Company.]—Mayor of Sheffield v. Barclay, 19 T. L. R. 2, is an important decision as to the incidence of loss in the case of a forged transfer of shares. The defendants without negligence and in good faith accepted a forged transfer of shares of the plaintiff corporation to one of their firm, and at their request the plaintiff corporation, also without negligence and in good faith, registered the transferee as owner. Subsequently the shares were sold by the defendants and the purchasers were registered as owners and new certificates issued to them. In an action brought by the true owner against the plaintiffs, the transfer to the defendants' nominee was found to be a forgery and the plaintiffs were ordered to make good the loss. They were held entitled in this action to indemnity from the defendants, the principle applicable being, according to the Lord Chief Justice, that when one of two innocent persons must suffer, the one who has innocently put forward the request upon which the other has acted must bear the loss. He considered that, in view of the subsequent disposition of the case, the view of Lindley, J., to the contrary in Simon v. Anglo-American Telegraph Co., 5 Q. B. D. 188, was not binding upon him.-In re Hiram Maxim Lamp Co., 19 T. L. R. 26, emphasizes the effect of a winding-up order. A shareholder, sued for calls, pleaded a set-off. Before trial the company went into liquidation. It was held that the ordinary rule applied and that as against the liquidator claiming payment of the unpaid balance of the shares the alleged set-off was of no avail. See the Winding-up Act, R. S. C. c. 129, and the notes thereto in Masten's Company Law.

Constitutional Law.] The judgment of the Judicial Committee, reversing that of the Supreme Court of Canada, 31 S. C. R. 516, as to the extent of the jurisdiction of the arbitrators respecting Provincial Accounts upon questions affecting the Common School Fund, is reported 19 T. L. R. 46, under the already well-worn name of Attorney-General for Ontario v. Attorney-General for Quebec.-The judgment in Ontario Mining Co. v. Seybold, affirming that of the Courts below, 31 O. R. 386, 32 O. R. 301, 32 S. C. R. 1, is reported 19 T. L. R. 48.

Contract.] Read v. Friendly Society of Operative Stonemasons, 19 T. L. R. 20, and Bulcock v. St. Anne's Master Builders' Federation, 19 T. L. R. 27, throw a good deal of light on the vexed question of the extent of the right to interfere between employer and employed. In the first case the Court of Appeal, varying the judgment of a Divisional Court -18 T. L. R. 577, noted 22 C. L. T. 263-held that the defendants a trade union-were liable in damages to the plaintiff for compelling, under threat of a strike, his employers to discharge him. In the second case, the converse of the first, the discharged workman failed in his action against the Masters' Federation, who had, as he alleged, compelled his discharge because he had before entering the employment in question joined in a strike, the evidence failing, in the opinion of the Court, to shew any direct pressure by the defendants, or anything more than a bona fide exercise by the employers of their admitted right to terminate the plaintiff's employment.-Lumsden v. Barton and Co., 19 T. L. R. 53, is a "coronation" case. The plaintiff sued to recover the price of seats on a stand "to view the procession." Darling, J., distinguishing his own decision in Krell v. Henry, 18 T. L. R. 823, noted 22 C. L. T. 362, on the ground that the defendants had incurred expense in getting the seats ready, held that there had not been a total failure of consideration, and that therefore the action failed.

Criminal Law.]-In Smith v. Moody, 19 T. L. R. 7, a conviction under s. 7 of the Conspiracy and Protection of Property Act, 1875,-with which s. 523 of the Criminal Code is almost identical-for that the defendant, with a view to compel a person to abstain from working for another, unlawfully and wrongfully did injure his property, was held bad for not stating what the property injured was. An objection that the particular work abstained from should have been stated was overruled.-Tromans v. Hodkinson, 19 T. L. R. 19, decides that a bookmaker, who went to the bar of a public house at stated hours and made bets with persons resorting there for that purpose, used the bar for the purpose of betting, and was therefore properly convicted under s. 3 of the Betting Act, 1853. See the Criminal Code, s. 197, as amended by 58

& 59 V. c. 40, and Rex v. Hanrahan, 3 O. L. R. 659.-In Rex v. Pittwood, 19 T. L. R. 37, a railway gate-keeper, who had forgotten to shut the gate at a crossing, so that a man drove upon the line when a train was approaching and was killed, was held to have been rightly convicted of manslaughter. The contention that for his breach of duty the gate-keeper was answerable to his employers (the railway company) alone, was held to be untenable.

Estoppel.]-Section 102 of the Larceny Act, 1861, s. 157 of the Criminal Code being to the same effect-provides that any one publicly advertising, or printing or publishing an advertisement of, a reward for the return of stolen property, using any words purporting that no questions will be asked, is liable to a penalty of £50 to be recovered by action. The plaintiff in Nutt v. Sol Syndicate, 19 T. L. R. 27, had recovercd judgment in another action against the supposed publisher of a paper in which an illegal advertisement had appeared. It was held that he was estopped in this case from contending that the defendant in the former action was not the publisher and that the defendants in this action were the publishers. Compare Toronto Dental Mfg. Co. v. McLaren, 14 P. R. 89; Keating v. Graham, 26 O. R. 361.

