about by dampness, and rot in woodwork by want of ventilation. Here the houses of these poor people must have been subject, it appears, to both dampness and closeness, and it is easy to imagine how the tenants must have suffered There were formerly 'visitations' made

by the heralds to the houses of the rich, in order to collect and regulate the coats of arms borne or assumed by the gentry; but how much more are wanted now-a-days 'visitations' of health officers and others to the scores of back streets and alleys, of courts and entries, in some of our manufacturing cities, where disease sits enthroned, and where apathy stands at her footstool.

TYPHOID FEVER AND MILK.

MR. EDWARD SERGEANT, medical officer of health and analyst of Bolton, in his lately published report on the health of Bolton during the year 1876, writes, "Of the many causes which operated during the year in the production of typhoid fever, none stands so prominent as the contamined milk supply from Eagley. The "milk" epidemic of typhoid fever which caused so much alarm in the early part of the year, will long be memorable in the annals of Bolton. It will be remembered that in the course of a few days, dating from January 22, over 100 persons were stricken with symptoms of typhoid fever, more or less severe; the whole of the persons affected in the borough during the epidemic amounted to 137, of whom seven died. The cause of the epidemic was due to the drinking of milk which had been contaminated by the addition of water containing filth from fæcal deposit. As proofs of the direct connection of the milk with the fever, it was shown that all those who partook of the milk suffered, and that the track of the milk cart from the Eagley farm marked unerringly, the course of the epidemic. The lesson taught by the above unfortunate occurrence points unmistakably to the necessity for strict sanitary inspection of all sources of milk supply; and since the premises of other vendors of food, as butchers, bakers, etc., are under sanitary supervision, I cannot see why the premises of vendors of milk-an article of food so liable to contamination, and so universally used-should not come within the same category. In section 78 of the Bolton Improvement Act, 1877, the Corporation seek the following powers with respect to dairies, namely: "For regulating the situation and sanitary arrangements thereof, the inspecting thereof by an officer of the Corporation at all reasonable times, and for ensuring the purity of the water-supply thereof." Until powers for the sanitary regulation of dairies are granted, the public health is endangered, and liable at any day to be shattered by the wholesale distribution of milk-typhoid.'

MORE FIREPROOF FLOORING. FOLLOWING Messrs. Evans and Swain's description of the fireproof flooring designed by them, Mr. CozensHardy volunteers a description in the Times of a large malthouse, which will, we are sure, interest our readers generally.

The malthouse was built about 1824, is 40 ft. by 180 ft., and over it is a chamber of the same size for storing barley and malt. This floor was made without any joists, and resisted the ravages of a large fire on April 1, 1827. The building is 40 ft. wide, and strong beams, 6 in. by 15 in., were placed on the brick walls 7 ft. apart, each beam being supported by two wrought-iron columns. Upon these beams 3 in. deals, 'groved and tongued,' were fastened without any joists. The fire originated in this chamber from the spontaneous ignition of high-dried malt, and in less than an hour the whole roof fell upon this floor. Some time elapsed before a fire-engine could be obtained. At length the fire was got under, but continued to burn for some twenty-four hours afterwards. It was strangely found that none of the beams were destroyed, and the floor was scarcely at all injured (only about a dozen small holes

having been burnt through). The floor exists at the present time as strong as it was fifty years ago. This floor, though somewhat novel in its construction, was simply made for strength, and without any idea of its being less liable to be destroyed by fire than crdinary floors. Mr. Cozens-Hardy is quite certain that the safety of this floor arose entirely from the 3 in. deals being 'groved and tongued,' thus preventing the air from getting between the joints and feeding the flames. If a floor on this principle were made, he adds, with a double thickness of 3 in. deals, tongued with hoop-iron, one above the beams and the other under, with concrete between, and with a ceiling of thick plaster, as suggested by Messrs. Evans and Swain, he has no doubt it would resist the action of fire much longer than any so-called fireproof buildings, and the cost would be very trifling. Mr. Cozens-Hardy offers to show the malthouse floor to anyone who may wish to see it.

