AMOS, MAJOR HARRY JOEL, Wisbech, potato merchant. Ct. King's Lynn.
Sept. 9.
ASHCROFT, JOHN, jun., Patricroft, farmer. Ct. Salford. Sept. 9.
BOYNS, RICHARD, late Ludgvan, fish hawker. Ct. Truro. Sept. 11
BRIGGS, JAMES, John-st, Bedford-row, solicitor. Ct. High Court.
BROOMFIELD, JOHN HENRY, Sunderland, boarding-house keeper.
Sunderland. Sept. 9.

Moss, JOHN HENRY (trading as J. and J. Moss), Ogmore Vale, builder.
Ct. Cardiff. Sept. 11.
WILLIAM
NUTTALL,
HENRY, Urmston, warehouseman. Ct. Salford.
Sept. 14.

PECK, BERTIE (late trading as B. Peck and Co.), late Upper-st, Islington,
shopfitter. Ct. High Court. Sept. 13.
PENDRY, SHADRACH, Windsor, livery stable keeper. Ct. Windsor

Sept. 11.

RIDAL, EDWIN JAMES, and PRESTON, SIDNEY, Sheffield, hay dealers. Ct.
Sheffield. Sept. 14.
SCHOENFELD, LOUIS NAPOLEON, Alexandra-ct, Maida Vale. Ct High Court.
Sept. 14.
STONE,
Ct.

THOMAS HENRY, Bexley Heath, commercial traveller.
Rochester. Sept. 13.

SWEETMAN, EDWARD, Ryde, hotel proprietor. Ct. Newport and Ryde
Sept. 13.

THOMAS, JOHN, Ebbw Vale, insurance agent. Ct. Tredegar. Sept. 14.
TRAVIS, JOSEPH SANKEY, Urmston, builder's clerk. Ct. Salford. Sept. 13.
WAINEWRIGHT, THOMAS SAMUEL, Leeds. Ct. Leeds. Sept. 11.
WATSON, S. G., Portslade, doctor of medicine. Ct. Brighton. Sept. 12.
WUITE, MARRAIANNE FANNY (trading as Thomas White), Ebley, plumber,
widow. Ct. Gloucester. Sept. 14.

WILLARD, GEORGE HENRY, Bradford, innkeeper. Ct. Bradford. Sept. 12.
WILLIAMS, THOMAS SAUNDERS, Llanwrtyd Wells, cattle dealer. Ct. New-
town. Sept. 14.
WOODWARD, WILLIAM, Maulden, market gardener. Ct. Bedford Sept. 14.

ADJUDICATIONS ANNULLED AND RECEIVING ORDERS

Sept. 9. Ct.

RESCINDED. GAZETTE, SEPT. 13. CLIFTON, JOSHUA, Saltoun-rd, Brixton, music hall artiste. Court. Sept. 9.

Ct. High

GAZETTE, SEPT. 17.

BULL, ARTHUR THOMAS, Leicester, credit draper. Ct. Leicester. Sept. 9.
Ct. High
BURMESTER, HUBERT LAWRENCE, late Houndsditch, clerk.
Court. Sept. 4.

Cox, ELI,, Wigan, hay dealer. Ct. Wigan. Sept. 7.
Sept. 9.
DUBBIN, HARRY, Watford, motor mechanic. Ct. St. Albans
ENGLISH, GEORGE FREDERICK, Lowestoft, draper. Ct. Great Yarmouth.
Sept. 10.

FESTOPSEY, ISAAC (commonly known as A. Milman), and FESTOPSEY,
MAURICE (trading and described in the receiving order as Milman
Brothers), Smith-st, Mile End, dairymen. Ct. High Court. Sept. 11.
GATLEY, JOHN RAWLING, Rhyl, gents' hosier. Ct. Bangor. Sept. 10.
HAAG, GEORGE, Chesterfield, pork butcher. Ct. Chesterfield. Sept. 10.
HEARLE, SAMUEL, jun., Probus, farmer. Ct. Truro. Sept. 11.
HEBBLETH WAITE, GEORGE ARTHUR, Kingston-upon-Hull, chemist.
Kingston-upon-Hull. Sept. 9.
Ct. Great Grimsby.

HOE, EDWARD, Great Grimsby, house painter.

Sept. 9.

Ct.

HURRELL, GEORGE, Great Yarmouth, upholsterer. Ct. Great Yarmouth. Sept. 9.

