PHIBES (Henrietta), Wilton-pl, Hyde Park Corner. May 20; Campbell, Hooper, and Todd, 30, Golden-sq, W. 1. PICKERING (Henry) (otherwise Henry Abney Hopton Pickering), Leigh-on-Sea and Covent Garden. Claims within two months to E. Fail, 18, Walbrook, E.C. 4. Dated March 19. POWELL (Eliza), Woodford Green. May 20; Ashurst, Morris, Crisp, and Co., 17, Throgmorton-st, E.C. 2. POTTS (John Bright), Manchester. May 24; Wood and Lord, Manchester. PHILLIPS (Amy Mary), Rushall. May 26; Nicklin and Cotterell, Walsall. PERRY (Mary), Birmingham. May 31; C. Upfil, Jagger, and Son, Birmingham, PENFOLD (Ellen), Chertsey. May 12; S. and H. S. Cartmel, Brampton, Cumberland. PEEL (Florence William), Bournemouth. May 23; Deputy Public Trustee, Manchester. Orford and Sons, Manchester, sols. RANDALL (William Henry), Abingdon. May 24; Challenor and Son, Abingdon. ROBERTS (Abraham), Clitheroe. May 29; Baldwin, Weeks, and Baldwin, Clitheroe. ROLLES (Ellen Cornelia), Cheltenham. May 23; Sparkes, Pope, Thomas, and Mathew, Exeter. ROSENTHAL (Alfred), Johannesburg, formerly Finsbury-ct. May 24; W. C. Crocker, 21, Bucklersbury, E.C. 4. ROGERS (David), Tonbridge. May 31; Warner, Son, and Brydone, Tonbridge. ROUILLARD (Fanny Katherine), Durban, South Africa. May 24; Michael Abrahams, Sons, and Co., 110, Bishopsgate, E.C. 2. ROBINSON (Mary), Heysham. May 31; Whiteside and Knowles, Morecambe. ROOME (Francis William), Derby. May 22; Taylor, Simpson, and Mosley, Derbys ROYDS (Lady Annette Nora Jane), Eaton-pl. March 20; Wilson, Wright, Davies, and Earle, Manchester. SCHRIMSHAW (Ellen), Bromley. May 21; Lendon and Carpenter, 31, Budge-row, Cannon-st, E.C. 4. SHERWOOD (Benjamin), Old Colwyn. May 18; T. H. Morgan and Co., Colwyn Bay. SHARP (Susannah), Southampton. May 20; C. J. Sharp, Southampton. STEPHENSON (Jane), Manchester May 26; A. Richardson, Manchester. SMITH (Frederick William), Southampton. May 27; Page and Gulliford, Southampton. SEWELL (Robert), Kensington. May 25; Francis and Crookenden, 23, Lincoln'sinn-flds, W.C. 2. STEVENS (Henry Edmund), South Africa. May 24; Michael Abrahams, Sons, and Co., 110, Bishopsgate, E.C. 2. SLACK (Henry), South Wingfield. May 24; Rickards and Cleaver, Alfreton. SCOTT (Capt. Gordon), Millbank. May 31; Kenneth Brown, Baker, Baker, Lennox House, Norfolk-st, Strand, W.C. 2. STARKIE (Anne Charlotte Amelia), Speke. May 31; Gair, Roberts, and Co., Liverpool. THOMPSON (James), Teddington. May 23; Smythe and Brettell, Girdlers' Hall, 39, Basinghall-st, E.C. TERRY (William Fenwick), Birkenhead. May 25; T. G. Henry, Liverpool. TURNBULL (William), Middlesbrough. May 29; Miles, Hutchinson, and Lithgow, Middlesbrough. TANNER (Anne James), Southampton. May 20; C. J. Sharp, Southampton. VAUSE (Florence), Hammersmith, formerly of Chiswick. May 30; Ellis, Bicker- WILKINS (Lorenzo Edmund), Ealing. May 20; Trustee Dept., Barclays Bank, 54, Lombard-st, E.C. 3, or Durrant, Cooper, and Hambling, 70-71, Gracechurchst, E.C. 3. WILLIAMS (Charles Roberts), Ashby-de-la-Zouch. May 18; Fishers, Ashby-de-laZouch. WALMSLEY (Thomas), Llanfyllin. Claims within two months to Hair and Co., 1, Cornhill, E.C. 3. Dated March 23. WHITELEY (David), Rishworth. May 31; Longbotham and Sons, Halifax. WATSON (Sam), Bradford. May 24; Deputy Public Trustee, Manchester. Howe, Denby, and Bairstow, Bradford, sols. WITHAM (John Wignall), Birksdale. May 30; Banks, Kendall, Taylor, and Gorst, Liverpool. YOUNG (Cyril George), Emsworth. June 1; Benjn. Kent and Co., Portsmouth. BANKRUPTS THE BANKRUPTCY ACT, 1914. RECEIVING ORDERS. GAZETTE, MARCH 19. ANDERSON, CHARLES STEPHEN MILLER, Cambridge, house repairer. Ct. Cambridge. March 15. ASHBRIDGE, JOHN GEORGE, Stoke-on-Trent, insurance inspector. Ct. Hanley and ARNOLD, ALFRED, Redgrave, late smallholder. Ct. Ipswich. March 16. BOWDEN, WILLIAM, Bedford-sq. Ct. High Court. March 9. BROWN, A. and A., Birmingham, builders. Ct. Birmingham. March 16. Ct. Huddersfield. BIRKETT, ROBERT A., Poynton, dentist. Ct. Macclesfield. March 11. BULLOCK, MARK, Brierley Hill, dealer. Ct. Stourbridge. March 12. March 15. COTTON, THOMAS, late Hastings, estate agent. Ct. Hastings. March 16. FIELDHOUSE, WILLIAM EDWIN, Bradford, late cabinet maker. Ct. Bradford. FUTTER, WILLIAM FREDERICK, Docking, draper. Ct. Norwich. March 17. HOLLANDER, JOEL BARNETT, Ferncroft-av, Hampstead, no occupation. Ct. High Court. March 12. HANNAH, FRANK DAWBARN, Liverpool, grocer. Ct. Liverpool. March 17. HOLMES, RICHARD, Shirebrook, fish