evidence that it was in fact given to secure its continuance, and Kay, J., held that mere continuance of the cohabitation was not enough to raise the presumption that the bond was given in consideration of future cohabitation.

IT will be seen that neither of these cases goes much further than negativing the existence of immoral consideration, or the presumption of it in the particular case. In re Henderson, however, we get something like a general rule, for Stirling, J., laid down the doctrine that the question in all such cases was one of fact, depending upon the provisions of the deed and the extrinsic evidence afforded by surrounding circumstances attendant upon its being given. In the older cases the fluctuation of the current of decision is probably to be ascribed to the conflicting claims of the man, whose temporary infatuation has been, perhaps, heavily paid for, and on the other, of the woman, who has forfeited so much for his sake. "Circumstances," we know of old, "alter cases."

MANY eminent solicitors are getting up a demonstration for the purpose of indicating the confidence and respect entertained for the Attorney-General by their branch of the profession, and to express their sympathy with him in the matter of the recent attack that has been made against his conduct and reputation. It was also being mooted that at the meeting of the Bar on Saturday, the opportunity should be made available for a similar purpose. Sir Edward Clarke, the SolicitorGeneral, has, however, written to the Times deprecating such a proceeding. "I know," says Sir Edward Clarke, "that the Attorney-General is so far from desiring any action of this kind that he will certainly not attend the meeting, unless he is fully assured that no such attempt will be made to pledge the Bar, as a body, to the expression of any opinion with regard to incidents and conduct which cannot as yet be fully and properly

discussed."

WHEN a propensity cannot be cured, it is wise to endeavour to control, or at least to guide it, so as to minimise the evil its indulgence might cause. Most men are born speculators. They commence in childhood with buttons and marbles, and they finish up either on the stock market or the racecourse, the former more reputable than the latter. If people then will dabble in stocks and shares, a journal performs a useful task in enquiring and investigating into the character, conduct, and ability of hose to whom the public are accustomed to resort for advice. For it is notorious that with the eminent exception of the three gentlemen whose names have appeared prominently in these columns, and two others-it may be three or four others -a great majority of persons who invite the public to trust them as honest guides, are unworthy of credit for honour or skill. Men whose time would seem more legitimately and usefully employed in helping their mothers at home to turn the mangle, or in vending small articles for domestic consumption, hold themselves out as guides and mentors of that gullible portion of the public who think that because a man calls himself a broker he may be trusted. These men, too, by their mode of action, reflect much discredit on the whole calling. In these circumstances we conceive that our interviewer has done good public service in finding out three gentlemen of responsibility and integrity. But we are by no means to be understood as in any wise advocating Stock Exchange speculations. What we only profess to say is, that if you are determined to speculate, and you are about to resort to a dealer, mind you are careful whom you select, and our interviewer has taken some trouble, according to the best of his judgment, to guide you aright.

WE regret to hear of the indisposition of Lord Justice Bowen, one of the kindliest, as well as ablest, judges on the Bench.

THE TEMPLE NEWSPAPER LAW

REPORTS.

COURT OF APPEAL.

MORRIS v. SALBERG.-Action against Execution Creditor for Directing Seizure by Sheriff of Plaintiff's Goods, Plaintiff not being Execution Debtor.-Direction Endorsed on Writ by Solicitor.-Scope of Solicitor's Authority.-Respondent Superior.-Whether Endorsement Amounted to Direction in Law.-Defendant recovered judgment against Morris, plaintiff's son, and issued fi. fa. against him. Defendant's solicitor endorsed fi. fa. : "The defendant is a gentleman who resides at Same Park, Llandysil, Cardiganshire." That address was in fact that of plaintiff, and not of his son, but the sheriff of Cardiganshire levied at Same Park, and his action was ratified by defendant and his solicitor. Action brought against sheriffs was stayed. Present action being brought against execution creditor, the jury found that the sheriff seized the goods of the plaintiff, instead of those of his son, because he was misled by the direction he received from defendant's solicitor, and assessed damages. Stephen, J., however, entered judgment for defendant, holding the endorsement on the writ was not a direction in law. Held (by Lord Esher, M.R., Fry, and Lopes, L.J.J.), that the decision of Stephen, J., must be reversed, for that the endorsement made by the solicitor might in law be a direction to the sheriff to seize the particular goods taken, that the jury having found the sheriff was misled, thereby the execution creditor was rendered liable by the act of his solicitor.

