always select strangers from the street to go wrong with, not intimate friends of their brothers. As he did not commit adultery with her, she must be innocent. Then they supply some powerful evidence by John, which it does not occur to them as strange that John never came forward to prove himself on oath either at the coroner's inquest, at the investigation before the magistrates, or at any of the stages of the lengthy trial at the assizes. On the contrary, it appears that John expressed himself as being determined to avoid, at the risk of being thought selfish by Mrs. Maybrick, any further necessity of "lying and scheming." It is an easy enough matter, comparatively, to lie and scheme outside a witness-box, but when it comes to taking an oath and being cross-examined in public, John thought that, selfish or not, this would not do. And so he announced to Mrs. Maybrick that he meant to protect himself from the world's curious gaze; and he did so effectually. If John is a married man he acted wisely for himself, for wives are sometimes a very unreasonably suspicious sort of people, and cross-examination in public is an awkward thing. If he be a bachelor unengaged, he has less excuse for abstaining from coming forward to give the important evidence which, it is now pretended, he could have given. And Mrs. Maybrick's advisers are blameable for not finding out from her who John was, and compelling him to come forward with his valuable and important evidence. Of course the Man in the Street could have done better for Mrs. Maybrick if he had been her counsel or solicitor than Sir Charles Russell or the solicitor who was actually employed.

THE Lancet, which is the organ of the medical profession, and recognised as an authority in every English-speaking country that we know of has spoken with no uncertain sound in its issue of last Saturday. With a due sense of the responsibility and importance of its utterance, it examined carefully the evidence before pronouncing its judgment. That judgment is that the deceased was poisoned by arsenic. In the course of an able review of the evidence the Lancet says:

In Mr. Maybrick's case the proximate cause of death was clearly gastro-enteritis and irritative fever. But what was the cause of the gastro-enteritis? In our opinion the defence were in error when they endeavoured to establish as two distinct and alternate hypotheses quoad the cause of death-gastro-enteritis and arsenical poisoning; for arsenic poisons primarily and chiefly by setting up gastro-enteritis. There is one fact mentioned in the account of the post-mortem examination that seems to us of some weight-namely, that the enteritis was very marked in places, whilst in others it was absent or less pro-. nounced. This is more in accordance with the theory of inflammation from an irritant cause, rather than from exposure to wet and cold. The localisation of the congestion in parts" distant from one another would be explained by supposing that it was produced by the process of elimination of the poison by the intestinal glands in the lower part of the small intestine and in the rectum, whilst the duodenal injection would chiefly be due to the direct action of the poison in the same way as the stomach. Except as the result of an extensive irritant, or previous organic disease, such as cancer or ulcer, fatal gastritis must be extremely rare, and, indeed, we are of opinion that the above-mentioned causes should be excluded before the assumption of so-called idiopathic gastritis as a sole cause

of death should be entertained. Irritant food and drink were suggested, but no facts were elicited to support the

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assumption. No other person in the house or at the office suffered in a similar way, and analyses of commercial samples, specially procured for the purpose, of the artificial food taken by Mr. Maybrick, gave negative results. Turning now to the results of the chemical analysis of the viscera, etc., we find nothing inconsistent with the theory of arsenical poisoning in Mr. Maybrick's case. The total amount existing in the body post-mortem was calculated at something under two grains, or in itself nearly a fatal dose; but this would probably be-especially considering that the stomach and its contents contained no arsenic-only a fractional amount of what was taken, seeing how rapidly the poison is eliminated. As proof of this assertion we quote the following statements, made at a trial, by Professor G. F. Barker, of Yale College :"It (arsenic) has been detected in the urine within one hour after it has been taken. The liver acquires its maximum quantity, in the opinion of several authorities, in from fifteen to eighteen hours after administration." "It is eliminated from the liver, and may entirely disappear in from eight to fifteen days after being taken, depending on the quantity and other circumstances." ""It is not a cumulative poison." "Persons have died from the primary effects of arsenic in eight days, and no trace of the poison has been found in the body on analysis." Finally, on this head we must subscribe to Dr. Stevenson's testimony of opinion. He is facile princeps amongst contemporary toxicologists, a man of unrivalled experience in this special department of medical science, of world-wide reputation.

AFTER disposing of the scientific part of the case, the Lancet has thought proper to investigate the question as to whether it was self-administered or by the prisoner, and comes to the same conclusion that we arrived at, "solemnly asserting" its opinion to this effect.

