11. 1s. 7d. (against 1l. 4s. 5d.). Exports fell from 97,608,000 tons in 1923 to 79,340,000 in 1924. This decline was, however, partly made good by an increase in home consumption, the total production being 9,367,000 tons lower, i.e., 269,133,000 tons. Unemployment was severe in the second half of the year; the spring demand caused the percentage to fall from 4.6 in January to 20 in April, but steady increases thenceforward brought the rate to 10.3 per cent. in October, after which there was improvement, the December figure being 7.9 per cent.

Shipping had, on the whole, a better year, the autumn being, as in 1923, the most favourable season. The demand for tonnage due to the Japanese earthquake that marked the closing months of 1923 did not extend far into 1924, and dullness ensued until the late summer. After the signing of the London Agreement, however, freight markets became brisk. Heavy Continental-and especially German-purchases of grain caused rates to rise sharply and idle tonnage to decline. By October the demand had largely subsided, and freight rates eased until the end of the year, when a demand developed for tonnage to load Australian grain for Europe. The beginning of 1925 found rates for loading at Victoria or South Australia some 6s. higher than a year before, at 48s. 6d. to 49s. a ton. Rates from the Argentine and from India were slightly higher on balance, other homeward freight rates showing little change. Coal freights were dull.

With the boilermakers' dispute finally settled (after a nine-months' lock-out in 1923) the way was clear last year for the recommencement of work on ships the construction of which had been suspended in the preceding year. The increase in tonnage launched was surprisingly large, the figure being 1,490,000 tons (against only 685,000 tons). As foreign launchings were about 330,000 tons lower, the production of the Empire exceeded the total from all foreign yards by nearly 500,000 tons, whereas in 1923 the Empire output was only half that of the rest of the world. Building was unhampered by labour disputes, and costs of production were reduced through greater efficiency of the workers. The figures of tonnage under construction at the end of the year were, however, not so favourable as the statistics of actual launchings in the previous twelve months; they showed a fall, due partly from higher costs arising from an increase of wages, of nearly 100,000 tons to 1,297,000 tons, whereas there was a slight increase in tonnage under construction abroad. The proportion of workers unemployed was unchanged on the year at 31.9 per cent., after having been down to 26-4 per cent. in July.

Depression again ruled in the iron and steel industry, prices being substantially lower at the end than at the beginning of the year. Production and export suffered, in comparison with those of 1923, by the removal of the stimulus resulting from the Ruhr occupation; and producers of crude and partly-finished material particularly met with increased competition from the Continent. Production both of iron and steel in the first half of the year was about equal to that of the corresponding period of 1923. In the last six months imports, which had previously consisted mainly of semi-finished material, increased in the case of shipbuilding material and other finished steel, and British exports and production were curtailed. The course of prices may be

gathered from the quotation for No. 3 pig-iron, which declined from 51. per ton in January to 41. in December. The number of furnaces in blast fell, in the same period, from 199 to 167, pig-iron producers suffering from large utilisation of scrap. For the whole year the production of pig-iron amounted to 7,320,000 tons (as compared with 7,438,000 tons), and of steel to 8,220,000 tons (against 8,489,000). Exports of iron, steel, and manufactures fell from 4,320,000 to 3,853,000 tons, while imports (coming chiefly from Belgium and France) rose from 1,323,000 to 2,430,000 tons. In the closing months, however, Continental costs of production showed a tendency to rise. Unemployment in the industry, already large, increased further: the percentage in December was 18 in the pig-iron branch (against 11.4 per cent. a year previously) and 27.6 in the steel business (against 17.1 per cent.). The output of Cleveland iron ore was estimated at 2,250,000 tons, an increase of 170,000 tons.