BAINBRIDGE v. SMITH.-Company.-Articles of Association.Meaning of Vacation of Office of Director.-Whether Provision Applicable to Directors Appointed by Agreement with Vendors to Company-Director's Qualifying Shares.-Meaning of Term “holdlimited company was one providing that the office of director ing in his own right."—Amongst the articles of association of a was to be vacated, inter alia, "if he ceases to hold the required amount of shares or stock to qualify him for the office, or do not acquire the same within one month after election or appointment." Held (by Cotton and Lindley, L.J.J.), that this provision had no application to managing directors appointed by an agreement with the vendors to the company qualification of a managing director should be "the holding in adopted by the articles. Another article provided that the his own right of shares or stock of the company of the nominal value of £25,000." Per Cotton, L.J., the words "in his own right" mean a beneficial holder including a mortgagor, the dicta of Jessel, M.R., in Pulbrook. v. Richmond Consolidated Mining Company, 9 Ch. Div., 610, dissented from. Per Lindley, L.J., that those dicta having been acted on so long, exception ought not now to be taken to them, and that "in his own right" has acquired by usage the meaning that the shares shall be held in such a manner that the company can safely deal with the holder as if he held them as his own.

LUMLEY V. BROOKES.-Action by Solicitors for Bill of Costs and Disbursements.-Defendant not Appearing, though Alleging and Counterclaiming for Negligence.-Right of Plaintiffs to Judgment and not merely to Order Directing Taxation.-Action by firm of solicitors against a client to recover amount of bill of costs and disbursements. Defence, no retainer, and negligence and counterclaim for damages for negligence in conducting action in which costs incurred. Defendant did not appear at trial and Kay, J., holding plaintiffs had proved the retainer, made an order referring the bill to the taxing master for taxation, reserving costs of action and adjourning further hearing with liberty to apply, and declined to make any other order. Held (by Cotton, Lindley, and Fry, L.J.J.), that the plaintiffs were entitled to have the counterclaim dismissed with costs, also to judgment for the amount claimed, subject to taxation, with

costs.

QUEEN'S BENCH DIVISION.

BISHOP et al. v. CONSOLIDATED CREDIT CORPORATION. Bills of Sale Acts.--Bill of Sale in Consideration “of the Sum of £30 now Paid."-Consideration Truly Stated.-Cheque to Order of and Indorsed by Grantor Taken Away by Grantee and £25 158. applied in Paying out Distress.-Plaintiff, a tenant, owing her landlord £21 for which he had distrained, raised money to pay out the distress by a bill of sale to defendants. The bill of sale was expressed to be granted in consideration of "the sum of £30 now paid." A cheque drawn to plaintiff's order was produced to her and endorsed by her, but the defendants' agent then took it away, cashed it, paid the landlord and the broker £21 and £4 15s., and afterwards handed plaintiff the balance. Held (by Hawkins and Charles, J.J.), affirming the judge of the City of London Court, that though the payments were made in good faith the consideration was not truly stated, and the bill of sale was void.

THE BAR COMMITTEE.

SIXTH ANNUAL STATEMENT.

AT the annual general meeting of the Bar, held in the Old Dining Hall, Lincoln's-inn, on the second Saturday in Trinity Sittings, 1888, the following members of the committee retired by rotation: Sir Horace Davey, Q.C., M.P., Messrs. R. B. Finlay, Q.C., M.P., R. A. Baysford, Q.C., G. Pitt-Lewis, Q.C., M.P., H. B. Buckley, Q.C., W. C. Renshaw, Q.C., E. W. Byrne, Q.C., H. F. Boyd, G. Farwell, C. E. H. Chadwyck Healey, Howel Jeffreys, M. Ingle Joyce, W. W. Knok, E. L. Levett, Decimus Sturges, and E. P. Wolstenholme.

To fill the vacancies caused by the retirement of the abovenamed members, twenty-six candidates were duly nominated, and at a poll held during the week ending the first Saturday in Trinity Sittings, the following received the largest number of votes, and were duly declared elected by the chairman : Sir Horace Davey, Q.C., M.P., Messrs. R. B. Finlay, Q.C., M.P., G Pitt-Lewis, Q.C., M.P., W. C. Renshaw, Q.C., E. Cutler, Q.C., E. W. Byrne, Q.C., S. Hall, Q.C., H. F. Boyd, F. Evans, G. Farwell, Howell Jeffreys, M. Ingle Joyce, W. W. Knox, R. H. Pinhey, Decimus Sturges, and E. P. Wolstenholme. Six hundred and fifty-two voting papers were received, but a large number were delivered after the close of the poll, and were therefore rejected.

