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air coming into contact and creating a circular movement is a feasible one. Lieut. R. H. ARMIT, R.N., says that if a vessel advances on a line where the barometer keeps falling as she progresses, she is pretty certain to experience a heavy gale; and if the barometer falls to about 28.60 inches, there is a certainty of encountering a hurricane-"the wind shifting all round the compass in a few minutes." Two strong currents of air meeting in contrary directions are likely to be curled round at the point of interception, and made to act like what is called a cyclone or circular storm. We need not, however, discuss this topic. The labours of Captain TOYNBEE have resulted in proving that ships in crossing the Equator, when bound to the southward, should not make a westerly crossing from May to September inclusive, nor cross to the westward of 25 deg. W. if it is possible to avoid doing so. A chart on a large scale is in preparation to illustrate and further develop the physical geography of the squares, already accomplished in miniature; but the Navigator who goes to sea, bound to the South, without the valuable little work whose contents we have noted, will deprive himself of a guide that ought not to be absent from his ship.-April 21, 1876.

AUSTRALIAN ROUTES.

Considerable attention has recently been given to the routes outward and homeward of ships trading between Europe and Australia. The loss of the Strathmore on the Crozet Islands and the sufferings of her passengers and Crew have awakened the zeal of certain writers, both in England and at the Antipodes ; but after carefully perusing all the correspondence on the subject, we fail to discover anything new in reference to it. Masters of ships do not agree in their conclusions, and therefore those who desire to profit by the experience of others are still left to follow their own judgment. The Committee of Lloyd's, it may be remembered, in consequence of three first-class ships bound to Australia being missing, requested the Lords of the Admiralty to instruct the Commander of one of Her MAJESTY's ships to visit the islands lying in what they alleged to be the ordinary track of vessels. Their Lordships, in reply, expressed their opinion that Masters of ships incurred great risk by going so far south and making the run among icebergs and floating ice, and they could not feel surprised at the announcement of missing vessels. On the 29th of January, 1870, when the Hydrographer to the Admiralty issued a circular to warn Captains of ships that icebergs and drift ice had come as far north as the parallel of lat. 40 deg., between 20 deg. and 25 deg. W. longitude, we entered fully into the question, and gave details of where ice on the Eastern and also on the Western routes had been met with in 1869. The impression left on our minds was that the missing ships of that period might be accounted for by mishaps among the ice. The "Australia Directory," as pointed out by the Lords of the Admiralty to the Committee of Lloyd's, directs that, after rounding the Cape of Good Hope, vessels bound to the south coast of Australia should run down their longitude on or about the parallel of 39 deg. S., where the winds blow almost constantly from some western point, and seldom with more strength than