An outstanding event in the insurance world was the appointment -arising out of the failure of certain companies-by the Board of Trade (in July) of a committee to inquire into suggested amendments to the Assurance Companies Act, 1909. Points to which the inquiry was particularly directed included: fuller powers for the Board of Trade in cases of insolvency; separation of classes of business in balance-sheets; special deposits by foreign companies; amendment of actuarial statements in the fourth and fifth schedules; and bond investment business. In life assurance a larger volume of business was transacted than in 1923, and most of the companies reduced their ratios of expenses. Some participating policies received attractive bonuses. Interesting developments were the prominence given to the effecting of endowment assurances by a single premium, the greater part of which could be borrowed from the office concerned; and the institution of a system of reversionary bonuses in industrial assurance. Fire claims were the lowest since 1917, The Times estimate of the cost of the principal fires in the United Kingdom, at 5,017,000l., being 2,174,000l. lower than for 1923. The questions that had arisen in connexion with the Japanese earthquake of the preceding year were finally disposed of during 1924, the companies gratuitously returning to the insured a full year's premium. Competition in the fire business was responsible for a decline in premium rates, and the marine insurance business had a similar experience. Amalgamations of the year include the purchase of the State Assurance Company by the Royal Exchange Assurance Corporation, and the acquisition of the Western Alliance Reinsurance Company by the Consolidated Insurance Company, under whose auspices it had been established in 1919. It was proposed that the Standard Life Assurance and the Scottish Temperance Life Assurance Companies should be mutualised.

LAW.

WITH the rest of the community the Legal Profession passed through a period of acute depression during 1924. So far as the common law work of the country was concerned, this was greatly accentuated by the shortage of judges in the King's Bench Division, which therefore was quite unable to keep abreast of its work, and at the close of the year actions which had been set down for trial for nearly eight months were unheard. Actions for trial in the King's Bench at the end of 1924 numbered 1,040, as compared with 668 a year before, while in the Probate and Divorce Division, there were 713 causes as against 623 in December, 1923, and this in spite of the fact that many undefended and pauper causes were heard at Assizes. Owing to the fact that the two additional judges authorised by the Judicature Act, 1910, can only be replaced by an address by both Houses of Parliament, during 1924 the Division was reduced to the Lord Chief Justice and fifteen puisne judges, and, further, owing to illness and the necessity for detailing a King's Bench Judge for the Divorce Court, the strength available for the best part of the year consisted of but fourteen judges all told. Just before the adjournment, in December, Parliament authorised an increase under the Act of 1910, bringing the number up to eighteen.

Perhaps the most notable feature of the legal year was the visit of the American Bar Association in July last. More than a thousand members of the Association accepted the invitation of the Inns of Court and the Law Society, who were assisted by the Canadian Bar Association in entertaining their American brethren. Apart from the purely social side of the visit, the meetings in Westminster Hall, and the unveiling of the Blackstone Statue in the Royal Courts of Justice-the gift of the American lawyers to the British lawyers-were occasions that will long be remembered, and the general interchange of ideas was probably productive of goodwill and understanding.

In view of the political situation, the output of legislation was not large. During the regime of the Labour Government, only forty-one statutes were passed into law, almost all of a non-controversial character. The Treaty of Peace (Turkey) Act carried into effect the Treaty signed at Lausanne in July, 1923; the position of the officers of the County Courts was placed on a suitable basis by the County Courts Act; while the Carriage of Goods by Sea Act gave statutory authority to the rules relating to the bills of lading, agreed to at the International Conference on Maritime Law held at Brussels in 1922 and amended in the following year by the Committee appointed by the Conference. Mention must also be made of two important provisions in the Finance Act. Inhabited house duty was repealed in respect of any year subsequent to 1923-24,

and corporation profits tax was terminated with reference to profits arising in an accounting period after last June. Other Acts of Parliament worthy of note are: the London Traffic Act-an attempt to control and regulate the traffic in and near the Metropolis through the Minister of Transport and the Advisory Committee; the National Health Insurance Act by far the largest of all the statutes passed, extending to 134 sections and seven schedules-which consolidates the numerous Acts passed dealing with this subject since 1911; the Housing (Financial Provisions) Act; the Irish Free State (Confirmation of Agreement) Act, which was necessary owing to the refusal of the Government of Northern Ireland to appoint its representative on the Irish Boundary Commission and the subsequent ruling of the Judicial Committee of the Privy Council; and lastly, the short statute which postponed the monumental Law of Property Act, 1922, for another twelve months, and the amending Act, a somewhat bulky measure, which prepared the ground for the Consolidation Bills.

One Bill requires special mention-the War Charges Validity Bill. For the fourth time under successive Governments it has been introduced in the House of Commons and passed, but rejected in 1924 by the House of Lords. It seeks to give legislative authority to charges imposed by Government Departments without the authority of Parliament. Charges of this kind have been declared by the Courts to be taxation, and as such illegal, and the Bill can only be described as retrospective legislation of the worst description.