The committee appointed Mr. Gilbert G. Kennedy to be a member of the committee in the place of Mr. Horace Smith, who has ceased to practise at the bar.

At the first meeting of the committee after the election, the Right Hon. Sir Henry James was re-appointed chairman, Mr. W. F. Robinson, Q.C., vice-chairman, Mr. E. P. Wolstenholme, treasurer, and Mr. Lofthouse, honorary secretary.

At the last annual general meeting, Messrs. Yarborough Anderson and R. B. Haldane were re-appointed auditors.

During the past year the Bar Committee have had their attention directed to numerous subjects affecting the Profession, and amongst others the following:

LAND TRANSFER BILL.

The Lord Chancellor having forwarded to the committee a copy of the Land Transfer Bill, with an intimation that he would be glad to consider any observations upon the clauses which the Bar Committee might be disposed to make, a report on the Bill was drawn up by a sub-committee, consisting of Sir Horace Davey, Messrs. Rigby, Channell, Byrne, Kenelm Digby, Dunning, and Wolstenholme, and adopted by the committee. This report was necessarily of considerable length, and a large amount of time was devoted to its preparation by the sub-committee. The committee are glad to know that this report and their former report on land transfer were very fully considered by the members of the Select Committee of the House of Lords, by whom the Bill was considered.

SITTINGS OF THE QUEEN'S BENCH DIVISION.

A joint committee was nominated by the Bar Committee and the Incorporated Law Society to consider the subject of the sittings of the courts of the Queen's Bench Division. The joint committee consisted of the chairman and the vice-chairman of the Bar Committee, and Messrs. Finlay, Q.C., Channell, Q.C., W. Rann Kennedy, Q.C., Kenelm Digby, W. Graham, R. Vaughan Williams, and R. S. Wright, nominated by the Bar Committee; and the President and the Vice-President of the Incorporated Law Society, Mr. John Hollams, Sir Henry Watson Parker, Mr. Henry Roscoe, Mr. J. W. Budd, Mr. William Walton, Mr. J. M. Johnstone, and Mr. F. K. Munton, nominated by the Incorporated Law Society. A report was drawn up by the joint committee and adopted by the Bar Committee and the Incorporated Law Society, and copies of the same were laid before the Lord Chancellor and the Lord Chief Justice of England and the judges. At the request of the Lord Chief Justice, a deputation from the joint committee had an interview with his lordship and three of the judges for the purpose of discussing the suggestions contained in the report. The committee are glad to say that most of these suggestions have been carried out, and it is hoped that the result will prove to be advantageous, both to the profession and the public, by lessening the uncertainty as to the time when actions will come on for trial, and the consequent expense of keeping witnesses in waiting. COUNTY COURTS.-COUNTY COURT CONSOLIDATION BILL, 1888. This Bill was fully considered by the committee, and a report thereon was prepared and placed in the hands of the legal members of the grand committee, and many of the suggestions in the report were adopted. As to clause 72, evidence was received by the committee from members of the Bar, from whom they learnt that instances had occurred in which a county court judge had, in deciding as to the order in which the business of the court should be transacted, felt himself fettered by the words of the clause as it then stood, which gave the barrister a right to appear, "but without any right of exclusive or pre

audience." The committee suggested that the words " or pre-" should be struck out, on the ground that on the evidence before the committee it was detrimental to the public interest, in that suitors were often deprived of the assistance of counsel in those cases in which their assistance was much needed. It constantly happened that counsel were kept waiting in court for a whole day, and sometimes for a longer period, without the case in which they were engaged being heard by the judge. The effect was that counsel declined to attend the court altogether, or required an increased fee. The committee are glad to say that the words were struck out of the Bill as they suggested, and County Court judges will now have full power to make regulations for the orderly transaction of the business of their courts. This alteration is of the more importance in consequence of the increased jurisdiction, and it is hoped that barristers and others will now have better information as to the time when cases in which they are engaged will be called on. With that view, the Bar Committee have prepared blank forms for daily lists of County Court business, and have supplied these with stamped and directed wrappers to the Registrars of all the Metropolitan County Courts. These will be posted in a frame outside the door of the Inner Temple Dining Hall. The notice board has been erected by the Benchers of the Inner Temple, who at once acceded to the request made by the Bar Committee that they would do so.