KAUFMAN, ELIZABETH, Middlesbrough, boot dealer. Ct. Middlesbrough. Sept. 11.

KIRBY, W. R., Forest Hill, captain in the South African Constabulary. Ct. Greenwich. Sept. 10.

LEWIS, DANIEL, Penygraig, miner. Ct. Pontypridd, Ystradyfodwg, and Porth. Sept. 9.

LEWIS, MARY ANNE, Barry, grocer, widow. Ct. Cardiff. Sept. 10.

LLEWELYN, BENJAMIN, Ystalyfera, newsagent. Ct. Neath and Aberavon.
Sept. 10.

MARTIN, ALBERT EDWARD (trading as the Midland Electrical Supply
Ct. Birmingham.
Company), Birmingham, electrical engineer.
Sept. 11.

MILLER, FRANK WILLIAMS, Devonshire-sq, manufacturer. Ct. High Court.
Sept. 10.

MILLINGTON, FREDERICK, Cargo Fleet, engineman. Ct. Middlesbrough. Sept. 9.

Ct. Cardiff. Sept. 10. Ross, JOHN WELLESLEY, Craven-st, Strand, publisher. Ct High Court. Sept. 10.

PERKINS, ERNEST ALBERT, Bridgend, greengrocer.

SALTER, ALFRED JOHN, Tonypandy, carpenter. Ct. Pontypridd, Ystradyfodwg, and Porth, Sept. 10.

SANDERS, SYDNEY, and SANDERS, JOSEPH WALTER (trading as S. and W. Sanders), Luton, builders. Ct. Luton. Sept. 11.

SCARBOROUGH, PERCY CHARLES, Potters Bar, ironmonger.

Sept. 10.

Ct. Barnet.

SIMPSON, WILLIAM FOREMAN, and SIMPSON, FREDERIC, Newmarket St. Mary, builders. Ct. Cambridge. Sept. 10.

SMITH, CHARLES BLYTHE, Willes-rd, Kentish Town.

Sept. 7.

Ct. High Court.

TRUSWELL, ERNEST (trading as H. Trus well and Co), Manchester, boot dealer. Ct. Salford. Sept. 10.

WADSWORTH, CHARLES (trading as Holt and Co.), Manchester, grey cloth agent. Ct. Manchester. Sept. 10.

GAZETTE, SEPT. 17.

BARNES, JAMES, Birkenhead, boot dealer. Ct. Birkenhead. Sept. 12
WALTER WILLIAM, and GRIGGS, HARRY JOHN (trading as
CHALFONT,
Ct. High
Walter W. Chalfont), Union-st, Marylebone, printers.
Court. Sept. 14.

COOK, ARTHUR G., Haywards Heath, coal merchant.

Ct. Brighton.

Sept. 12. COOPER, RUTH, Dewsbury, dressmaker. Ct. Dewsbury. Sept. 14. Ct CORDERY, Newport, Mon. EDWARD HENRY, Newport, draper.

Sept. 13. CORNTHWAITE, EDWARD, Rochdale, plumber. Ct. Rochdale. Sept. 13. fruiterer. Ct. DAFT, Cheltenham, Cheltenham. ERNEST CHARLES, Sept. 13. DELAHUNTY, PHILIP JOHN, Norwich, general shopkeeper. Ct. Norwich. Sept. 14.

EVANS, JOHN (late trading as Evans Brothers), Bedwas, late builder Ct. Newport, Mon. Sept. 13.

FITT, GEORGE, Lowestoft, gentleman. Ct. Great Yarmouth. Sept. 14. FUDGE, FRANCIS ELLIS (late trading as Fudge and Co.), late Blackwood, fruiterer. Ct. Tredegar. Sept. 11.

FUNNELL, AMOs, Great Grimsby, late fish merchant. Ct. Great Grimsby. Sept. 14.

GRAY, WILLIAM HENRY GEORGE, Bath-st, Poplar, late railway station master. Ct. High Court. Sept. 12.

GREENWOOD, JAMES, Keighley, fine art dealer. Ct. Bradford. Sept. 12.
Ct. Wigan. Sept. 13.
HADDOCK, WILLIAM, Wigan, milk dealer.
Ct. Tredegar. Sept. 12.
HIGGS, ALBERT NICHOLAS, Aberbargoed, grocer.
HENDERSON, LEONARD JAMES, late Carlton-mansions, Maida Vale, sales-

party-" Consignees to effect discharge of cargo steamer paying 1s. per ton COMMERCIAL

CONTENTS

REPORTS.