PROPOSED HOSPITAL ACCOMMODATION FOR SOUTH SHIELDS, JARROW, AND HEPBURN. A JOINT Committee has been appointed to take into consideration and report on the advisability of having a hospital for the reception of infectious diseases for these urban sanitary districts. The suggestions were drawn up by Dr. Spear, and recommend that a site of about four acres in a central position be obtained, that the excreta should be removed by water through pipes unconnected with the local system of sewerage, that the water-supply should be from the company's mains, that the buildings should be on the pavilion principle and the wards only one storey high, that there should be separate pavilions for small-pox and scarlet fever, and one for typhus and typhoid fevers, as well as a receiving room for doubtful cases, and that there be 2,000 cubic feet of air space, also 144 square feet of floor surface for each acute case, and two-thirds of this space for each convalescent. The question of providing private rooms for better-class patients to be considered hereafter, as well as the rate of payment from such patients. The sum of half a guinea a day is proposed, which is not to include the nurse's wages nor medical attendance. A table is appended from fifteen places, showing the number of beds, cost of hospital, cost of building per bed, and average cost per patient; also the number of permanent nurses, and whether pauper patients are received or not. The returns under the head of cost of building per head show such great variations as lead to the belief that some must be temporary buildings, whilst others have been unnecessarily expensive. Thus at Leek the cost was 287. 175. for a wooden building; at Bristol, 24/., but the site is Corporation property; at Nottingham, 45. 10s.; at Sunderland, 50/.; at Tunbridge Wells, 61. 175. ; at Rugby, 647. 145.; at Glasgow, 771. 1os. ; at Hastings, 927. 175. ; at Taunton, 100/.; whilst at Cheltenham it was as much as 1657. These sums, however, do not include furnishing and other expenses, as at Everton (Liverpool), including all expenses, it was 1387. 8s. ; at Darlington, 2417. 8s.; and at Bradford, 349. 4s. per bed. There are three hospitals in Glasgow, which make up altogether 620 beds, and are returned as having cost 53,6327., and at Bradford 22,000/. for 63 beds. hospitals at Rugby, Nottingham, and Everton (for Liverpool) are all built of wood. The total cost of the proposed hospital at South Shields, for land, buildings, and furnishing for fifty beds, is estimated at 5,600/., but of course the cost of maintenance would vary according to the number of patients, and ranged in the returns from 37. at Glasgow for each patient, to 147. 16s. at Bradford. At the London Fever Hospital the average cost per patient is 6. 10s. We give these figures, as they may be useful for the guidance of other local sanitary bodies whenever they propose following the example so worthily set by the above-mentioned authorities.

The

Special Reports.

THE SEWAGE OF STROUD.

THE sewage of Stroud has been worked for upwards of ten years upon Dr. Bird's plan of precipitation by sulphated clay; various modifications of the tanks being from time to time made to perfect the effect of the precipitation, and the filtration of the sewage.

During the last twelve months the system has been found to work so satisfactorily, that, notwithstanding the heavy rains and flood, nearly four hundred tons of dried solid sewage has been kept out of the brook, and no solid matters have been allowed to flow into it. Thus, one of the problems of the sewage question has been solved, and there is therefore no reason now why our rivers should be any longer made the carriers of the filth from our towns-for the sewage waters flow out of the Stroud sewage tanks into the brook as a clear liquid, free from either taste or smell, and no complaint has arisen of fouling the brook or of unpleasant smells, even at the works themselves.

The property of Dr. Bird's sulphated clay is to fix the ammonia, and to deodorise the sewage, thereby removing all unpleasant smells even in the process of arresting the solid matters, which when they are dredged, are placed under sheds, where fermentation is checked by the use of a sprinkling of the sulphated clay, and when sufficiently dried this sewage is screened for drilling as a manure.

The next problem of the sewage question is the disposal of this dried sewage, which would otherwise accumulate, and here, too, the result of the system at the Stroud sewage works has proved to be a solution of the problem, for the whole of the four hundred tons of dried sewage, which has been during the last twelve months stopped from passing into the brooks, has, with the exception of some small quantities sent out for experiments, been sold to the farmers and others in the neighbourhood; and those farmers who had purchased the manure in the preceding year have shown themselves desirous of obtaining another supply. Notwithstanding the unusually unfavourable season for the use of manures, the result has been that fair crops of mangolds and roots have been grown by its use. It has also proved itself a good manure for potatoes, producing crops of large tubers, in many instances free from disease.