CIRCUITS.

The Bar Committee regret that it does not appear that it has yet been found practicable to carry out the scheme for the circuits which was understood to have been approved by the judges early in 1888. The serious evils arising from the one judge system still continue on most of the circuits. It would be useless to repeat the arguments that have been frequently urged by the Bar Committee, as they are well-known, both to the profession and the judges. A copy of a report by Mr Justice Cave on "Circuits" has been forwarded to the Bar Committee by his lordship. This almost entirely meets the views of the committee, and they trust that it will have an important influence in remedying evils which are now of long standing. During the year resolutions have been passed by the North-Eastern, South-Eastern, and Midland Circuits, and the members of the Northern Circuit practising in London, and forwarded to the Bar Committee. These have been approved by the committee; they relate principally to the trial of quarter sessions' prisoners at the assizes, and express an opinion that such prisoners should be tried at quarter sessions. Copies of the resolutions, together with the report of the Bar Committee, have been laid before the Lord Chancellor, the Lord Chief Justice of England, and all the judges. It is hoped that the desired object will be effected by the Assizes Relief Bill (which, it is understood, will be re-introduced into Parliament early in the session), and that the result will be that the time now occupied by the assizes will be considerably shortened, and that consequently the courts in London will be able to sit for longer periods to dispose of more important business.

NEW RULES OF COURT.

A joint committee was appointed by the Bar Committee and the Incorporated Law Society to consider the question of the promulgation, from time to time, of new rules of the Supreme Court. The joint committee consisted of Messrs. W. F. Robinson, Q.C., Cozens-Hardy, Q.C., F. A. Bosanquet, Q.C., M. Ingle Joyce, and R. Vaughan Williams, nominated by the Bar Committee; and the President, Vice-President, Messrs. Hollams, Hunter, and Markby, nominated by the Incorporated Law Society. The joint committee considered that it was important in the interest of the public, and for the convenience of the members of the Profession generally, who have charge of those interests, that a sufficient opportunity should be afforded them for the consideration in draft of any proposed rules. Many of the rules involve matters of detail in procedure, in respect of which the practitioners in the Supreme Court, both barristers and solicitors, have necessarily a very large experience, and would be able to render very material assistance. A communication was addressed to the Lord Chancellor, signed by the vice-chairman of the Bar Committee and the President of the Incorporated Law Society, requesting his Lordship to give the subject his favourable consideration, with the view of making arrangements so that the Bar Committee and the Incorporated Law Society might have an opportunity of considering new rules of court in time to make any suggestions thereon before the same came into force. In reply, his Lordship stated that he fully recognised the material value of the assistance which members of both sides of the Profession are capable of rendering in the passing of rules of the Supreme Court, and that any suggestions with reference to legal procedure coming from the Law Society and the Bar Committee would be received with interest and considered with the greatest care, and his Lordship invited both those associations to aid the judges with such suggestions from time to time.

FEES CHARGED TO BARRISTERS FOR SEARCHING THE ROLLS.

The Bar Committee having been informed that, under the rules and regulations of the Record Office of the 1st May, 1887

a fee was charged to barristers having occasion to search the rolls, the committee communicated with the Master of the Rolls, calling his attention to the fact, and asking his Lordship to consider whether the privileges which had previously been granted to the Bar might not be restored to them. His Lordship thereupon made the new rule of the 1st of August, 1888, which ordered that the fees should be remitted in the case of any barrister desiring to consult records of a later date than the year 1760 for the purpose of obtaining instruction for himself, or for literary use, or to use as citations by way of authority to the court, and not for the purpose of obtaining information as to facts to be used by or between other parties.

SITTINGS OF THE CHANCERY DIVISION.

In November last a joint committee was appointed by the Bar Committee and the Incorporated Law Society for the purpose of preparing a report on the sittings of the Chancery Division. The joint committee consisted of Messrs. W. F. Robinson, Q.C., Romer, Q.C., Cozens-Hardy, Q.C., W. C. Renshaw, Q.C., E. W. Byrne, Q.C., Methold, Decimus-Sturges, Ingle Joyce, Farwell, and Vernon Smith, nominated by the Bar Committee; and the President, Vice-President, Messrs. J. Addison, J. W. Budd, J. Hollams, H. L. Pemberton, H. Roscoe, W. H. Gray, H. J. Francis, and Thomas Rawle, nominated by the Incorporated Law Society.