KING'S BENCH DIVISION.

JUDICIAL COMMITTEE OF THE EAST LONDON RAILWAY JOINT COM

MITTEE (apps.) v.

GREENWICH UNION ASSESSMENT COMMITTEE

(resps.).-Rating

-Railway-Link line-Annual loss in working......... 126

99

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Vol. 133.-No. 3626.

101

CABLE COMPANY V.
ATTORNEY GENERAL FOR NEW.
FOUNDLAND.-Law of Newfound-
land-Telegraph cables
CORRINTHE AND OTHERS . SEMINARY
OF ST. SULPICE, MONTREAL.-Law
of Canada-Seigniory-Rights of
Indians-Stat. 3 & 4 Vict. c. 30
SAMSON V. AITCHISON.-Negligence-
Liability-Cardriven by permission
of owner-Principal and agent-
Control
SUPREME COURT OF JUDICATURE.
COURT OF APPEAL.

Re SALMEN; SALMEN . BERNSTEIN.-
Will - Bequest of business
Direction to executors and trustees
to carry on the same
DENTAL MANUFACTURING COMPANY
LIMITED V. DE TREY AND Co.
Passing-off-Exclusive agent for
sale of another's manufactured
goods

HIGH COURT OF JUSTICE. CHANCERY DIVISION. PENNINGTON . CAYLEY.-Mortgage Foreclosure Opening foreclosure-Adding parties-Order of revivor-Application under Order XVII., r. 4 VIOLA . ANGLO AMERICAN COLD STORAGE COMPANY LIMITED. Company-Action to set aside sale by mortgagee of company-Debenture-holders' action-Receiver STAIT v. FENNER; MACNAB, Third Party- Landlord and tenant Lease-Proviso enabling lessee by notice to determine - Notice by equitable assignee invalid FENNER V. MACNAB.-Vendor and purchaser-Contract-Vendor not bound to get in legal estate-Conveyance as beneficial owner

104

106

The Law and the Lawyers.

Law Society Meeting.

MR. C. L. SAMSON in his presidential address delivered this week at Cardiff divided his observations into two portions. First, he dealt with several points contained in the annual report of the council, and with his comments on the recent legislation promoted by the society and on land transfer and on the notorious Land Registry circular we entirely agree. We are also glad to note that there is to be an appeal against the decision of the Court of Appeal in Scott v. Scott on the question of contempt of court, for we have already expressed our opinion as to the correctness of this decision.

The Position of the Profession.

IT is the second portion of Mr. SAMSON's address that will doubtless give rise to much general discussion and criticism. In that he considered the position of the Profession, the prospect of the Profession, and whether anything can be done to improve that position and prospect. With a great deal that he said we agree, but it is a matter for much regret that he should have gone out of his way to make a quite unwarranted attack upon the other branch of the Profession. Recriminations of this kind do little good, and to attribute the increase of the cost of litigation merely to court fees, counsel's fees, and fees of expert witnesses is not in accordance with fact. We do not for one moment deny that the fees of eminent counsel have increased, but so have the fees paid to the leading men in every profession. It is all a question of supply and demand, and where it is desired to retain the best talent available, whether barrister, solicitor, surgeon, or engineer, the services rendered by such men are worth what they will fetch, and competition to obtain those services naturally raises their monetary value.

Cost of Litigation.

DELAY and uncertainty have done much to increase the cost of litigation. Owing to the lack of judicial strength, causes are subjected to interminable delays, and, as we have often pointed out in these columns, cases after being in the paper for some days, with the witnesses and parties in attendance, have to be postponed to some future date owing to the services of the judge being required in some other place. Mr. SAMSON is quite right that the proposal to appoint only one additional judge for the King's Bench Division is simply playing with the matter, for the experience of recent years has conclusively shown that two additional judges are absolutely necessary. Modern business methods have also added considerably to the cost of litigation, as the amount of documentary evidence forthcoming in nearly every case, owing to the typewriter and the shorthand writer, has increased expenses in all directions.

Some Suggested Amendments.