"To all of these articles Mrs. Maybrick had access, and considering that she alone in the house was proved to have recently purchased arsenic-to the extent of seventy grains or more-one can scarcely convict the jury of having added 'insufficient motive to insufficient facts.' -The Lancet.

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HERE are a few mems. April: the Maybricks not getting on well together. About April 20th Mrs. Maybrick procures twelve fly-papers, which she says she wanted for flies which were troublesome. April 27th, the Wirral Races, when the disagreement culminated in a violent row, and Mrs. Maybrick made use of her threat to Mrs. Samuelson. Evening of April 27th, Mr. Maybrick seized with numbness, sickness, etc. Doctor attends him on 28th. On the morning of the 29th he gets up better; he has recovered; the poison, if poison it was, was eliminated from his system. On this day, however, 29th, Mrs. Maybrick makes a fresh purchase of fly-papers, but this time she doubles the quantity; she buys twenty-four instead of twelve. On April 30th and on May 1st and 2nd Mr. Maybrick goes to business. On May 1st some Revalenta Arabica was sent by Mrs. Maybrick (at all events, it passed through her hands) to his office in a jug. Although the jug had been washed, traces of arsenic were subsequently detected adhering to the rim of the jug. On May 2nd some beef-tea was sent to his office, and he was ill after taking it.

CAN anything be more indecorous than the endeavour to approach the Queen personally in this matter of the Maybrick trial? If Her Majesty were to interfere, except by constitutional methods, and by the advice of her Minister, we should have Jack the Ripper, if he be convicted, saying that it was only because he is a poor man that the Queen allows him to hang, but that it would be a different thing if he were a rich man and the son of a Countess.

A CORRESPONDENT writes that he saw people laughing while they signed the petition, and forcibly urges that in a population of thirty or forty millions all that is necessary is organisation, and you are safe to get thousands of signatures to anything under the sun. It by no means follows, therefore, that the petitions represent any proportionately large body of opinion. It is no particular person's interest to get up a counter-petition, or a very remarkable state of things would be seen. Meantime, people who prefer trial by jury to trial by plebiscite leave matters to take their course, although they strongly disapprove of the agitation.

agitations, and it is that the feeling of civilised man is against capital punishment. Indeed, it is well known that many a person has been acquitted owing to the reluctance of juries to take the responsibility of hanging a fellow-creature, whereas if the punishment had been instead penal servitude for life, there would have been a certain conviction.

THIS indeed is one of the problems of the age. Everyone must wish that capital punishment could be done away with; but people who have thought the matter over see difficulties in the way. Take, for instance, a case of a burglar being caught by the master of the house. If he commits murder so as to avoid capture, he escapes altogether; or even if caught, the difference of punishment for the extra offence of murder would be but a greater instead of a less number of years in prison. What burglar would not in this case strike for a chance for freedom? Similarly, if a person, not intending to kill, maims, would he not be tempted to put the finishing stroke, and destroy the only evidence against him? If a woman, with her adulterer, intends to flit away with her husband's money, again the chances of detection and imprisonment would be destroyed if she first killed her husband. It is the unfortunate witness of any crime who would stand in most danger of being put out of the way. It is but a rule of three calculation-the punishment for murder, viz., some years extra imprisonment, weighed against the chance or certainty, by means of the murder, of escaping altogether. If this difficulty could be got over, many people who now uphold capital punishment would be seriously influenced.

Ir is nonsense to say that death is not so terrible as lifelong imprisonment. While there is life there is hope, and no torture being allowed nowadays, it is astonishing how soon a life-prisoner unconsciously adapts himself to his circumstances. The aim in affixing death as the punishment for murder is to differentiate this crime from all others; to make the punishment different not only in degree, but in kind.

THE case of Reg. v. Turner, which was necessarily interesting from the circumstance that the defendant was charged here with misfeasance and malversation as to stamp monies, as acting consul at Buenos Ayres, had one point of interest. The defendant had originally pleaded "not guilty," and the plea had been recorded. After the case had been opened, however, his counsel, seeing there could be no doubt as to his guilt, desired to amend the plea to "guilty," aud some doubt was felt as to whether the Court could, after plea recorded, consent to its withdrawal and amendment. Mr. R. S. Wright ultimately, however, referred to an authority for this course in "The Regicides Case" (Kelyng's Rep. 11), "Which day all the prisoners were arraigned, and pleaded not guilty,' but afterwards some of them withdrew their plea, and confessed the indictment. which was accordingly recorded by the Court, and agreed by all the judges that it might be done, although the clerk had recorded the plea of not guilty, etc.' (and see Holdsworth's Case, 1 Lewin Crown Cases, 279). But what would Bentham have said to the existence of any legal difficulty in taking such a course in the circumstances?