In January the joint committee made a preliminary report: They were of opinion that it was absolutely necessary for the efficient disposal of business in the Chancery Division that an additional judge should be appointed, so that two judges of the Chancery Division might sit continuously for the trial of witness actions; that the occasional services of a judge attached to the Queen's Bench Division would not meet the difficulty; that the new judge should be a permanent judge, familiar with the principals of equity and the practice of the Chancery Division. In the opinion of the joint committee, the details of any rearrangement of business could not be usefully suggested or reported upon until it was known what judicial staff would be provided for working it. joint committee had considered various suggestions for facilitating the business of the division; but they were of opinion that any further report would be more usefully made when it is known whether or not an adequate staff would be provided for the speedy and effective administration of justice in the Chancery Division.

The

The preliminary report was afterwards adopted by the Bar Committee and the Incorporated Law Society, and sent to the Lord Chancellor.

CONGRESS ON INTERNATIONAL LAW, BRUSSELS, 1888.

The Lord Chancellor forwarded to the Bar Committee an invitation to representatives from England to attend the Congress, with a request that the Bar Committee would nominate some gentlemen for the purpose. Unfortunately, the invitation was not received until the middle of the Long Vacation, when it was found impossible to procure the attendance of any representatives from the English Bar.

THE ROYAL COURTS OF JUSTICE.

The sub-committee, which now consists of Messrs. S. Hall, Q.C., W. W. Knox, English Harrison, Bargrave Deane, and Farwell, in July last submitted to the principal secretary of the Lord Chancellor suggestions (based on a report made by one of their number) for the improvement of the fittings of the various courts and the better accommodation of the Bar, urging the necessity for an additional robing-room near the Strand entrance, and the desirability of having a barrister's room in the building.

Some of these suggestions were attended to during the Long Vacation, and in October and November last further representations were made by the sub-committee, with the result that the fittings of the courts have been considerably improved, and the sub-committee have been given to understand that endeavours will be made to supply an additional robing-room, and that the possibility of providing a room in the building for the use of the Bar will be further considered.

FINANCE.

From the above statement, which does not by any means exhaust all the work which has come before the committee during the past year, it will be seen that the amount of work to be done by them has considerably increased, and the labour falling on their honorary secretary has become very serious. It is plain that the work of the committee cannot be properly done without the assistance of a salaried officer, but the number of subscriptions received annually does not permit of any proper salary being paid. The committee therefore appeal to the members of the Bar to subscribe in larger numbers, so as to give the committee the assistance of a salaried officer, and thus enable them properly to dispose of the increasing work which falls on them.

CORRESPONDENCE.

[The Editor does not necessarily agree with the statements and opinions of his correspondents.]

To the Editor of PUMP COUrt.

SIR, AS I feel convinced that "thou wouldst that truth should prevail at thy court" at all cost, I am emboldened to make a slight correction or two upon your interviewer's gleanings from the New York Life Company's general manager.

To-day, I took PUMP COURT to the club to have a quiet read over, and when I came to your interviewer's adventures I rubbed my eyes thinking that the somnolent effect of the ease and comfort around had sent me off into a dose, and that the facts of American Life Assurance history had become disarranged in consequence; but I found that all the rubbing of the eyes in the world could not alter the paragraph as printed. Here it is: "In answer to that, I would advise you to read our prospectus. However, I can say that we were the first to introduce Tontine Endowment Insurance here, and from time to time the original plan has been improved upon, by adding all the most notable and valuable features which life insurance experts have yet discovered, and in consequence of this our non-forfeiting free Tontines is the latest and most improved form of policy issued by any office."

Naturally on reading this, question after question came into my mind and arranged themselves somewhat after this order :1. What company invented the tontine system of life assurance?

2. What company from time to time improved the original plan ? 3. What company started the non-forfeiting or semi-tontines?

4. What company invented and first issued the free tontine policy?

5. What company made all its policies incontestable and undisputable, and by its example compelled all other companies to follow its example?

6. What company first started immediate payment of claims on completion of proofs of death, in the place of long delays of months and even years; and a long list of other improvements, both of the tontine and other forms of life assurance ?

The answer to these questions stood out clear and distinct: The Equitable Life Assurance Society of the United States was the pioneer of all these improvements, and force of circumstances compelled other life offices to follow in its wake.