SEVERAL other matters upon which the president dwelt well merit the attention of those in authority, and as to these some distinct change in the law and practice is eminently necessary. The first of these is the "ridiculous disparity" between taxed costs and solicitor and cleint costs, for in litigation-apart from costs incurred through over-caution and extravagance-there ought to be a practical indemnity. Again, the present system of bills is, as Mr. SAMSON truly describes it, a relic of barbarism," while complete freedom of action to contract. as to charges in both contentious as well as in noncontentious matters ought to be permitted between solicitors and their clients so long as, again to quote the president, "the parties are sui juris, of competent understanding, when there is no fraud or duress, and when ample opportunity of revising a bargain is referred to the court."

Women and the Legal Profession.

It is not surprising that the proposals of Mr. EDWARD A. BELL, contained in his paper on the admission of women into the Legal Profession, were considered somewhat premature by some of the speakers at the meeting, and that a motion in favour of the previous question was carried. Whether or not in the future women will be admitted to the practice of the law in this country, time alone will show, but, apart from those earnest persons who consider that in all cases and in all circumstances to use the words of the Interpretation Act "words importing the masculine gender shall include females," there are many and serious objections to "the removal of the existing archaic and unjust restraint upon the admission of qualified and competent women into the ranks of the Legal Profession," as Mr. BELL describes the present position.

The Long Vacation.

WE are sorry that the president ruled out of order the motion of Mr. MAGGS with reference to the Long Vacation, presumably upon the ground that the subject had not been referred to in his address. It seems a great pity that a matter of such importance should not have been fully discussed. There is little doubt that the general public and a large body of professional opinion is strongly in favour of a curtailment of the summer vacation, and, as we pointed out nearly two years ago, in matters of this kind the interest of the public

paramount. Of course the legal machinery must have some considerable and consecutive period of vacation, but, as we have already stated, two months' recess is amply sufficient for rest and recuperation. The present

Nothing is more curious than the fact that sections of Acts of Parliament of great interest to lawyers are at times all but forgotten by the Legal Profession. When some years ago the fact that the undermanning of the judiciary had become pre judicial to the public interest, a section in the Appellate Jurisdiction Act 1876 providing for the appointment of additional judges was brought to the notice of the Government by Mr. Cave, K.C., and its discovery was a revelation to many persons learned in the law, not only at the Bar, but on the Bench. A correspondent in a lay paper calls attention to the existence of what he terms a long-forgotten section (sect. 75) of the Judicature Act 1873. This section provides that “a council of the judges of the Supreme Court, of which due notice shall be given to all the said judges, shall assemble once at least in every year on such day or days as shall be fixed by the Lord Chancellor . for the purpose of . . . inquiring and examining into any defects which may appear to exist in the . . . administration of the law in the High Court," and directs that the council "shall report annually to one of Her Majesty's Principal Secretaries of State which, if any, amendments or alterations it would in their judgment be expedient to make in this Act or otherwise relating to the administration of justice." Some five years ago, according to the correspondent, it was elicited in the House of Commons that successive Lord Chancellors had disregarded these provisions, and that a council of judges had only reported on three occasions since the passing of

the Act.

FRAUD BY AN AGENT.

THE rule for deciding whether a principal is liable for the fraud of his agent is laid down clearly in the text-books. For instance, Bowstead on Agency states that every principal is civilly liable for every fraud committed by his agent in the ordinary course of his employment, and for the benefit of his principal, though he did not authorise it, and even if he had expressly forbidden it. There are plenty of authorities for that proposition, but they apparently have their origin in the interpretation of the decision in Barwick v. English Joint Stock Bank (16 L. T. Rep. 461; L. Rep. 2 Ex. 259). There the plaintiff had been in the habit of supplying a customer of the defendants with oats on credit, upon the defendants' guarantee. He demanded a better guarantee, and the defendants' manager thereupon gave him a written guarantee that the customer's cheque to the plaintiff should be paid in priority to any other payment "except to the bank." The customer was in fact indebted to the bank to the extent of £12,000, but this fact was not known by the plaintiff. The latter then supplied the customer with oats to the value of £1227 for carrying out a Government contract, and a cheque for £2676 was sent to the customer by the Government in payment of this and other consignments. This cheque was paid by the customer into his account, but the customer's cheque in favour of the plaintiff was dishonoured by the defendants, who claimed to retain the whole sum in payment of their debt.