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will admit of carrying sail. To the southward of 40 deg. there may be open water, and if the ice has not drifted so far north, ships bound for Melbourne, Tasmania, or New Zealand may possibly fall in with strong winds, which will speedily waft them to their destinations; but it requires careful Masters, attentive Officers, and a well-disciplined Crew to keep them out of danger when so near to the Antarctic regions. COOK, BISCOE, and MOORE went as far south as 65 deg. to 70 deg.; but they were in surveying vessels and always prepared for emergencies. The line of freezing in January and February is in about 53 deg. S., and it varies at different months in the year. In certain seasons, therefore, a ship could stand away some 400 miles further south, but we do not see what object can be gained by knocking about in a region where ice may be met with at any hour; while the boisterous weather strains a vessel and damages her spars, sails, and rigging, besides carrying away boats and deck-fittings. In passenger ships the cold must cause discomfort; and we feel assured that the majority of travellers would rather chance a little delay by taking a more temperate course than suffer from the presence of icebergs. The Strathmore was lost from error, and by not taking warning from the seaweed that was met with on nearing the Crozet Islands. If anything may be learned from the wreck of that ship, it is, that care should be exercised in approaching land. The rule is not applicable only to the Eastern Hemisphere, but holds good everywhere else. It does not follow, however, that because a ship is run so far to the south, she is to be stranded on an island distinctly marked on the charts. A ship need not, on the other hand, be steered against an iceberg simply because one or one hundred are seen. We repeat the remark in reference to navigation of this latter character, that a good lookout must be kept, the barometer and thermometer constantly consulted, and nothing left to chance. Despite what the Lords of the Admiralty may urge or we advise, there are Captains who will keep away to the southward after rounding the Cape of Good Hope until they get beyond the 39th degree, and they may do so with impunity. It is a fact that, where Masters of 500 to 900-ton vessels would not dare to go some years back, Captains of 1,500 to 3,000 now venture without any fear of the result. Such ships as now leave our Ports ought not to be made unseaworthy by strong winds; on the contrary, they require stiff breezes to propel them through the seas, and their Commanders go to the south to find such aids. The Admiralty Ice Chart shows that bergs have floated as far north as Cape Recife, and at no considerable distance from Table Bay. In 1844, during the winter months of July, August, and September, immense icebergs fetched lat. 37 S., long. 25 E.; so that, if ice deterred a Master from pushing his way, he would have to hug the Cape and keep round the land to Port Natal, and then haul off to the eastward. A resolute Master, who understands his duties and responsibilities, has to choose his own route, and no pusillanimous fears will prevent him from making a high southing if he has confidence in himself. Along the parallel of 35 deg. South latitude there is a current setting to the east from 20 to 25 deg. East longitude. From 55 to 95 East longitude there is no set to help a ship; but in lat. 40 S., long. 100 E., another current is fallen in with, which strikes Cape Leuin and runs along the

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coast of Australia, from thence to the southward of Tasmania, and on to New Zealand. The mail steamers derive great advantage from this stream, and it is said that some Captains of sailing ships have made excellent passages by keeping in with the current. It is of no use attempting to prove that more genial weather and favourable currents are to be met with in the parallels of 40 to 45 deg. if Masters of ships are resolved to go to the southward of 50 deg. S. We cannot, however, lose sight of the danger likely to happen from encountering ice in these localities.-July 5, 1876.

CARRIAGE OF EXPLOSIVES.

The Board of Trade have recently issued a circular on the "Carriage of Explosives in Ships." It is intended for the instruction of the Principal Officers of the Board of Trade, and sections of the Acts of Parliament relating to the conveyance of dangerous compounds by vessels are quoted in it. The sections of the Statutes referred to are the 29th of the Passengers Act, 1855; 23 to 28 of the Merchant Shipping Act, 1873; and 33, 34, 42, 58, 98, 101, and 106 of the Explosive Substances Act, 1875. These are followed by the Order in Council of August 5, 1875, and from this document we have culled the following classifications:-Class 1 comprises the ordinary gunpowder. Class 2, mixtures of nitrate, namely, pyrolithe, pudrolithe, and poudre saxifragine. Class 3 includes all chemical nitro-compounds possessed of explosive properties, or capable of combining with metals to form an explosive compound, and these are divided into nitro-glycerine, dynamite, lithofracteur, dualine, glyoxiline, and methylic nitrate. These are the only mechanically mixed preparations which consist either wholly or partly of nitro-glycerine, or of some other liquid nitro-compound. The sub-division of nitro-compounds embraces gun-cotton, gun-paper, xyloidine, gun-sawdust, nitrated gun-cotton, cotton gunpowder, SCHULTZ's powder, nitro-mannite, picrates, and picric powder. Class 4 comprises chlorate mixtures, including such explosives as HORSLEY'S blasting powder, BRAIN's blasting powder, HORSLEY's original blasting powder, ERHARDT's powder, REVELEY'S powder, HOCHSTADTER's blasting charges, REICHEN'S blasting charges, teutonite, and chlorated gun-cotton. Class 5 includes any chemical compound or mechanical mixture which, from its great susceptibility to detonation, is suitable for employment in percussion caps and other appliances for developing detonation, or others of a similar preparation which, from their extreme sensibility to explode and their readiness to undergo decomposition from very slight exciting causes, are specially dangerous. These are such compounds as fulminates of silver and of mercury and the preparations of those substances, and any preparation consisting of a mixture of any chlorate with phosphorus, with or without the addition of carbonaceous matter, and mixtures of chlorate with sulphur or with a sulphuret. This division comprises also such substances as the chloride and iodide of nitrogen, fulminating gold and silver, diazobenzol, and the nitrate of diazobenzol, Class 6 includes all kinds of ammunition, such as safety cartridges, safety fuzes for blasting, railway fog signals, percussion caps, cartridges for small arms, cannon, shell, mines and blasting, shells and torpedoes, fuzes for