merchant. Ct. Nottingham. March 15. HUDSON, ALFRED, Swinton, casement works manager. Ct. Salford. March 15. JERRARD, CHARLES Henry, Westcliff-on-Sea. Ct. High Court. March 17. JONES, SARAH, Llanerfyl, grocer. Ct. Newtown. March 15. Ct. High Court. LEITE, JOSE PINTO, Count dos Olivaes e de Penha Longa; LEITE, JULIO PINTO, High Court. March 17. MARSH, JAMES, Leigh, wheelwright. Ct. Bolton. March 15. Ct. MARTIN, WILLIAM OWEN, late Kettering, confectioner. Ct. Derby and Long Eaton. March 16. MELHUISH, ARTHUR TUCKER (trading as the Newton Abbot Concrete Company), MELL, GEORGE, late Adlingfleet, potato merchant. Ct. Manchester. March 15. POLLARD, THOMAS HENRY, Cromwell, farmer. Ct. Nottingham. March 15. RAYNOR, GERTRUDE BRUMPTON (trading as Madame Swan), Great Grimsby, ladies' costumier. Ct. Great Grimsby. March 15. RODLEY, JOHN ERNEST, Leeds, credit draper. Ct. Leeds. March 16. RUSHMORE, ALFRED FRED FOX (trading as Rushmore and Son), King's Lynn, upholsterer. Ct. King's Lynn. March 15. RIMMER, JOSEPH, Southport, baker. Ct. Liverpool. March 17. SAUNDERS, GEORGE, Middlesbrough, late boarding-house proprietor. Ct. Middlesbrough. March 15. SIMPSON, JOHN, Oldham, ring frame overlooker. Ct. Oldham. March 15. Ct. Newcastle-upon TOMSEN, F. (trading as C. G. Lewington), Brentford. Ct. Brentford. March 15. WHITTAKER, RICHARD HENRY (trading as R. H. Whittaker and Co.), Huddersfield, Amended notice substituted for that in Gazette, March 12. GAZETTE, MARCH 23. ALLEN, HARRY, Dudley, metal works manager. Ct. Dudley. March 19. BRADLEY, FRANCIS HENRY (sued as and trading as E. Bradley), Eastbourne, decorator. Ct. Eastbourne. March 19. COOKE, GEORGE WILLIAM, Oxford-st, ladies' outfitter. Ct. High Court. March 18. CATLOW, THOMAS, Blackpool, cotton dealer. Ct. Blackpool. March 17. CONNICK, DANIEL, late Troedyrhiw, licensed victualler. Ct. Merthyr Tydfil. March 19. EDWARDS, DAVID WILLIAM, Bangor, baker. Ct. Bangor. March 19. GARDINER, JOHN, Grosvenor-pl, mortgage broker. Ct. High Court. March 17. March 19. HOWARTH, EDWARD, Accrington, tailor. Ct. Burnley. March 19. PARRY, EDWARD (trading as Edward Parry and Son), Bangor, painter. Ct. PRINGLE, WILLIAM, Great Grimsby, confectioner. Ct. Great Grimsby. March 18. ROBERTS, ALBERT, Norwich, late fish merchant. Ct. Norwich. March 19. SELLAR, NATHAN, late High-st, Chadwell, collector. Ct. High Court. March 19. SYMONS, LEO S., late West Bolton-grdns, Kensington. Ct. High Court. SMITH, HENRY, Batley, market attendant. Ct. Dewsbury. March 18. SMITH, ALFRED ELLIS (late trading as Frederick Smith), Walsall, taxi-cab proprietor. Ct. Walsall. March 18. SKIPSEY, ARTHUR CAMPBELL, Jarrow, pharmaceutical chemist. Ct. Newcastleupon-Tyne. March 17. THOMAS, DAVID, St. Helens, grocer. Ct. Liverpool. March 19. WHARMAN, SAMUEL, late Chichele-rd, Cricklewood, no occupation. Ct. High WOLF, WILLIAM, Fenchurch-st, wood flour merchant. Ct. High Court. March 18. WHARTON, JOSEPH, Maryport, draper. Ct. Workington and Cockermouth. ADJUDICATIONS. GAZETTE, MARCH 19. ANDERSON, CHARLES STEPHEN MILLER, Cambridge, house repairer. Ct. Cambridge. March 15. ASHBRIDGE, JOHN GEORGE, Stoke-on-Trent, insurance inspector. Ct. Hanley and Stoke-upon-Trent. March 16. ARNOLD, ALFRED, Redgrave, late smallholder. Ct pswich. March 16. BEVAN, ERNEST EDWARD, Rochester, coal merchant. Ct. Rochester. March 16. BORNE, HARRY, Nailsworth, boot repairer. Ct. Gloucester. March 15. Ct. FIELDHOUSE, WILLIAM EDWIN, Bradford, late cabinet maker. Ct. Bradford March 16. HEWITSON, WILLIAM (trading as Able and Co.), late Long Acre, Covent Garden, business broker. Ct. High Court. March 17. HILL, ARTHUR EDWARD, Keppel-rd, East Ham, transport worker. Ct. High Court. March 17. HOLMES, RICHARD, Shirebrook, fish merchant. Ct. Nottingham. March 15. HUDSON, ALFRED, Swinton, casement works manager. Ct. Salford. March 15. JOHNSON, CHARLES, Bradford, picture frame maker. Ct. Bradford. March 17. JONES, REGINALD HOWARD, Derby, draughtsman. Ct. Derby and Long Eaton. March 16. JONES, SARAH, Llanerfyl, grocer. Ct. Newtown. March 15. LESLIE, GEORGE GREGORY (described in Rec. Order as George Leslie), late Bradford, secretary. Ct. Leeds. March 10. LEWIS, SAMUEL, Cymmer, coal miner. Ct. Neath and Port Talbot. March 16. LEWIS, DANIEL, Keppel-rd, East Ham, transport worker. Ct. High Court. March 17. MCLAUCHLAN, JAMES EDWARD, Cardiff, advertising contractor. Ct. Cardiff. March 12. MARTIN, WILLIAM OWEN, late Kettering, confectioner. Ct. Derby and Long Eaton. March 16. MELHUISH, ARTHUR TUCKER (trading as the Newton Abbot Concrete Company), Newton Abbot, painter. Ct. Exeter. March 15. OWSTON, JOHN CHARLES, late Birkenhead, cattle foods salesman. Ct. Birkenhead. March 16. OPENSHAW, JAMES PHILIP, and OPENSHAW, JOHN ROBERT (trading as Openshaw Brothers), Bolton, builders. Ct. Bolton. March 13. PICKARD, JAMES ARTHUR, Keighley, hide merchant. Ct. Bradford. March 16. PERKINS, HARRY, Blisworth, farmer. Ct. Northampton and Towcester. March 16. RODLEY, JOHN ERNEST, Leeds, credit draper. Ct. Leeds. March 16. RIMMER, JOSEPH, Southport, baker. Ct. Liverpool. March 17. RENOUF, STANLEY JOHN, Reading, late grocer. Ct. Reading. March 15. SAUNDERS, GEORGE, Middlesbrough, late boarding house proprietor. Ct. Middlesbrough. March 15. SIMPSON, JOHN, Oldham, ring frame overlooker. Ct. Oldham. March 15. THOMPKINS, BENJAMIN GEORGE, Stanley, radio engineer. Ct. Newcastle-upon- WHITEAR, ERNEST FRANK, Darlington, builder. Ct. Stockton-on-Tees. March 16. WEGODA, ALEXANDER, Regent-st, general merchant. Ct. High Court. March 15. WILLIAMS, FREDERICK EDWARD, Cradley Heath, confectioner. Ct. Dudley. March 15. Amended notice substituted for that in Gazette, Jan. 27, 1925. WILLIAMS, THOMAS HENRT ROWE (described in Rec. Order as Terence Hertford Williams), Kingsway House, Kingsway, furniture dealer. Ct. High Court. Jan. 22, 1925. Amended notice substituted for that in Gazette, April 17, 1925. WALLACE, JAMES MADDER TINLINE (described in Rec. Order as James M. Wallace) late Chalcot-grdns, Hampstead, bank clerk. Ct. High Court. April 9, 1925. Amended notice substituted for that in Gazette, Jan. 8. DE DURCAL, FERDINAND SEBASTIEN DE BOURBON, DUC (described in Rec. Order as Fernando de Borbon de Durcal) (sued as Le Duc de Durcal), Jermyn-st. Ct. High Court. Jan. 4. Amended notice substituted for that in Gazette, March 12. LAWRENCE, WILLIAM JAMES HOSKIN, Ludgvan, basket maker. Ct. Truro and Falmouth. March 9. GAZETTE, MARCH 23. BROWN, WILLIAM ALBERT, and BROWN, GEORGE EDWARD (trading as A. and A. CONNICK, DANIEL, Merthyr Tydfil, late licensed victualler. Ct. Merthyr Tydfil. FENTON, FREDERICK PLUMMER, Jarrow, draper. Ct. Newcastle-upon-Tyne. March 18. FUTTER, WILLIAM FREDERICK, Docking, draper. Ct. Norwich. March 18. HUBBARD, CHARLES, Norwich, electrician. Ct. Norwich. March 19. March 20. LOWE, ALEXANDER CHARLES, Stoke-on-Trent, general dealer. Ct. Hanley and MARSH, JEAN, Kingston-upon-Hull. Ct. Kingston-upon-Hull. March 18. PHILLIPS, SYDNEY TAYLOR, Rhyl, late haulage contractor. Ct. Bangor. March 19. REEVE, THOMAS FREDERICK, Pattishall, late carrier. Ct. Northampton and ROBERTS, ALBERT, Norwich, late fish merchant. Ct. Norwich. March 19. SMITH, ALFRED ELLIS (late trading as Frederick Smith), Walsall, taxi cab proprietor. Ct. Walsall. March 18. SUMMERS, CHARLES JAMES, High-st, Camden Town, furniture dealer. Ct. High Court. March 19. THOMAS, DAVID, St. Helens, grocer. Ct. Liverpool. March 19. WILKEY, HENRY BERTRAM, Devonport, licensed victualler. Ct. Plymouth. March 20. WHARTON, JOSEPH, Maryport, draper. Ct. Workington and Cockermouth. March 17. い WHARMAN, SAMUEL, late Chichele-road, Cricklewood, no occupation. Ct. High Court. March 18. WILKINSON, ALFRED (described in Rec. Order as A. Wilkinson), Marchmont-st, Russell-sq, inventor. Ct. High Court. March 18. WHITE, JOHN STANLEY (described in Rec. Order as J. Stanley White), Thurgoland, engineer's representative. Ct. Barnsley. March 20. WHITTAKER, RICHARD HENRY (trading as R. H. Whittaker and Co.), Huddersfield, worsted manufacturer. Ct. Huddersfield. March 20. GAZETTE, MARCH 23. POWELL, HENRY WEYLAND MARTIN, Bicester. Ct. Oxford. March 15. (Adjudication annulled, and Rec. Order rescinded.) BIRTHS, MARRIAGES, AND DEATHS MARRIAGE. HULBERT-CLUTTON-BROCK.-On the 10th inst., at St. Paul's, Onslow-square, by the Rev. the Hon. W. Talbot Rice, Charles Geoffrey Keith Hulbert, son of Mr. Charles Hulbert, Senior Master in Chancery, to Phyllis, widow of John Alan Clutton-Brock. DEATHS. EARDLEY-WILMOT.-On the 10th inst., at Bournemouth, His Honour Judge LAWRENCE. On the 13th inst., at Greensmount, Christ Church-road, Cheltenham, the Hon. Alfred Clive Lawrence, C.B.E., King's Proctor and Treasury Solicitor. NICHOLLS. On the 15th inst., at Clevelands, Sevenoaks, also of 14, Old Jewrychambers, E.C., Arthur Edward Nicholls. NOTICE TO SUBSCRIBERS PREPAID TERMS OF SUBSCRIPTION, INCLUDING POSTAGE, ARE AS FOLLOWS: For LAW TIMES and Indices, LAW TIMES REPORTS and Indices and Statutes and Index (annual rate 52 issues). £5 0 0 For LAW TIMES and Indices and Statutes and Index, but without REPORTS and Indices (annual rate 52 issues)...... TO ADVERTISERS SCALE OF CHARGES FOR ADVERTISEMENTS £ s. d. 5 0 £ s. d. 