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FEW decisions will be received with more surprise-it does not follow that it is erroneous, but it may safely be said that no one has hitherto placed the same interpretation on the words in question-than Tuck v. Southern Counties Deposit Bank, Limited. In 1885 an absolute assignment by deed was made of certain personal chattels to the plaintiff in the action. This deed was not registered as a bill of sale. In 1888 the assignor executed a bill of sale of the same chattels to the defendants as security for a loan from them. The assignor died, the defendants seized the chattels, and the plaintiff brought this action, claiming the chattels under the absolute assignment. Kay, J., was of opinion that the assignment to plaintiff, not being “a security for the payment of money," did not require registration, and, in answer to a contention that it was void by reason of 13 Eliz. c. 5, pointed out that even if that were so the defendants had not defended in the

ONE thing emerges, however, from this and previous capacity of creditors, or raised that ground of defence in

the pleadings. In the Court of Appeal, however, Cotton, Fry, and Lopes, L.JJ., held that the absolute assignment to plaintiff did require to be registered as a bill of sale, and that section 8 of the Bills of Sale Act, 1882, applied to every bill of sale. But the point of novelty was this. Cotton and Fry, L.JJ. (Lopes, L.J., dissenting), were of opinion that the second bill of sale was void on the ground that, by reason of the existence of the unregistered absolute assignment, the assignor was not at the date of executing the second bill of sale true owner of the chattels comprised therein within the meaning of the Bills of Sale Act, 1882, sect. 5. Lopes, L.J., was unable to take this view; in his opinion the provision of sect. 5 of the Bills of Sale Act, 1882, was intended to refer to after-acquired property, and not to apply to such a case as that.

DIRECTORS of limited companies have in Atkin v. Wardle et al. a reminder of the existence and effect of section 42 of the Companies Act, 1862, which provides that if a director signs on behalf of a limited company, wherein its name is not mentioned in manner indicated in sect. 41 of that Act, he shall be personally liable to the holder of the bill for the amount thereof. The plaintiff had entered into a contract with a certain limited company, to erect certain baths for them. In part payment of the price he drew a bill, addressing it to the "Salt Water Baths Company, Limited, South Shields." Defendants, who were directors of the company, accepted the bill as directors of the "South Shields Salt Water Baths Company," leaving out the word "Limited." The bill was dishonoured at maturity; the plaintiff sued the defendants on the bill, contending they were personally liable under section 12 of the Companies Act, 1862, and Denman, J., and subsequently, on appeal, Lord Esher, M.R., Lindley and Bowen, L.JJ., concurred in holding that this was so.

IN Colquhoun v. Brooks we have an important decision on the Income-tax Act, 16 and 17 Vict., cap. 34. The respondent, Mr. Brooks, who resides solely in England, is a partner in two distinct firms, viz., H. Brooks and Co., of 70, Bishopsgate-street Within, and the firm of Brooks, Robinson, and Co., of Melbourne, Victoria. For the financial year ending April 5th, 1884, a sum was remitted to him, and in addition to this sum there was standing to his credit in the books of the Melbourne firm, as representing the estimated profits due to him for the year ending April 5th, 1885, a considerable further amount, no portion of which had been received in England. Mr. Brooks was assessed to income-tax under Schedule D of 16 and 17 Vict., c. 34, for the year ending April 5th, 1885, not only on the profits received by him as partner in the London firm and on the sum received by him in this country from the profits of the Melbourne firm, but also on the further amount not transmitted to this country, but standing to his credit in the books of the Melbourne firm. The Incometax Commissioners for the City of London reduced the assessment by this amount, but stated a case. In the Divisional Court, Stephen, J., held that respondent was rightly assessed to income-tax on this further amount; but Wills, J., held (though as junior judge he withdrew his judgment) that he was not. The Court of Appeal reversed the decision of the Divisional Court, holding, as Wills, J., held below, that respondent was not assessable on this further amount. The House of Lords (Lord Halsbury, L.C., Lords Fitzgerald, Herschell, and Macnaghten) upheld the decision of the Court of Appeal, though not on the same grounds. In the judgment delivered by Lord Herschell, he pointed out in detail the greater anomalies which would result from holding the further sum not received in this country assessable; and also showed that the machinery requisite for assessing trade profits arising and remaining abroad had not been provided, nor was there any provision for separate assessment of a single partner in respect of the gains of the partnership.