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blasting which are not safety fuzes, fuzes for shells, tubes for firing explosives, and war rockets. All ammunition as before defined, containing its own means of ignition or adapted to explode or fire the same by friction or percussion, comes within the foregoing division. The Firework Class is No. 7, and this includes everything intended for pyrotechnic effect or signals. Several of the Harbour Boards have adapted their rules according to the classification here given. For instance, the Thames Conservators have enacted that no ship shall carry more than 1,000 lbs. of any explosive other than Class 6 at the same time with any naphtha, paraffin, petroleum, or other volatile oil, except a small quantity for the ship's use; and such naphtha &c. is not to be used for any purpose, or on any pretence whatever, in a ship carrying more than 1,000 lbs. of any explosive (ammunition excepted) whilst she is in the River Thames within the jurisdiction of the Board. Section 6 of the Merchant Shipping Act, 1876, empowers the Board of Trade to detain ships which are unfit to proceed to sea without serious damage to human life; and the principal Officer of the London District may provisionally detain, on account of the improper loading of her cargo, any vessel that has on board as freight either gunpowder or explosive compounds. This Officer is instructed that he need not detain a ship provided the explosives are packed as required by Section 33 of the "Explosive Substances Act, 1875." On reference to that section, we find that the construction of boxes, barrels, or cases must be approved by the Government Inspector, and so made that they cannot be accidentally opened or become defective whilst being conveyed, and they must be so tight as not to allow the powder to escape. If a double package is used, the inner one must be manufactured in a similar manner. With good barrels or cases there ought to be no leakage whatever, and, without the powder escapes, no danger can arise beyond a conflagration of the entire cargo and ship. Of course we here refer to common gunpowder, and not to bituminous or nitro-glycerine compounds. The Principal Officer is not to stop a ship from sailing if she has gunpowder or other explosives on board, provided the packages are enclosed in a substantial compartment formed of double boards with an intermediate lining of felt. "If such a compartment is not provided, the Officer "must satisfy himself that the explosives are 'other"wise' and by careful stowage secured from con"tact with or danger from any other article or "substance carried as cargo on board the ship. If "the explosives are surrounded with goods carefully 66 packed, and have boards between them and the goods, so as to completely isolate them from all cargo, packing-cases, &c., likely to cause explosion "by metal coming in contact with powder, and if "they are placed on and surrounded by sailcloth or "felt in such a way as to prevent effectually any "of the powder getting adrift during the voyage "and filtering into the general cargo, and if they "are so placed and surrounded that the Crew cannot 66 get amongst them in their attempts to plunder 66 cargo, the Officer need not interfere with their 66 stowage." As there is a large quantity of gunpowder shipped from the Thames for places abroad, no unnecessary impediments should be thrown in the way of such a trade. Already the cost of export is

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more than doubled, for we have been told that a Shipowner had to expend 271. 5s. to earn 137. 15s. We admit that powder ought not to be stowed over articles liable to spontaneous combustion, or is permitted to fall among the general cargo. It has been customary to stow it in the hold, immediately under the hatches, and on the top of tarpaulin. At the end of a voyage, when barrels have been badly constructed, loose powder has been swept up on the tarpaulin; but as there is so much agitation respecting the destruction of ships by explosions, we once more ask those interested in Underwriting to mention a case in which they have suffered a loss through the blowing up of a ship at sea by gunpowder. Naked lights and negligence in Port are the dangers to be guarded against. We do not care, however, for sensational surmises. We want facts. The best guardian of a ship's hold has been gunpowder. When this is boxed in, Jack will have less fear, and then an explosion may occur.