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Any contributions that may be sent on approval will be carefully considered by the Editor; but no responsibility whatever can be accepted in respect thereof, although, if unsuitable, every effort will be made to return them, provided that a stamped addressed wrapper is enclosed for that purpose. The copyright of all contributions (including reports paid for) shall belong to the proprietors of the LAW TIMES, together with the right of republication in any form they may think desirable. Apart from any express agreement that be made, contributions are only received and considered on these tions. THE LAW AND THE LAWYERS Business in the Courts THE Hilary sittings close with the business of the courts, with possibly two exceptions, in a far more satisfactory position than has obtained for many years. In the Court of Appeal cases are heard almost on the expiry of the notice, and this expedition is all to the good, for genuine appeals are encouraged, and those that are entered merely to gain time will become non-existent. Chancery matters are well up to date, and the courts are prepared to deal speedily with those questions that are bound to arise under the new property statutes. In the King's Bench both special and common jury cases have not made the progress one would have hoped. This time last year the special jury list dated back to the end of November, and the common jury list to mid-December, but at the present time those lists have only been disposed of to the beginning of December. However, the non-jury list, which in April 1925 was in arrear to the previous mid-November, has been disposed of down to the beginning of January last. The Crown and Civil papers give no cause for complaint, and the Probate and Divorce Court is keeping abreast of its work. Arbitration THE Lord Chancellor has appointed Mr. Justice MacKinnon (chairman), Mr. John Gordon Archibald, Sir Thomas Willes Chitty, Sir James Martin, Mr. Frank Boyd Merriman, K.C., and Mr. William Norman Raeburn, K.C., to be a committee to consider and report whether any, and, if so, what alterations are desirable in the law relating to arbitration, and in particular to submissions, arbitrations and awards made or held in England and Wales, or the law relating to the effect given in England and Second Sheet Wales to submissions, arbitrations and awards made or held elsewhere. There are many points upon which a careful consideration of the existing law is distinctly opportune, particularly with regard to submitting cases and awards for the consideration of the court. There seems to be no reason why interim and final submissions should have different appellate results, but this is only one of the matters that require examination. The composition of the committee. ensures that the inquiry will be full and practical. Indictable Crime in 1924 ACCORDING to the volume of criminal statistics just issued the number of persons tried for indictable offences in 1924 was 57,374, a slight increase over 1923 and a check to the steady though small diminution during the four preceding years. Measured by the figures given, the introductory note accurately states the position that "crime was increasing before the war, was less after the return to peace, and now does not yet show a definite tendency to increase or decrease." Crimes of violence have not increased, and although during the past fifty years the population has risen from 24 millions to 39 millions, the number of murders coming to the knowledge of the police has remained almost stationary at about 150 per annum, of which about fifty have been cases of infanticide. As to homicide, an interesting comparison is made in the introductory note between this and foreign countries. It says: The figures of murders committed in England and Wales are not comparable with the figures for foreign countries because of differences in the definitions of murder. If, however, the total numbers of all homicides in certain countries are taken, approximately accurate comparisons can be made. In 1924 the number of homicides in England and Wales (including murder, manslaughter, and infanticide) was 274, and the annual average for the five years from 1920 to 1924 was 268. The estimated