The plan adopted at Stroud is as economical as it is possible to be. No steam engines or expensive machinery are used, and the material employed, 'sulphated clay,' is cheap in its preparation, and simple in its application. The only requisite is a sufficient number of precipitating tanks. But it is in this that towns are generally deficient; for example, the tanks at Stroud, with a population of 5,000, are larger than those at Cheltenham, with a population of upwards of 40,000. It has been affirmed that Dr. Bird's plan has been tried at Cheltenham, but the statement is incorrect. It has never been tried there, and indeed, the tanks there would be altogether unsuitable for it; but his 'sulphated clay' has been used there for the purposes of deodorisation, and in one of the surveyor's reports it is stated that its action was successful.

The effect of the ten years' working of Dr. Bird's plan at the Stroud sewage works is in fact this

that where any town is furnished with a sufficient number of precipitating tanks, as Stroud is, the scientific problems of the sewage question, purification and the disposal of the sewage when collected, is clearly solved, and the mere fact that the whole of this sewage is sold after trial, goes far to prove that the sewage thus collected has been found to be a valuable manure, the more especially as it is found that farmers who have bought the manure one year, wish to buy it again.

SEWER GASES.

AT a recent meeting of the Royal Society, Professor E. Frankland communicated a paper 'On the transport of solid and liquid particles in sewer gases.' He first referred to the large amount of suspended matter in the air, which consists of aqueous and other volatile particles that disappear by a gentle heat. There are other particles that consist partly of organic and partly of mineral matters, and the processes of fermentation, putrefaction, and decay afford abundant evidence that zymotic and other living germs are present among the organic portion. Of the zymotic matters, those which produce disease in man are obviously of the greatest importance, for there are well authenticated cases on record that disease has been communicated by the germs being in suspension in air that has escaped from sewers. Professor Frankland has considered it important to investigate the conditions under which the germs pass from sewage into the air. Does the flow of sewage in a properly-constructed sewer produce sufficient agitation to disperse liquid particles through the air space of the sewer? In this and in the other experiments mentioned below a solution of lithic chloride was used, Professor Frankland having previously ascertained by three separate tests that no lithic chloride is carried off at ordinary temperatures by aqueous vapour from a saturated solution of it. Some of the solution being placed in a glass jar it was agitated, and though this was done with greater violence than would ever happen to fluid in a sewer, it was proved that none of the lithic chloride was disengaged. It is, therefore, extremely improbable that the mere flow of foul liquid through sewers can impregnate the circumambient air with suspended particles. There is, however, another kind of agitation to which sewage is subject that may produce a very different result-viz., the development of gases during the processes of fermentation and putrefaction. When minute bubbles burst at the surface of an effervescing liquid little particles of it can be seen projected into the air some inches, and then falling again. Professor Frankland experimented to test whether particles too small to be seen might not be also projected, and in consequence of the smallness of their masses in relation to their sectional areas, might continue suspended in the air for a long time. A strong solution of lithic chloride was acidulated by the addition of hydrochloric acid, some fragments of white marble were added, and this produced an effervescing liquid. A tube 3 in. in diameter and 5 ft. long, was held over it, and there were distinct traces of lithium found during effervescence at the upper end. A second tube 3 in. in diameter and 12 ft. long, was then held nearly at right angles at the top of the first, a slight draught through it being caused by external heating. At the further end of this tube, too, lithium was distinctly traced. The particles were also found to

pass readily through two inches of charcoal, and they passed even a layer five inches thick, though in greatly diminished numbers. Here, then, in the breaking up of minute gas bubbles is a cause of the suspension of particles in the air. If, therefore, through the stagnation of sewage or constructive defects which allow of the retention of excrementitious matters for several days in a sewer, putrefaction sets in, then gases are generated, and the dispersion into the air of zymotic matters is very probable. It is of the greatest importance that foul liquids should pass rapidly and freely through drainpipes and sewers, so as to secure their discharge from the system before putrefaction sets in.