DASSEN ISLAND AND ITS REEFS.

The losses of two large ships within a short distance of each other on the South-West Coast of Africa, and within a day's sail of the anchorage in Table Bay, are events of importance, not only to those immediately concerned, but to navigation. On the 19th of October the Windsor Castle, outward bound with passengers, went ashore on Dassen Island, and shortly became a total wreck; and this report has been quickly followed by that of the loss of the St. Lawrence, with the 2nd and 3rd Regiments on board, at Paternoster Point, some forty miles further to the northward. Fortunately there has been no loss of life in either case, though that of property has been very serious. The case of the Windsor Castle has been the subject of an investigation at Cape Town, the result being the suspension of the Master's certificate for nine and of the Second Mate's for three months. That of the St. Lawrence remains to be investigated. There can be no doubt that the loss of one if not both of these ships arose from running too fine a course when approaching Table Bay from the northward. Dassen Island lies a few miles off the mainland in Saldanha Bay. It lies low, and in thick weather might easily be missed. But the locality is specially dangerous by reason of the reefs which stretch out to sea from the island, and which makes the navigation treacherous in the extreme. It was one of these reefs which caught the Windsor Castle. Happily, there was little sea on at the time. Had it been blowing, as it frequently does on that coast, heavily from the southward and westward, the ship would have broken up at once, and not a soul, in all human probability, would have been saved. A ship, in making for Table Bay, has no excuse for getting entangled amongst the reefs of Dassen Island. There is abundance of sea room on the starboard hand, and nothing is gained by keeping an inshore course. Ten miles to the westward of Dassen, in the parallel of 33° 30', there are 110 fathoms. The proper course from Dassen Island to Robben Island, at the entrance to Table Bay, runs in water of from 30 to 40 fathoms, and Masters are warned in approaching the latter island to give it a wide berth, for, although lighted, it is low and dangerous. But if this caution is necessary with respect to a lighted island in Table

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Bay, how much more requisite is it with regard to an unlighted island lying on an exposed coast and surrounded by reefs stretching a long way out to seɛ, Dassen is a place to be avoided by all Mariners ac quainted with that part of the African Coast, the dangers of which are fully set forth in the Sailing Directions. The Windsor Castle is the second vessel which, within the past three years, has gone ashore on the reefs surrounding this island. On the 25th of May 1873 the mail steamer Roman, belonging to the Union Company, on her homeward passage from Cape Town, ran on the reefs off Dassen. The vessel was subsequently got off and repaired in Table Bay. Whether the interests of navigation do not require that the island should be lighted need not at present be discussed. There is abundance of sea room to avoid the danger, and, except in thick or foggy weather, very prevalent on that part of the West Coast, there is no excuse for any ship running into the dangers of Dassen Island, whether bound in or out of Table Bay. With respect to the loss of the St. Lawrence, it seems strange at first sight that any ship making for Table Bay should have been caught on Paternoster Cape, which should have been left some miles to the eastward. The wreck of a troopship in the neighbourhood of the Cape at once recalls the loss of the Birkenhead on an outlying danger beyond Table Bay, a disaster which has impressed its name on the locality. But the Birkenhead struck on a rock twelve feet under water, and which previously had been little known, if known at all, to Mariners. Twenty-four years have elapsed since the Birkenhead was lost on the rock which bears her name. Since then the rock and the adjacent coast have been very carefully surveyed, and it is not likely a similar casualty will again occur there. But the outlying dangers of the South-West and South Coasts of Africa are numerous, and demand all the caution and vigilance which can be given to the navigation of those waters. The true secret of safety there, as elsewhere, lies in keeping a good offing, and giving well-known dangers a wide berth. In making Table Bay from the northward there is, as we have said, no reason or excuse for keeping close in with the mainland. Talle Mountain can be seen many miles out at sea, and, as before observed, Robben Island, at the entrance of the bay, is well lighted. Prudent Shipmasters shape a bold course for Table Bay, and make the Mountain as a landfall. To make free with the coast, more particularly to the northward, is bad navigation, leading, as we have seen, to very disastrous results. The facts connected with the loss of the Windsor Castle and the St. Lawrence, properly brought out, will be instructive, and supply a useful and, unfortunately, a much-needed warning to Shipmasters navigating their ships into Table Bay.—December 9,