total population of England and Wales in 1924 was 38,746,020. In the United States, in the registration area inhabited by ninety-three millions of people out of the total of one hundred and ten million population of the whole continental area of the United States, there were 7788 homicides in 1922, of which 5714 were committed with firearms. In Germany in 1921 there were 167 persons sentenced to death for murder; in Italy in 1918, with a population of 36,557,615, there were 1983 homicides (including attempts) actually denounced to the courts (in England and Wales the corresponding figures for 1918 for such crimes known to the police were 267); and in France in 1913 there were 855 persons tried for homicide. There has, however, been a slight increase in the figures relating to sexual crime, and there is little doubt that the increase is more than the statistics show. For figures relating to sexual crimes are for several reasons specially difficult to interpret. Besides reducing to indecent assault, to enable the case to be dealt with summarily, charges of more serious sexual crimes committed against young persons, the courts also, with the same object, sometimes reduce to common assault charges of indecent assault The note also states committed against adults. what is well known concerning shopbreaking, larceny and fraud. As to these it says: It will be noticed that practically the whole increase of crime is confined to crimes of dishonesty. There is usually an increase of larceny during hard times such as have been experienced in recent years. As regards frauds, there appears to be a decay of commercial probity which may have had its origin in the opportunities for getting rich quickly afforded in certain quarters by the Great War. But it is suggested that the increase of crimes under all three heads is largely assignable to efforts to maintain the same or even a higher standard of living than before the War upon means reduced by the general impoverishment of the nation, and to reckless attempts to live more or less luxuriously without rendering any services in return, which may also be traceable to experiences during the War. Non-indictable Offences THESE amounted in 1924 to 584,453 as against 546,606 in 1923, an annual average of 539,974 during the five years 1919 to 1923, and 680,290 in 1913. Motor car cases have risen from 25,701 in 1913 to 123,774 in 1924, but drunkenness has decreased from 204,038 in 1913 to 83,687 in 1924. As to the lastmentioned figures it is accurately pointed out that "The decrease in the figures is believed to be mainly attributable to the high price and diluted strength of intoxicating liquors, to restricted hours of sale, to unemployment, to the increased cost of living, and, last, but not least, to a gradual change of habit and opinion.' Punishments and Probation THE following extracts from Mr. Farrant's illuminating introductory note are worthy of careful consideration. As to fines and imprisonment he says: At the opening of the nineteenth century persons accused of crimes were triable only at assizes and quarter sessions. The punishment prescribed for most crimes was death, but some other punishment was usually substituted, i.e., transportation for life or for long terms of years, or, at a later date, penal servitude. Mere imprisonment was not a usual punishment for crimes. At this time the powers of justices out of sessions (i.e., out of quarter sessions) were mainly confined to the preliminary examination of persons accused of crimes, and to punishing poachers, vagrants, and drunkards. In the course of the first half of the century, however, powers were conferred on justices to try some crimes summarily under certain circumstances, and many minor offences created by statute were placed within the summary jurisdiction of justices. In 1857, the first year for which regular returns of summary proceedings were collected, 34,398 persons charged with crimes and 327,287 persons charged with minor offences were tried by courts of summary jurisdiction. In the same year 20,269 persons were tried for crimes before courts of assize and quarter sessions. (In 1807 the whole number of persons tried for crimes was only 4446.) One result of the change in criminal procedure was that imprisonment became the ordinary punishment for all crimes. and for all minor offences too serious to be met by the imposition of a fine. So long ago as 1857 the number of convicted persons received into prison