Medical Officers' Reports.

BIRMINGHAM. The population was estimated in the middle of 1875, to have been 366,325; the number of births registered was 14,862 which is equal to 40:57 per 1,000; and there were registered 9,668 deaths, so that the death-rate for the year was 26 34 per 1,000, which is less than in 1874, but greater than in any year since 1864, and nearly 3 per 1,000 above that of London. The deaths under one year and above forty were more than usual, which were caused chiefly by bronchitis. There were no less than 19.6 per cent. of deaths under one year to total births, which, although much above the rate for London, was below that of Norwich, Liverpool, and Leeds. This large mortality was caused chiefly by an unusually large number of deaths from diarrhoea, which is somewhat singular, as the mean temperature of the summer was less than usual. The zymotic deathrate was 5.86 per 1,000 living, against 17.35 in 1874, the reduction having arisen from a much smaller number of deaths from scarlet-fever and small-pox. Dr. Hill attributes the majority of the deaths from diarrhoea to improper feeding of infants with bread and water, arrowroot and water, and solid food. There were 868 deaths from diarrhoea, 265 from scarlatina, 204 from fever, 438 from whooping cough, 174 from small-pox, 141 from measles, and 55 from diphtheria. The chief mortality from small-pox occurred in 1874, when but few were registered in most other places. The percentage of deaths in 1875 amongst the vaccinated cases was 14'47, whilst amongst the unvaccinated it was as high as 63.21, which is strong evidence against the opponents of vaccination. The death-rate per 1,000 population from the seven principal zymotic diseases was 5.86, from pulmonary diseases (except phthisis) 4'87, from tubercular affections 260, and from wasting and convulsive diseases of infants 4:26. These rates for zymotic diseases and wasting and convulsive affections are very high. Dr. Hill made reports under the Artisans' Dwellings Act on certain districts as being unhealthy, which the Town Council have approved. The by-laws respecting the construction and ventilation of houses had not been agreed to, and the filtration of the water is deemed to be insufficient. Many of the houses are still supplied from wells, and Dr. Hill reports having examined above fifty, nearly all of which were contaminated with excremental matters. There were 13,207 nuisances reported upon by the inspectors, 10,765 notices served for the removal of nuisances, 12,352 nuisances abated without legal proceedings, and 843 abated on magistrates' orders,

and above 6,000 visits paid to lodging houses. Dr. Hill also analysed seventy-three samples of food, of which twenty-eight were adulterated, viz., ten of milk, nine of tea, four of pepper, two of mustard, two of coffee, and one of milk of sulphur.

MANCHESTER.-The annual death-rate of Manchester was as high as 32:55 in 1868, the year in which the health committee was established, and was only 28.51 in 1875, the average for the first four years being 3012, and for the last four years 28.12, or less than in 1875. The population is estimated at 353,254, and the number of deaths registered was 10,074. The number of deaths in the early part of 1875 was much greater than usual, in consequence of the very cold weather causing an excessive mortality from inflammatory diseases of the lungs. Scarlet fever, fever, and diarrhoea had decreased considerably during the last four years. As regards scarlet fever, Mr. Leigh remarks on its lessened severity when treated in well ventilated and well provided hospital wards. The death-rate from zymotic diseases was as low as 2.8 per 1,000 population, but varied considerably in the various outdistricts. These, as well as average total deathrates, are given, not merely for each registration district, but have been calculated for each enumeration district of the census (1871) for the ten years 1861-70, and for the five years 1871-75, which must have entailed enormous labour. The death-rate under one year to total deaths is a very valuable table, as it shows that in one district, Market Street, it was as small as 9'2, whilst in Ancoats it was 41.9. The percentage of deaths under five years to total deaths was 152 in Market Street, 529 in St. George's, 517 in Ancoats, and 514 in Ardwick, showing that great social as well as sanitary differences must exist in these districts. The percentages above five were Market Street 84-8, Cheetham 60, Ardwick 48·6, Ancoats 48.3, and St. George's only 471, showing that more than half of the total mortality in these districts occurred amongst children under five years of age. The estimated population of Market Street is 15,739, of Cheetham 23,106, of Ardwick 29,764, of Ancoats 51,316, and of St. George's 61,424, so that the avoidable deaths under better sanitary arrangements, diminished density of population, and greater amount of home comforts and care must have been enormous. As some proof of this it is shown that out of 4,959 deaths which had occurred during fifteen years amongst members of the Society of Friends, only 611 or 12.4 per cent. took place amongst children five years old against 529 in St. George's. Is not such a report as this enough to make any one shudder? There is next given a table, showing the infant mortality under one and five years in all the registration districts of England, arranged so that the lowest rate in 1851-60 heads the list, and the highest concludes it, the two cities having the greatest proportion of deaths, being Manchester and Liverpool-St. Olave's, Southwark, West London, and St. Giles being the next, although St. Olave's had much improved in 1861-70. The figures for the two decenniads, as might have been expected, do not correspond. Mr. Leigh observes that the removal of the labourers' dwellings and their re-erection has not caused overcrowding in other parts of the City, as the regulations as to lodging-houses, including tenements separately let off, are such as to prevent it. The average number of inhabitants per house is only 54, whilst in 1773 it