1876.

EXPLOSIVE SUBSTANCES.

Major MAJENDIE, R.A., Her MAJESTY'S Inspector of Explosives under the 38th Vic., c. 17, having placed before the Secretary of State for the Home Department his annual report for the year 1875, a copy of it has been laid before both Houses of Parliament and printed. This document deals with the inspections made by Major MAJENDIE and Major FORD at all the gunpowder, dynamite, gun-cotton, and other factories, and gives a history of the acci

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dents which happened during nine months ending December 31, 1875. At the gunpowder works there were eight disasters, involving the deaths of eleven persons and injuries to eleven. There was one accident at a patent cotton gunpowder factory, but no lives were lost or injuries sustained. Dynamite is chargeable with one explosion, accompanied with the death of one person and injury to three others; and in the manufacture of fireworks one accident took place, in which three individuals were killed and three wounded. The average for the period mentioned was below that of former periods. Major MAJENDIE enters into details with respect to the Bremerhaven explosion, and completely exhausts the whole subject in relation to the diabolical attempt made by ALEXANDER KEITH, who went by the alias of WILLIAM KING THOMAS, to destroy the Mosel (8) on the 11th of December 1875. The box contained a clockwork machine which would go for a certain time and then strike a hammer, which was so fixed as to explode the contents of the chest. KEITH-for that, it appears, was the miscreant's right name— labelled the box "Caviare," and gave directions that it should be kept in a warm room, in order that it might not be spoiled. Mr. WARD, Her MAJESTY'S Consul at Bremerhaven, states that the degree of the momentary pressure caused through the explosion of the 350 kilos. of lithofracteur has been estimated by calculating the degree of resisting power contained in the pieces of iron and other metals which were torn off the steamer at 360,000 kilos. per square centimetre, or at the rate of 360,000 degrees of atmospheric pressure. The hole made in the quay on which the case stood measured 9 metres in circumference and 2 32-100 metres in depth; and the solid pavement, with the soil beneath it, was pressed downwards, whilst neither stones nor sand were thrown up on the sides of the cavity. The Mosel and the tugboat lying alongside of her were seriously damaged, and houses at a distance of 750 metres had their windows broken. The detonation was heard at a distance of fifty-five miles. The case was lifted from a waggon in which passengers' goods were transported and slipped out of the carrier's hands. The Major enters fully into the actual cause of the explosion, and states that, by a singular oversight, the apparatus was not provided with a detent spring, Herr FUCHS, who made the machine, having understood it was meant for use in a factory. Had he known it was intended to withstand the shock of a violent concussion, he would have fitted a contrivance by which the horizontal lever could not descend till released by the mechanism. The trigger, says Major MAJENDIE, received a jar when the heavy case fell, and this may have released the hammer. Had there been no clockwork with a striking contrivance, there is every probability that the lithofracteur would not have exploded. On the 22nd of February 1872 a cardboard box containing lithofracteur, weighing five pounds and enclosed in a wooden case, was thrown from the top of a quarry on to the rocky ground below, a height of about 150 feet, but although the cartridges were thrown out, no explosion took place. A box containing 56 lbs. of dynamite, packed in ten cardboard boxes, was allowed to fall 60 feet on to broken shingle, and there was no explosion. The experiment was repeated on solid rock, with a fall of 130 feet, with the same result. Major MAJENDIE