was about 100,000. By 1904 the total had increased to 198,395, including 107,625 persons imprisoned in default of payment of fines. In 1924. however, the number of convicted persons imprisoned had been reduced to 44,237, chiefly through the operation of two statutes, the Probation of Offenders Act 1907 and the Criminal Justice Administration Act 1914. And as to probation :-- The other factor in reducing the number of persons unnecessarily confined in prison is the application of the provisions of the Probation of Offenders Act 1907 which enables the courts to release on probation persons who are found guilty of crimes and offences. The total of guilty persons released from all Courts without punishment under the Probation of Offenders Act was 79,853. It should be noted that a much larger use of the Probation Act is made by courts of summary jurisdiction in dealing with the more serious indictable offences than with the much larger number of non-indictable offences. Thus, of 44,264 persons found guilty of indictable offences, no less than 22,141, or more than half, were released without punishment; whereas of 534,303 persons found guilty of other offences tried summarily, only 56,259, or about a ninth, were released under the Probation Act. The reason of course is that the great bulk of the latter class of offences can satisfactorily and properly be dealt with by fine, and in any consideration of statistics with regard to the total number of "persons convicted in our courts," it should always be remembered that no less than 470,056 are convictions that result merely in a fine, and that only 3 per cent. of the persons fined are imprisoned in default of payment. The Criminal Justice Act 1925, when it comes into operation this summer should have further beneficial effect, and Mr. Farrant is fully justified in stating: Whatever may have been the case in former times there do not now exist any grounds for contending that the criminal law is administered oppressively and the above particulars make it clear that, on the whole, the provisions of the law are suitably and mercifully applied to the persons brought before the courts." RECOVERY OF POOR RELIEF BY GUARDIANS IN the recent case of Pontypridd Union Guardians v. Drew (noted ante, p. 260), the question arose as to whether guardians were entitled, by statute or at common law, to recover from a pauper, who subsequently became possessed of means. the value of ordinary poor relief granted to him. The facts in the above case were briefly as follows: The plaintiffs granted outdoor relief to the defendant, who was a miner, for the support of himself and his family during the period of a strike. The relief was given weekly between the 15th April and 30th June 1921, in the form of orders on tradesmen for goods. The defendant subsequently became possessed of means, and the plaintiffs then sued the defendant for £6 12s. 6d., the cost of goods supplied to him by way of ordinary poor relief, or, in the alternative, poor relief granted by way of loan under sect. 58 of the Poor Law Amendment Act 1834. It was found as a fact that the first weekly supply was intended by the plaintiffs as ordinary relief, and that the subsequent supplies were intended by them to be granted by way of loan, but that no intimation of that intention was made to the defendant, who received the goods in the belief that he was receiving ordinary poor relief. Now sect. 58 of the Poor Law Amendment Act 1834, to which we will refer again later, provides that any relief which the commissioners (now the Ministry of Health) shall by any order declare or direct to be given or considered as given by way of loan shall 66 be considered to be loan. And the Relief Regulation Order of the 16th Oct. 1911, which deals with the powers conferred on the guardians of a poor law union to board-out pauper children, provides by art. XI. that any relief given under the provisions of this order by the guardians may, if the guardians think fit, be given by way of loan to the parent of the child." But the provisions of the foregoing order, which need not be set out here, do not direct any relief to be given by way of loan, nor do they declare that any relief which has been given shall be considered as given by way of loan. In Pontypridd Union Guardians v. Drew (sup.), the Divisional Court of the King's Bench (Justices Salter and Acton) held that the alternative claim under sect. 58 of the Poor Law Amendment Act 1834 