There can be no doubt but that the Equitable stands as the great monument of truth in life assurance and other companies dwell in its shadow, and in the mystery of that shadow our friend Fisher-Smith seems to revel.

At the Club here I have not dates by me of all the facts relating to the history shadowed forth in the above questions. But briefly put it is as follows:

In 1869 the Equitable invented and started what was the original tontine policy, and in 1871, when in Manchester, I advocated insurance in both tontine life and endowment policies. At that time there was no suspicion of any form of tontines on the New York Life's prospectus, but in the latter part of the next year, I learnt that the New York had adopted the Equitable form of tontine policy.

Some years afterwards the Equitable, to meet the want of the public, introduced the semi-tontine policy with its nonforfeiting clauses. Then in the early part of the next year (somewhere about April), the New York again adopts the Equitable, new form of tontine policy, and calls it the latest departure in life assurance, making people believe that they originated that form of policy.

Then some three years ago I can remember being at a grand banquet at the Hotel Metropole, at which President Hyde was present; in fact, it was given in his honour by Mr. Parker. President Hyde gave a clear history of the formation of the Equitable Society, touching upon all the improvements introduced by the Directors of the Equitable into its policies, both tontines and ordinary life, and wound up as a grand climax with the new free tontine policy; and when I was in America last year I found that from private information given me that i was the intention of the New York Life to copy that form of policy also, aud make it its leading feature. Now I note they call it "OUR Non-Forfeiting Free Tontine is the latest and most improved form of policy issued by any office."

Verily friend Fisher-Smith has not left any of his native assurance behind him when he "yellow-stoned" your interviewer with one of his marvellous descriptions from out of the mysteries of the shadow of truth.

Your interviewer appears to have gone away astounded at the New York's new business of £26,000,000. What would he have done had he had it whispered into his ear that the Equitable did over £32,000,000. Verily he would have been wafted into Wonderland, there to wander through eternal space.

dreaming of that grand total of human misery relieved and atoned for by the loving Providence of thousauds of husbands and fathers.

In anticipation, I thank you for your courtesy in allowing me a space in your valuable "Court" to place truth on its proper pedestal. Your obedient servant,

LOUIS E. De Ridder.

UNDER THE PUMP.

A Strange Message. By Dora Russell. Three vols. (London : Sampson, Low & Co).-Legal readers of fiction, and there are innumerable members of both branches of the profession who find their pleasantest form of recreation in the perusal of the creations of the romancist's fertile brain, might well dub this clever and exciting story "The Great Personation Case," as the plot turns upon the curiously audacious personation of a dead woman by her sister. Miss Dora Russell is an adept at the art of weaving intricate and fascinating plots, and it would therefore be distinctly unfair to her, as well as to her readers, to reduce their interest in the perusal of her clever book by indicating in any but the most shadowy manner the ingenious problem upon which the plot hinges. Suffice it that we are introduced to a certain James Biddulph, a handsome, distingué man, rich, but living a life of comparative seclusion, in itself suggestive of mystery and romance. We guess at once that there is a turned-down page in this man's life-story, a page probably blotted and blurred-one which, if he could, he would gladly forget. It is not, therefore, altogether surprising to find that the "strange message " which gives its title to the book is one which is received by Leonora Stewart, the heroine, a charming Scotch girl, and that it warns her that James Biddulph, the man whom she has learned to love, and from whose lips she is hourly expecting a proposal, is not a man with whom she should associate, if she has any regard for her honour and her peace of mind. A hot-blooded young lover, one Alick Fraser, who would lay down his life for a kind word from Leonora, complicates matters, and we soon find ourselves confronted alike with a murder and a mystery. From that moment the novelist holds our attention in a dual chain, and with admirable art she contrives not only to throw suspicion, with all the damning circumstantial evidence conceivable, upon an innocent man, but also to maintain inviolate until an advanced stage of the story, the mystery which environs the personality of the individual whose name is written on James Biddulph's turned-down page, and whose wiles and machinations constitute the unknown personage, the evil genius of the story. But A Strange Message is not entirely and solely a story of sensational incident. Many clever character sketches enliven the author's pages, and we get glimpses of pleasant people and pleasant places, as well as studies in the romance of crime. Indeed, A Strange Message is a peculiarly readable story, free from vulgarity or anything offensive, although the scene in which the personation problem is solved-or rather attempted to be solvedis somewhat grim and ghastly, and it will certainly add to its author's reputation. Tolucid and vigorous diction, Miss Russell adds an exceptional power of plot-weaving, and while her characters are life-like, her incidents are exciting, without outrunning the limits of probability. In a word, A Strange Message is a decidedly wellwritten and well-conceived story, romantic, sensational, yet not extravagant or vulgar. The author does not impose too great a strain upon her readers' credulity, nor does she insult their common sense or their good taste, and the result should be that her clever style and well-directed efforts should render her latest story

popular with all who can appreciate stimulating yet wholesome fiction.