Fixtures.]-The question of fixtures as between mortgagee and conditional vendor of the mortgagor is again elaborately dealt with by the Court of Appeal in Reynolds v. William Ashby and Son, 19 T. L. R. 70, and the articles in questionmachines worked by steam and fastened by bolts and screwswere held to have become subject to the mortgage.

Gas Company.] That an automatic slot meter is the agent of its owner to receive payment for the wares supplied by it is the short and perhaps fairly accurate way of putting the point decided in Edmundson v. Mayor of Longton, 19 T. L. R. 15, a case placed under the heading of gas company because of the (legally speaking) accident that gas was the commodity supplied by the particular machine the scope of the agency of which was under consideration. The customer duly placed in the machine his shillings from time to time, and without negligence on his part the shillings were felon

iously abstracted.

It was held that the loss fell upon the gas company and that the customer was not bound to pay again.

Husband and Wife.]-The judgment in Morel Brothers v. Westmorland, 18 T. L. R. 599, noted 22 C. L. T. 263, as to the wife's authority to pledge the husband's credit, was reversed by the Court of Appeal, 19 T. L. R. 43, chiefly on the ground that the liability was a several liability of either husband or wife, and that having elected to sue the wife the plaintiffs could not also sue the husband.

Infant.]—The judgment of the Court of Appeal in Thurstan v. Nottingham Permanent Benefit Building Society, 18 T. L. R. 135, noted 22 C. L. T. 29, as to the liability of an infant on a mortgage, was affirmed by the House of Lords: 19 T. L. R. 54.

Insurance.]-The judgment in Stuart v. Freeman, 18 T. L. R. 511, noted 22 C. L. T. 210, as to the effect of payment of a premium for life insurance after the life had dropped, was reversed by the Court of Appeal: 19 T. L. R. 24. The Court of Appeal held that there was evidence to justify the finding that there was an implied right to thirty-one days of grace, and got over the difficulty of the death on the thirtyfirst day before the actual payment by the nice distinction that the payment in question was that of a quarterly instalment on a policy previously renewed for a year subject to payment of four quarterly instalments, and therefore not ipso facto terminated by the death.-In re Williams and Lancashire, etc., Ins. Co., 19 T. L. R. 82, is an important decision in these days of employers' liability insurance. A policy of that nature provided that the employers should give "immediate notice to the company of any accident causing injury to a workman," and time was to "be deemed to be the essence of this condition." The accident in question happened on the 10th of October, and the notice proved (an alleged informal oral notice not being given effect to) was the forwarding to the company on the 4th of December of the formal demand for compensation served by the workman on the employers on the 1st of December. It was held that the

condition had been broken and that the employers could not obtain from the company indemnity against the compensation awarded to the workman. Compare with this Shera v. Ocean Accident and Guarantee Corporation, 32 O. R. 411.

Landlord and Tenant.]-The question in Jones v. Livington, 19 T. L. R. 77, was whether by agreeing to "let " premises the lessor impliedly covenanted for quiet enjoyment. The Court of Appeal, applying Baynes v. Lloyd, [1895] 2 Q. B. 610, held that at all events there was no implied covenant as against a title paramount-which was the case in Judgment and evidently inclined to the view that there was no implied covenant even as to the lessor's acts. It was contended by the plaintiff that there had been by the lessor an oral warranty as to the permissible mode of user of the premises, eviction having taken place at the instance of the head landlord because of mis-user. This contention was held, however, not to have been made out, and in addition the Court pointed out that such a question could not be dealt with by collateral warranty, but was part of the subject matter of the contract.

Master and Servant.]-The judgment in the somewhat novel case of Lloyd v. Woodland Brothers, 18 T. L. R. 578, noted in some detail, 22 C. L. T. 264, was reversed by the Court of Appeal, 19 T. L. R. 32, that Court being of opinion that there was no evidence to justify the findings of the jury, especially the finding that the lift was defective because of the absence of an inner gate, based as it was entirely on a view of a plan of the lift in question. The importance of the pleadings and particulars in a case of this kind is indirectly emphasized, and there is a useful discussion of what must be made out to justify recovery.-Worthington Pumping Engine Co. v. Moore, 19 T. L. R. 84, is an interesting case as to the right of a servant to inventions made by him during the term of his employment in relation to the articles dealt in by the employers. Admitting the general principle that the mere existence of a contract of service does not per se disqualify a servant from taking out a patent for an invention made by him during his term of service, even though the invention may relate to subject matters germane to and useful for his