failed, and that the plaintiffs therefore had no statutory right to recover in this action. The question then arose as to whether the pauper was liable at common law to repay the guardians the cost of the poor relief which they had granted him. In In approaching an investigation of the above question it is necessary to pay close regard to the attitude of the Legislature in these matters. It appears that Parliament has legislated from time to time on the assumption that the guardians do not possess a common law right to recover the cost of poor relief supplied by them to a pauper. this respect the Poor Relief Act 1819 (59 Geo. 3, c. 12), s. 29, provides in terms that whenever it appears that an applicant for relief might, but for his extravagance, neglect, or wilful misconduct, have been able to maintain himself or his family, the overseers of the poor may advance money weekly or otherwise by way of loan on a written promise to repay the same; and that the justices, upon the application of the overseers within one year after the making of the loan, may inquire into the circumstances of the person to whom the money was advanced, and order him to repay the whole or part of such money as they think fit, with leave to commit in default of payment for any time not exceeding three months. And the Poor Law Amendment Act 1834 (4 & 5 Will. 4, c. 76), s. 58, provides in terms that any relief which the commissioners shall declare or direct to be given by way of loan, and whether any receipt for such relief or engagement to repay the same shall have been given or not by the recipient, shall be considered to be a loan. And sect. 59 of the same statute empowers the justices to attach wages in the hands of the master or employer in all cases where any relief shall have been given by way of loan to a poor person under the Act. And finally the Poor Law Amendment Act 1849 (12 & 13 Vict. c. 103), s. 16, provides that Where any pauper shall have in his possession or belonging to him any money or valuable security for money, the guardians of the union or parish within which such pauper is chargeable may take and appropriate so much of such money or the produce of such security, or recover the same as a debt before any local court, as will reimburse the said guardians for the amount expended by them, whether on behalf of the common fund or of any parish, in the relief of such pauper, during the period of twelve months prior to such taking and appropriation, or prior to such proceeding for the recovery thereof, as the case may be It is well to note that sect. 16 of the Poor Law Amendment Act 1849 aforesaid confers the first and only statutory power to sue for payment for poor relief which has not been granted by way of loan. Many actions have been brought under that section of which the case of Guardians of the Poor of the West Ham v. Ovens (1872, 27 L. T. Rep. 616; L. R. 8 Ex. 37) provides a good illustration. In that case, the plaintiffs sought to recover the sum of £19 19s., being the amount expended by them in the relief of the defendant, a pauper, and his family, during twelve months prior to the proceedings in the action. A few days before the defendant became chargeable to the guardians, he was injured by an accident caused by the negligence of the St. Katherine Dock Company. He afterwards commenced an action against the dock company and obtained a judgment in his favour and £300 damages. The guardians then applied to the defendant for payment of the above claim, and payment not being made, they brought an action. The Court of Exchequer held that a judgment is a valuable security" within the meaning of sect. 16 of the Poor Law Amendment Act 1849, and that the plaintiffs were entitled to recover the sum of £19 19s. which they claimed from the defendant. In the course of his judgment, Baron Kelly said: " We ought to put a large and liberal construction on the Act which was passed to prevent persons from looking to the parish for support who have the means of supporting themselves." The Poor Law Statutes to which we have referred show an increasing tendency to enlarge the statutory rights of the guardians to recover payment for poor relief, and one might reasonably assume that the Legislature has never recognised the existence of any common law liability on the part of a pauper to repay the cost of poor relief granted to him by the guardians. But that view is not supported by the decided cases. In Re Buckley's Trust (1860, Johnson, 