In Metropolitan Board of Works v. Howard we have another decision on the Lands Clauses Act, 1845. The action was brought on an inquisition finding £1,031 to be due from defendants to plaintiff in respect of certain property of his having been injuriously affected by certain street improvements made by defendants. Plaintiff was the tenant of a fully licensed public-house in Bridge

street, which had been the main street on the Middlesex side of the Thames leading to old Putney Bridge. The Metropolitan Board of Works built a new bridge across the Thames at Putney, a short distance higher up the river, and made a new thoroughfare on the Middlesex side leading to this new bridge. The old bridge was then closed, and, Bridge-street terminating at the water's edge, the traffic was diverted at a point before plaintiff's house was reached, passing along the new thoroughfare, and so over the new bridge. On the inquiry before the jury plaintiff produced evidence that in consequence of the diversion of the traffic the trade of the public-house had greatly diminished, and obtained from the jury an award of £1,031 as compensation. The defendants contended the inquisition was bad, as based solely, or to a great extent, in loss of profits of trade which could not be the subject of compensation. The House of Lords (Lords Herschell, Fitzgerald, and Macnaghten) held that an interference such as that shown with the access to the respondent's house was an injurious affecting of his premises, giving a right to compensation if he could show that the house itself had been affected in value, having regard, not to the particular use which he was making of the house, but having regard to all the purposes for which such land might be used, that in this case the sheriff and jury had jurisdiction to entertain the claim and award compensation, and that the only question the House of Lords could consider was whether there was any evidence before the jury which warranted the award of any damages. If a house were rendered less accessible to customers, that might diminish the value of it for all purposes, though the evidence as to actual loss of trade ought not to have been admitted.

THE fallacy which underlies the arguments of many who plead for Florence Maybrick arises from the fact that they all along suppose that the contention of the other side is that the cause of death was acute arsenicais. But this is a mistake. No one suggests in face of the evidence that the man died from what we may call acute arsenic The poisoning; arsenic was but the ultimate cause. immediate or proximate cause was gastro-enteritis. This is the way that slow poisoning by arsenic works.

IT is said that if the Home Office interferes with the progress of the law in the Maybrick case, it will be on the lines suggested by us in our issue of last week at page 61, paragraph three.

LEGAL HONOURS.

Information intended for publication under the above heading should reach us not later than Tuesday morning in exch week.

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Mr. William Digby Seymour, LL.D. (Dublin), Q.C., has bee appointed Judge of County Courts for Circuit No. 1, in succession to Judge Holl, who has been transferred to Berkshire.

Mr. Richard Loveland Loveland, barrister, has been elected Chairman of the Second Court at the Middlesex Quarter Sessions. Mr. Loveland is a magistrate for the counties of London and Middlesex.

Mr. William Frederick Webster his been appointed one of the Revising Barristers for Middlesex and London.

Mr. Walworth Howland Roberts has been appointed one of the Revising Barristers for Middlesex and London.

Mr. John William Richards, barrister, has been appointed Counsel to the Commissioners of Charitable Donations and Bequests in Ireland. Mr. Richards was called to the bar at Dublin in 1880.

Mr. Philip Samuel Solomon has been appointed a Queen's Counsel for the Colony of Fiji.

Mr. George Sydney Davies, solicitor, of Crickhowell and Brynmawr, has been appointed Clerk to the Lieutenancy for Brecknockshire. He is registrar of the Crickhowell County Court and clerk to the county magistrates and to the Commissioners

of Taxes.

The Home Secretary has appointed Mr. Frederick Mead, of 11, King's Bench Walk, to fill the vacant seat in the Metropolitan Police magistracy. Mr. Mead was called at the Middle Temple in Trinity, 1869.

Mr. ROWLAND WHITEHEAD, of the Inner Temple, has been appointed Honorary Secretary to the Mansion House Committee on Railway Rates. Mr. Whitehead is the son of the Right Hon. Alderman James Whitehead, Lord Mayor of London.

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