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states, however, that in none of these instances was the substance in a frozen condition; and as the frost was severe when the calamity happened at Bremerhaven, a comparison of tests is not altogether reliable. The panic engendered by the Bremerhaven accident led to a statement that "dynamite is quite unexplo"sive by either friction or percussion at any temperature, neither will it explode when exposed to "fire alone." Major MAJENDIE declares that these statements are absolutely incorrect and dangerously misleading." Dynamite, he says, may be exploded by such agencies as those mentioned with very great ease, and he furnishes proofs of his assertion. He then states that dynamite and lithofracteur, when disposed in small quantities on hard surfaces, and subjected to percussion, are actually at least as liable to explosion as cap composition. The Major next quotes from the report of the Committee of the House of Commons on Explosives, to the effect that 6 cwt. of dynamite, contained in 12 wooden boxes, was placed in a shed, and lighted shavings applied. In about three minutes a sudden burst of flame from the dynamite set fire to the building, which burned fiercely for six minutes, when an explosion occurred. The shed was blown to fragments, and a crater formed on its site 18 feet in diameter by 2 feet in depth. It should be mentioned, however, that two of the boxes had no lids, though, as regards the explosion, this may not have accelerated the outburst. Major MAJENDIE refers to these experiments incidentally, though holding that the record of the Bremerhaven affair ought not to create undue alarm, and raise a prejudice against nitro-glycerine preparations, for the case which held the lithofracteur had travelled without accident, and with no especial precautions, to New York and back to Germany. It has been established that if nitro-glycerine escapes from the receptacle holding it and besmears, however slightly, anything of a commonly hard substance, and it is struck by a hammer, an explosion will follow. Nitro-glycerine is, consequently, an exceedingly dangerous thing to carry, as was proved by the falling of a case at Colon, and another awful affair at San Francisco. Nitro-glycerine, however, is used in the United States with as much safety as gunpowder, but great care is required in handling it. During the last nine months of 1875 the licences granted in the United Kingdom for nitro-glycerine preparations were 406, proving that this class of explosive is largely on the increase for mining purposes. To get over the difficulty of leakage, the nitroglycerine-or, as it is sometimes called, glonoine oil— is mixed with absorbents, and the names and compositions for which licences have been granted are as follows:

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The first and last of the above-named contain the largest quantity of purified nitro-glycerine. Dynamite No. 1 is prepared with the infusorial earth alone, but No. 2 is mixed with 71 parts of nitrate of potash, 10 parts of charcoal, and 1 part of purified paraffin ("ozokerit"). Lithofracteur has 1 part of charcoal, bran, or sawdust, 3 parts of infusorial earth, 21 parts of baryta and carbonate of soda, and a part of sulphur and manganese. The absorbents are intended to prevent the oil from exuding, and in cold weather there can be no doubt that protection is secured. If, however, a box is exposed to the heat of the noonday sun, or to the warmth from fires, the oily matter is pretty certain to escape. If, however, the dynamite or lithofracteur is packed in airtight metallic cases, or in boxes manufactured from any material that will not stave in, or allow the nitro-glycerine to go through them, there should be far less danger in conveying these explosive substances than those of different kinds of the ordinary gunpowder.— June 7, 1876.

OWNER'S LIABILITY FOR INJURY TO SERVANTS.