was 6. As regards the prospective operation of the Artisans' Dwellings Act, the medical officers say that Ancoats is the district in which it should first be tried. The sanitary work appears to be actively carried out, as 14,400 cesspits have been destroyed in two years, and a large number of nuisances abated. There were 3,686 visits paid to houses in which infectious diseases had occurred, 262 houses cleansed and disinfected, and 6,656 articles 'stoved in the disinfecting oven.' In conclusion, we would observe that the maps which accompany the report would be a great assistance to anyone desirous of carefully considering the statistics of the different enumeration districts.

Parliamentary Proceedings.

HOUSE OF COMMONS.
(Tuesday, June 5.)

SLAUGHTER OF DISEASED CATTLE FOR
FOOD.

SIR M. H. BEACH, in reply to Dr. Cameron, mentioned the several Acts of Parliament relating to cattle diseases under which orders had been issued giving veterinary inspectors power to regulate the disposal of carcasses by sale. In regard to a case recently brought before the Blanchardstown Petty Sessions (in which the evidence, as stated in the question, was that a cow whose lungs weighed 52 lbs., and whose case was described by the Dublin medical officer of health as one of the worst cases of pleuro-pneumonia he had ever seen, was sold for human food by the Poor Law guardians), it appeared that the inspector of the North Dublin city union considered the animal in question fit for human food, and ordered the carcass to be sold. The case was brought before the magistrates, who disagreed with regard to it, and the case was dismissed without prejudice. Before the issue of the last order on this subject by the Privy Council, inquiry was made as to the practice in Great Britain, and it was discovered that, generally speaking, it was the practice of local authorities to utilise animals slaughtered for pleuro-pneumonia for human food unless disease was so far advanced that the meat was unfit for consumption.

Dr. Cameron said he would call attention to this subject on an early day.

(Monday, June 11).

SANITARY STATE OF THE METROPOLIS. MR. BAILLIE COCHRANE gave notice that on an early day he would call the attention of the House to the disgraceful state of the streets of the Metropolis, especially in the districts of Chelsea, Belgravia, and Knightsbridge, which, if not attended to, might renew this summer the evils of former years; and would ask the Home Secretary whether he will introduce any bill to give the Government greater control over the vestries, and to compel the publication of their revenue and expenditure accounts, so that the public may know how much of the large amount now levied by rates is expended on sanitary arrangements.

CANAL BOATS BILL.

MR. SCLATER-BOOTH, replying to Mr. W. E. Forster, said that if the order for going into committee on the Canal Boats bill were reached before half-past 12 o'clock on an early day, he would consent to the motion for referring the measure to a select committee.

Law Reports.

POWERS OF GAS COMPANIES.