700) one Richard Buckley was a person of unsound mind who had been maintained in a lunatic asylum for many years by his parish. He was entitled to a reversionary interest which fell into possession in 1854 and then consisted of £371 16s. in Consols. The overseers of the poor of the parish to which the lunatic belonged obtained an order from the justices under the Lunatic Asylums Act 1853 (16 & 17 Vict. c. 97), s. 104, to seize and sell so much of any goods or chattels, or to take or receive so much of the rents and profits of the lunatic as might be necessary to defray the sum of £83 which they had paid on his behalf. The trustees of the above-mentioned reversionary interest sold out the fund and paid the proceeds into court under the Trustee Relief Act. The court, ViceChancellor Page Wood, held that a portion of the corpus of the lunatic's property might be applied in satisfaction of the claim of the overseers. In Re Newbegin's Estate; Eggleton v. Newbegin (1887, 57 L. T. Rep. 390; 36 Ch. Div. 477) the question arose as to the effect of the Statute of Limitations upon the operation of sect. 104 of the Lunatic Asylums Act 1853 (sup.). It was held by Mr. Justice Chitty that the guardians of the poor of a parish to which a pauper lunatic is chargeable are entitled under sect. 104 of the Lunatic Asylums Act 1853, in the event of the pauper becoming entitled to property, to recover only six years' arrears in respect of the sums paid by them for his maintenance in an asylum. That decision was followed in Re Watson; Stamford Union v. Bartlett (79 L. T. Rep. 462; (1899) 1 Ch. 72), where the plaintiffs maintained a female lunatic in their pauper lunatic asylum for sixteen years prior to her death. When the pauper was admitted in 1882 she had no means, but in 1895 she became entitled to a fund and a receiver was appointed in lunacy. The pauper died in 1898, and in an action by the guardians against the legal representatives of the deceased lunatic for arrears of maintenance it was held that the plaintiffs were entitled only to six years' arrears from the commencement of the action. The question now arises as to whether the guardians are entitled to recover the expenses of necessaries supplied by them to a pauper. In Guardians of the West Ham Union v. Pearson (1890, 62 L. T. Rep. 638) the defendant developed delirium tremens and became violent in his own house; a relieving officer of the union was sent for who ordered the defendant to be removed to a workhouse where he was detained and examined by a doctor and brought before the magistrates as a lunatic. The magistrates, however, held that the defendant was not a lunatic and discharged him. The plaintiffs had incurred the sum of £1 17s. 6d. in respect of these proceedings and brought an action against the defendant to recover that sum as money paid to the use of the defendant, and alternatively under the provisions of the Lunatic Asylums Act 1853 (sup.). A Divisional Court of the Queen's Bench consisting of Lord Justice Fry and Mr. Justice Mathew held that the expenses claimed had been incurred on behalf of the defendant in the way of necessaries, and that, apart from the Lunacy Acts, there was a common law liability upon the defendant to repay those expenses to the guardians. The rule about necessaries thus laid down in Guardians of the West Ham Union v. Pearson (sup.) was applied, in Re Clabbon (91 L. T. Rep. 316; (1904) 2 Ch. 465), to the case of an infant. It appears that in June 1897 an infant became chargeable to the guardians of the poor of the parish of St. Mary, Islington, who boarded the infant out for the sum of 5s. per week. In 1903 the infant became entitled under the will of his grandfather to a legacy of £100, and one-third of the testator's residuary estate which consisted of £503 in Consols. In June 1904, the clerk of the guardians, as next friend of the infant, took out an originating summons against the executor of the above will, asking that the sum of £83 9s. might be paid by the executor to the guardians in respect of the infant's maintenance from June 1897 to Nov. 1903. The only question to be determined was whether the guardians were entitled to the money expended for maintenance within six years, or only to the money so expended within twelve months which is specially given by sect. 16 of the Poor Law Amendment Act 1849. Mr. Justice Farwell in giving judgment said: "This common law liability extends in all cases, including that of |