The Practice of the Railway and Canal Commission. By A. Raye Butterworth, LL.B., solicitor, formerly of the Inner Temple, barrister-at-law. (Butterworths).This is a supplement to the able work by the same author, viz., A Treatise on the Law relating to Rates and Traffic, which we reviewed in our issue of 13th of March last. This supplement, however, will be found of independent use, and is an exceedingly handy and portable manual for practitioners in the Commissioners' Court, and cannot, at the same time, fail to be useful to any one of the numerous persons interested in or affected by the Traffic Acts. The notes and the arrangement of them are admirable, but the index it is which most claims our commendation. Old readers of Pump Court know how strongly we have had sometimes to condemn what would otherwise be good books on account of faulty or incomplete indexes; if, indeed, any law book can be said to be other than bad if the index is weak. We can cordially recommend the little manual.

The New Law and Practise of Railway and Canal Traffic. By Robert Woodfall, of the Inner Temple, barrister-at-law (Wm. Clowes & Son, Lim.), 1889.-This volume gives us at length the Railway and Canal Traffic Act, 1888, and the rules of procedure to be observed in the constitution of the Railway and Canal Commission, with notes embodying cases on more important points. The book will prove, we believe, a useful contribution to the literature dealing with questions to be litigated in that Court, from the eminently accessible form in which the author has compiled his treatise, and the useful and readable introduction, or sketch of previous legislation on the subject. The rules of procedure, so lately issued, given here, will be found wanting in many of the treatises which were earlier in the field.

Books received :-Select Pleas in Manorial and other Seignorial Courts. Temp. Henry III. and Edward I. Edited for the Selden Society by F. W. Maitland. (Bernard Quaritch).

TEMPLE CHURCH.-APRIL, 1889.

April 14.-Palm Sunday.-Morning: Te Deum Laudamus in F(Attwood); Jubilate Deo, in F (Attwood); Anthem," Glory honour, praise, and power" (Mozart). Evening: Magnificat in F (Attwood); Nunc Dimittis, in F (Attwood); Anthem, "Who is this?" (Kent).

April 19.-Good Friday.-Morning: Te Deum Laudamus, Chant; Benedictus, Chant; Anthem, "He was despised Chant; Anthem, "He was despised" (Hopkins). (Handel). Evening: Magnificat, Chant; Nunc Dimittis,

INSURANCE.

As the Atlas of mythology supported Atlas Assurance on his shoulders the pillars on which the Company. world rested, so with equal ease his modern namesake of the assurance world supports the weight of the assurances it has assumed to carry. On Friday, the 29th of March, there was held at the company's house, in Cheapside, the 81st Annual General Court of Proprietors, and the deposits and accounts that were there presented show that, because an office has become an octogenarian in years, there is no reason why it should lose the full vigour of virility. A few years since, this company was lapsing into a state of non-progression, and bade fair to assimilate to that position that we have pointed out often becomes the condition of offices that have grown old, and at the same time wealthy. With Life Funds of a sufficient calibre to carry them over each successive valuation, they often become increasingly apathetic as the years go on.

The Atlas, however, has sprung into new life and vigour under the present able management, and now bids fair to place itself well forward in the van of leading companies. Its new business for the year shows an increase over that secured in the preceeding, and amounted to nearly £400,000. For a few years past, the new business has been going steadily up, and if the increasing ratio which has characterised the past is maintained, we may look for an advancement in this particular that could hardly be expected, considering the age of the office. It is a matter of pleasure to have this to note, for it sustains our old contention that there exists no reason why a life assurance organisation should not be in as healthy and growing a state at 500 years as it was at 50.

The premium income showed anincrease, as would be naturally expected, but owing to the exceptionally large amount of single premiums received, was not as correspondingly greater than the previous years, as it would otherwise have been,

The Life Assurance Fund was also augmented during the year, and showed the fine array of figures comprised in £1,397,288.