THE Queen's Bench Division has had before it the case of the Queen v. Colne Valley Gas Company. This was an indictment for obstruction of a highway, and was tried before Lord Coleridge at the Spring Assizes, Leeds, when it appeared that the defendants had on two or three occasions dug trenches across a highway, near Huddersfield, for laying down or repairing their works. The highway in question was eight yards wide, and it was proved that on one occasion they had dug trenches in three places, two of which were across the highway, and the third parallel to it. The trenches were three yards long, and were opened at night and closed at three in the morning. On another occasion some more trenches were dug, so that it was impossible to drive past along the highway, and these were kept open from eleven at night until two o'clock in the following afternoon. The case of The Queen v. the Longton Gas Company' was cited at the trial, the circumstances of which were very similar to those of the present case, and where eminent judges had held that the defendants had been properly convicted. Lord Coleridge told the jury that as a matter of fact he directed them that, the facts being undisputed, and being identical with those in the case which had been cited, if they thought the facts were proved they should pronounce a verdict of guilty, and he afterwards added that having told them the proper verdict to find-indeed, the only verdict they could find-on the authority of the case which had been cited, which bound them as much as it bound him, they must tell him whether they thought there was a sensible and appreciable obstruction of the highway; therefore, he would ask them, on the authority of that case, was there a sensible and appreciable obstruction of the highway? The jury found that there was. A rule nisi was afterwards obtained for a new trial on the ground of misdirection.

It was contended, on the one hand, that there was no misdirection, or that if there was it was on an immaterial part of the case; and, on the other hand, that the learned judge had practically left no choice to the jury, who could not have found any other verdict but that of guilty; that this being a criminal case, the question was entirely one for the jury, and that the surrounding observations, therefore, amounted to misdirection, and that the verdict should be set aside.

The Court were of opinion that there ought to be a new trial. They decided mainly on the ground that from the mode in which the case had been left to the jury the latter may possibly have misunderstood the case of "The Queen v. the Longton Gas Company," which the learned judge had told them bound them and him. When that case was examined, it appeared possible that the jury might have been misled, for the facts in that and in the present case were not the same. The judgment in 'The Queen v. Longton' was not grounded only upon the facts, but also upon admissions which were made on both sides. It was not there disputed that the highway was obstructed, but it was contended that the defendants had a right to obstruct as they did. The learned judge told the jury in this case that he should ask them whether they thought that there was a sensible and appreciable obstruction by the defendants in the sense he had explained to them, which he had explained with reference to the Longton They thought, indeed, that the whole course of the case showed that the jury were so tied up with the Longton decision, which was not necessarily applicable, that the verdict was not satisfactory.

case.

BRIEF NOTES AND CASES.

TRAMWAYS.

1873. Edinburgh Street Tramways Co. v. Black.— 'Tramways Act, 1870.'-Special Act.-General Act

varied by special Act.-Held that the aggrieved parties had no legal redress.-When an Act directs compliance with deposited plans and sections, they are to be regarded as embodied in the Act. (L. R., 2 sc. App. Cas., 336.) BUILDING LINE.

1876. Kerr v. Preston Corporation.- Public Health Act, 1875,' S$ 156 and 251.-Wrongful encroachment on a building line by plaintiff.-Threat of proceeding against him.-Injunction to restrain such possible proceedings on the ground of acquiescence refused.--A local authority has no power to acquiesce; it can only give assent by writing. -The Court has no jurisdiction to restrain criminal proceedings for breaches of the Statute Law. (46 L. J., Ch., 409.).

PAVING EXPENSES.

1877. Grice 'v. Hunt.- Local Government Act, 1858,' § 62.-Paving expenses. -A notice of apportionment is not a 'demand,' and is essentially different from a ‘demand.'—The section contemplates that some document be served which shall pointedly remind the person in default that such is the case, and time runs from the service of this notice. (46 L.J., M.C., 202; W.N., 1877, p. 100; 36 L.T., 404 ; 41 J.P., 261.

MANDAMUS.

1876. Harrogate Medical Officer v. Harrogate L.B.H. -Application for Mandamus to compel a Board to allow a duly appointed officer to discharge his duties.-Application refused.-Mandamus only the remedy for non-performance of public duties.-A Board not being required to perform medical officer's duties.-Mandamus does not lie.-His remedy under the circumstances is action for non-payment of salary. (Times, Nov. 22, 1876.)

STREET PAVING.