In the Exchequer Division, on the 27th of November, the action of "JONES v. The Great Western Railway Company" was finally disposed of. The cause had been heard before two juries without any satisfactory result. The plaintiff was the widow of a Bargeman whose life had been sacrificed by a bag of oilcake falling on him from the slings of a crane. It was alleged that the accident happened through one of the defendants' servants negligently handling the lift. On the plea of contributory negligence being raised, Mr. Baron POLLOCK directed a nonsuit. We may therefore assume that the servant was not wholly in fault. These actions for personal injuries have been rather numerous during the past few years, and, as a rule, where no contributory neglect can be proved, the employers are mulct in damages and costs. Decisions have, however, been recorded where an employer has been held not liable for loss of life or injury in consequence of defects in gear not being known to him. Here is an example:-A Shipwright sued Shipowners for injuries received by him in the execution of his duties. He took hold of a cross bar of the railings round the hatchway to assist him in his descent, and the rod unshipped itself in consequence of the movable end fitting very loosely in its socket. When the bar gave way the Shipwright was precipitated into the hold. It was held that, to make an employer liable, it must be shown that he knew the railing was in a dangerous condition, and, in the absence of evidence to that effect, a nonsuit was directed.-(Liverpool Court of Passage, Oct. 29, 1874.) A totally different construction of the law has also been laid down. Take the following as a specimen :-A foreman labourer in the employ of Shipbuilders was engaged in having a boiler lifted by a crane, and the hook of the chain broke. The man suffered severe injuries, and entered an action for recovery of damages. There was a flaw in the crane-hook, and witnesses for the plaintiff stated that it could not have snapped in the manner it did unless it had been faulty, and, further, that the defects could have been detected by ordinary tests. The jury awarded 5001. damages.-("MATTHEWS v. Hull Dock Company," Hull Venire Court, April 13, 1874.) In another case a hydraulic

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lift was improperly set going by a person who, it was contended, had no authority to do so, and therefore the defendant could not be made liable.-(" PARISH v. JOUANNET," Common Pleas, Feb. 23, 1874.) A labourer sued a Stevedore for injuries received through bales being thrown down a hold, one of which struck his hand and crushed it. Mr. Justice BRETT held that the man who threw down the bales was a fellow servant, and that the defendant, their common employer, was not responsible. The plaintiff was nonsuited.-(The Peterborough, "REGAN v. MARSH," Common Pleas, February 19, 1874.) A trial which occupied a considerable time in the Law Courts involved several points of a special character, one of which raised the question whether a man was a servant of the Shipowner, or, if so, for a particular service. (The Priam, "BROWN v. HOLT," Exchequer, February 5 and December 7, 1874.) A Consular passenger from Hong Kong had to sleep in the forecastle with two other Seamen. When in the tropics a section of the hatch was rigged up in order that more air might find its way below, and, in lowering a jib, a block struck the erection and sent the section edgeways down the forehatch upon the plaintiff's head, fracturing his skull and otherwise injuring him. In defence it was alleged that the erection had been put up contrary to the Captain's orders, and that the foreĥatch was a fit and proper place for the plaintiff to sleep in, according to the 212th Section of the Merchant Shipping Act, 1854. At the first trial judgment was entered for the plaintiff, but leave was given to the defendant to move the Court to enter a nonsuit against the plaintiff, or a verdict in his favour. The Lord Chief Baron, in the last action, left several questions to the jury, and it ended in a verdict for the plaintiff, with damages 4751. Another case will serve to illustrate the operation of the law as regards a Shipowner's liability for injuries inflicted on passengers or other persons not actually trespassers. A Shipping Clerk went on board a steamer at Funchal to make arrangements for coaling her. On returning to the vessel to see that the work was being properly carried on, and while passing along the deck, he fell through a bunker-hole which had been left unprotected, and thereby sustained a serious injury to his knee. The hole had been used for shooting the coals, but the men, on leaving off work, left lights to give warning of the danger, but which, it was alleged, were removed by some of the Crew. The defence was that the plaintiff, from the nature of his occupation, should have known that, during the process of coaling, bunker-holes might possibly be open; that he ought therefore to have taken more care than he did; and that his inattention had contributed to the accident. With respect to the lights, it was said they were taken away by Portuguese labourers engaged by the plaintiff himself; and although they were paid by the Master of the ship, it was argued that their negligence or improper acts could not make the defendant liable. Baron BRAMWELL, in summing up, said the case presented hardships on both sides a hardship upon the plaintiff, if he had been guilty of no negligence himself, that he should be put to so much suffering without compensation; and a hardship upon the defendant Shipowner, against whom it was not alleged that he had either an improperly fitted ship or an inefficient Crew, and on

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