On the disbursement side of the accounts we find the claims were £120,052. This was after sums re-assured had been deducted, but include reversionary bonus additions. The amount expended in commissions and management expenses was not as large as the increased accession of new business would seem to call for, being £16,700, which is not a heavy per centage of the premium income when compared with that of other offices who push for new policy holders. Other items were of a nature satisfactory to shareholders and assuring to all interested in any way.

As the last quinquennial valuation was for the five years ending December 25th, 1884, one will come in due course at Christmastide of this year. What the result of this will be is not our province to anticipate, even if we possessed the power; at the same time we have a feeling instinctively and otherwise that the Atlas is now on the up grade to greater successes and a more prosperous career than ever it has enjoyed heretofore, and we shall watch its future with renewed interest.

In the Fire Department the premium income has experienced increasing figures in each succeeding year for several years past, and amounted to £187,432 in the year just ended. The ratio of losses to premium was 53.8 per cent., which compares favourably with the general annual average of other first class offices, being considerably under the experience of many of them. Five years is a very fair period in which to take a survey of the progress of the business. The Atlas record in this respect shows its annual fire premium income to be as nearly as possible double that of five years ago. We believe this growth of business has taken place side by side with a very exhaustive weeding-out of much of the business which had been on the books for many years. The accounts of this company show that the

average loss ratio for the past five years has been under 55 per cent. compared with a loss ratio for the preceding five years of 64 per cent. While the dividend has been restored from 15 per cent. to 20 per share, the reserves have been strengthened by some £90,000. It is scarcely then a matter of surprise that the shares to-day stand in the market at 23 as against 13 five years ago. That a new, vigorous but cautious hand has been at the helm of management during the last five years is abundantly evident. We have always said that in insurance matters it is the man not the machine that determines success. The cautious foresight evinced by the manager in building up reserves corresponding to the expansion of business is one well worthy of imitation by other offices, and the absence of which we have had frequently cause to complain of. The statement of the chairman at the last three annual meetings showed that some £12,000 had been saved each year by the discontinuance of insurance on properties which the manager considered too risky, and events proved he was right, for these were burnt within the period mentioned. The head office of this company at 92, Cheapside, is conducted with a clockwork regularity, precision, and smoothness, if we may use the term, which few other offices equal, and none surpass, while the branch offices in Pall Mall, at Bristol, at Leeds, Liverpool, Manchester, and Glasgow, all show signs of a new vitality infused into them from the parent office.

But the Atlas does not now limit its work to the great insurance centres of the Kingdom. Some four or five years ago, soon after the installation of the present manager, Mr. Pipkin, the Company embarked in foreign fire business, and we believe we are right in stating that the loss rate in this business for the whole time is but slightly over 50 per cent. If to this be added about 30 per cent. for commissions and expenses, we get a rough idea of the profit that has accrued in this department of risks, viz., 20 per cent., which is a very handsome showing. We have rated the expense as high as 30 per cent., because it can never fall far short of this when the expenses incident to careful watching of the risks are considered.

All these good results in both departments, Life and Fire, have been attained by the Company since the accession to office of the present secretary and actuary.

Assurance Co.

ON Tuesday, April 2nd, the 42nd British Empire annual general meeting of the British Mutual Life Empire Mutual Life Assurance Company was held at the Cannon Street Hotel, and 42nd annual report of the directors was submitted to the members, together with the accounts and balance sheet for the year 1888, in the form required by statute. Mr. John Runtz, chairman of the directorate, presided, and in moving the adoption of the report said that 2,406 proposals were received, amounting to £968,041, resulting in 2,036 policies for £834,315, with a new annual premium income incident thereon of £27,996. During the year 300 policy-holders had died, the claims in consequence of which, with bonus additions, amounted to £92,854. The number of deaths was below the number expected, and the claims in consequence were less than those of the previous year by £13,881. The total premium income (less reassurance premiums paid to other companies) is £190,654; and the total income from all sources is £261,288.

This office is conducted on the strictly mutual principle, and all surplus income is added to the accumulated fund for distribution to policy-holders at each triennial valuation. The surplus income for the past year was £83,625, out of which £16,754 was paid to policy-holders as cash bonus, and £1,706 allowed in reduction of premium, leaving £65,165 as the net addition. to funds. The average rate of interest obtained on the invested securities (which are all of the highest class) exceeded £4 7s. 6d. per cent. The Accumulated Life Fund at the close of the year stood at the handsome figures of £1,277,266.

The British Empire Mutual has made rapid strides