1875. Groinnell v. Eamer.-Injury to plaintiff from the giving way of a defective coal grating in a public highway.-Premises under lease, lessee to repair. -Held that the plaintiff had no right of action against the defendant as lessor. (L.R., 10 C.P., 658; 32 L.T., 835.)

INFECTIOUS DISEASES.

1877. Tunbridge Wells, Q.B., v. Bishopp. —Public Health Act, 1875,' § 126.-A medical man walking with a patient through a public street in order to secure his admission to a Hospital, held not in charge of the person suffering. (L. R., 2 C.P.D., 187.)

Legal Notes and Queries.

TRURO SANITARY AFFAIRS.

AT a recent meeting of the Truro Union, the following items of business were amongst those dealt with. At Mer. rose Farm, Gerrans, several deaths had taken place during the last three or four years from epidemic disease, in the family of a person occupying the farmhouse. The inspec tor said that he had made an inspection of the premises, and considered the probable causes; the epidemic might have been caused by the proximity of pig-sties to the dwelling-house and bad drainage. He had made application to the trustees of the estate to make the necessary improvements. The Local Government Board had written to sanction the letting of the old workhouse to the Truro Urban Sanitary Authority for an hospital, at a rental of 10. a year.

cern, for the prolongation of the term of a patent, in respect of an invention of certain improvements in obtaining sulphur and sulphurous acid from alkali waste. Alkali waste is said to be produced in enormous quantities by alkali makers, so much so that 21 tons of waste are usually provided in the manufacture of each ton of alkali. The waste fouls the air and pollutes and poisons any water with which it may come into contact, and is considered highly injurious to health and life. The patent in question utilises the waste and renders it virtually innocuous. Their lordships dismissed the petition.

LOCAL BOARDS AND BUILDERS.

MR. JUSTICE MANISTY has had before him the case of Waghorn v. Wimbledon Local Board. This case raised a question of considerable importance to architects and surveyors. The plaintiff is a quantity surveyor.' The defendants are the Burial Board and Local Board for Wimbledon. In 1875 they instructed their surveyor to prepare plans and specifications, and to procure tenders for the erection of a cemetery chapel. These instructions were embodied in a resolution passed at a meeting. When Mr. Rowell had prepared the plans, he instructed the plaintiff to take out the 'quantities' and he advertised for tenders. Several builders sent in tenders, having used the quantities taken out by the plaintiff in arriving at their estimates. The defendants did not accept any of the tenders, the amount of the lowest being higher than the sum which they intended to expend. The case for the defendants was that they never authorised Mr. Rowell to employ the plaintiff to take out the quantities. Several architects and surveyors were called for the plaintiff, who stated that the business of a quantity surveyor was quite distinct from that of an architect, and that it was necessary that the quantities should be taken out to enable builders to tender. They also stated that the custom was for the builder, when sending in a tender, to add the charges of the quantity-surveyor to his estimate, and that if the tender was accepted he paid the quantity-surveyor. If, however, none of the tenders were accepted, the building owner was liable to pay the quantity-surveyor's charges.

His lordship ruled that, as the Board had instructed the surveyor to procure tenders, and as tenders could not be made without quantities, they had impliedly authorised him to get the quantities taken out.

It was then submitted that the defendants, being a corporation, could only contract under seal, and there being no contract under seal here, the plaintiff could not recover.

His lordship ruled that as the defendants had by resolution impliedly authorised Mr. Rowell to get the quantities taken out, and had had the benefit of the work which bad been done, their objection was not tenable. Judgment was accordingly entered for the plaintiff for the amount claimed (1707.).

Reviews.

Bathing in London. A Practical Treatise, containing a description of the Baths and Bathing-places in London. By HADLEY PRESTAGE. (London: J. Roberts, 195, High Street, Shoreditch.)

THE writer of this little pamphlet is evidently a tyro in authorship, and it is to be hoped that, if it reaches a second edition, he will correct some of the palpable inconsistencies and inaccuracies it contains. He intimates in the introduction that he is of opinion that while the Act which was passed in 1846, "to encourage the establishment of public baths and wash-houses," remains in the hands of the local boards, it will not have a fair chance of doing the great sanitary work it was originally designed to accomplish.' But, again, at page 36 he recommends the vestry of Bethnal Green to follow the good example of