Several other matters in 1924 had more than passing interest for the Law. In January, the Select Committee on the taxation of betting published their unfinished report in which they agreed that such a method of raising revenue was practicable, but they refused to say that it was desirable. The House of Lords, however, on a motion by Lord Newton, was of opinion that it was "desirable and practicable," but professional opinion was disposed to agree with the Committee. Lottery prosecutions again brought into prominence the inequality that exists in the administration of the law on this matter. During the early part of the year a considerable wave of blackmail began to make itself manifest, but the very severe sentences imposed upon those convicted checked it at the outset. In fact, in the case of two men who appealed to the Court of Criminal Appeal against their sentences, the Court added yet another year of penal servitude. Again the long tale of "scuttling " actions seemed to be coming to an end. This form of maritime crime was confined to the subjects of two or three nations, and was part of the aftermath of war. Depreciated vessels and fallen freights were strong inducements to attempt to defraud underwriters.

Apart from cases of purely legal interest, three actions were disposed of by the Courts that attracted considerable public attention. Harnett v. Bond, tried by Mr. Justice Lush with a Special Jury, occupied the Court at the end of 1923 for sixteen days and resulted in a verdict for the plaintiff for very heavy damages for assault and false imprisonment against the defendants, one of whom was the manager of a licensed house for lunatics and the other, one of the Commissioners in Lunacy. This verdict was set aside in May, 1924, by the Court of Appeal after seven

days' argument, and judgment was entered for the manager and a new trial ordered against the Commissioner. A further appeal was made, but after the trial a Royal Commission was appointed to consider the whole of the present lunacy law and administration. At the end of the year Mr. Justice Rowlatt was occupied for a very considerable period in hearing American Tobacco Co. v. Guardian Assurance Co., the question being whether the fires that occurred in Smyrna, after the Greek debacle and the occupation of that town by the Turks, were within the fire insurance policies or were excluded by the exceptions. Much evidence was given, but the learned judge found that the defendant company were not liable. The case of Robinson v. Midland Bank was the most notorious of the year. Its appeal to the imagination of the public was largely due to the suppression of the name of one of the chief actors for "reasons of state." The details of the case were both unpleasant and sordid, and the true identity of "Mr. A." was known to most people from the outset. For eight days the proceedings before Lord Darling flooded the press, the facts and surmises were widely discussed, and an exceedingly commonplace story of the underworld assumed the proportions of a cause célèbre.

From the Professional point of view the number of leading decisions was not large, but their interest was undoubted. Matrimonial relations were considered in two cases by the House of Lords. In Russell v. Russell, by a majority of three to two, it was held that the rule which does not allow a husband or a wife to give evidence of non-intercourse after marriage in legitimacy cases, applies equally to divorce proceedings, while in G. v. G. an important ruling was given as to the inference of incapacity to be drawn in nullity suits from refusal of intercourse. The same final tribunal in Duff Development Company v. Government of Kelantan demonstrated the difficulty of bringing a sovereign government within the jurisdiction of the Courts, even although it had agreed to restrictions on the exercise of its sovereign rights; and Rose & Frank Company v. J. R. Crompton & Brothers Ltd. definitely laid it down that engagements of honour only, in whatever form they may be expressed-pledges, understandings, or obligations-cannot be enforced in a Court of law where that is the clear intention of the parties. Two other decisions of the House of Lords are worthy of note. In Edwards v. Porter, again by a majority of three to two, the Law Lords refused to reverse the ruling given in Seroka v. Kattenburg in 1886, a case that has been the subject of some judicial comment. It must now be taken that until Parliament decides to the contrary, a husband is liable for the torts of his wife, quite apart from the law of agency, the sole exception being where the tort is so intimately connected with a contract that it forms part of the same transaction. Sutherland v. Stopes-the birth restriction libel-was finally disposed of during the year. At the trial the jury found that the words were defamatory, that they were true in substance and in fact, that they were not fair comment, and they awarded damages. On these findings the House of Lords approved the holding of the Lord Chief Justice, that the defendant was entitled to judgment. This practically endorses the view of Lord Loreburn in Dakhyl v. Labouchere that "the plea of fair comment does not arise if the plea of justification is made good."