The plaintiff brought an action against the bank for false representation. Baron Martin ruled that there was no evidence to go to the jury in support of the plaintiff's case, and directed a non-suit. The plaintiff appealed, and, in directing a new trial, Mr. Justice Willes said: "The general rule is that the master is answerable for every such wrong of the servant or agent as is committed in the course of the service and for the master's benefit, though no express command or privity of the master be proved." He goes on to cite instances, as where owners of ships have been held liable in trespass for the acts of masters abroad

66

improperly selling the cargo; then he says: In all these cases it may be said, as it was said here, that the master has not authorised the act. It is true he has not authorised the particular act, but he has put the agent in his place to do that class of acts, and he must be answerable for the manner in which the agent has conducted himself in doing the business which it was the act of his master to place him in."

The words are not very clear, but they have always been interpreted to mean that if an agent committed a fraudulent act for his own private ends, even though it belonged to a class of acts which he was authorised to do in his master's service, his master would not be liable. Thus in British Mutual Banking Company v. Charnwood Forest Railway Company (57 L. T. Rep. 833; 18 Q. B. Div. 714) the secretary of a company answered certain questions which were put to him as to the validity of certain debenture stock of the company. The answers were untrue, and were fraudulently made by the secretary for his own benefit, the fact being that the secretary had fraudulently issued the debentures in question in excess of the amount which the company was authorised to issue. The plaintiffs in consequence of these answers lent money upon the stock and found afterwards that it was valueless. They then sued the company for the fraud of their secretary.

The company had reaped no benefit from that fraud, and the Court of Appeal (Lord Esher, M.R. and Lords Justices Bowen and Fry), reversing the decision of the Queen's Bench Division, held that the company was not liable.

case.

Lord Justice Bowen in his judgment refers with approval to the rule laid down by Mr. Justice Willes in Barwick v. English Joint Stock Bank (ubi sup.) and distinguishes that "In that case," he says, the act done, though not expressly authorised, was done for the master's benefit. With respect to acts of that description, it was doubtless correct to say that the agent was placed there to do acts of 'that class.' Transferred to a case like the present, the expression that the secretary was placed in his office to do acts of that class,' begs the very question at issue, for the defendant's proposition is, on the contrary, that an act done not for the employer's benefit, but for the servant's own private ends, is not an act of the class which the secretary either was or could possibly be authorised to do."

A somewhat similar case was Ruben v. Great Fingall Consolidated (95 L. T. Rep. 214; (1906) A. C. 439). There the secretary of the company had borrowed money upon the security of a share certificate which he had fraudulently issued to the plaintiffs, having affixed the company's seal without authority and forged the signatures of the two directors. The company refused to register the plaintiffs as owners of the shares, and the plaintiffs claimed damages. It was held that the secretary had no authority to do anything more than the ministerial act of delivering the share certificates, when duly made, to the owners, and that the company were not responsible for his wrongful act outside the scope of his authority. Lord Davey, in his judgment in that case in the House of Lords, says that where a secretary is acting fraudulently for his own illegal purposes, no representation by him relating to the matter will bind his employers. He adds: "The reason for the qualification is that a representation made under such circumstances, whether express or implied, is also part of the same fraud, and cannot rightly be considered to be made by the servant as agent or on behalf of his master."

This aspect of the law of principal and agent was recently reviewed by the House of Lords in Lloyd v. Grace, Smith, and Co., reported in the Court of Appeal, 104 L. T. Rep. 789; (1911) 2 K. B. 489. The facts were as follows: Mrs. Lloyd, who owned two freehold cottages and a mortgage for £450, was dissatisfied with the income which she received from her property. Accordingly she called on the respondent firm and had an interview with their conveyancing clerk, Sandles, who conducted that branch of the business without supervision. Acting on his advice, she brought the deeds relating to the property with her next day and then signed two documents which he put before her. One was a transfer of the mortgage and the other an absolute conveyance of the cottages to Sandles himself. She did not read them, but signed without demur, and Sandles gave her a receipt for the deeds in his own name and afterwards, at her Second Sheet.

་

request, in the name of the firm. Sandles then called in the mortgage and misappropriated the proceeds, and mortgaged the cottages to secure a private debt of his own. Mrs. Lloyd sought to recover against the firm in the King's Bench Division; the jury found that Sandles professed to act as conveyancing manager for the firm, and added that in their opinion the plaintiff believed that she was dealing with the firm. Mr. Justice Scrutton upon these findings gave judgment for the plaintiff. The defendants appealed, and, upon the authority of Barwick v. English Joint Stock Bank (ubi sup.), the Court of Appeal (Lords Justices Farwell and Kennedy) reversed the decision in the court below Lord, Justice Vaughan Williams being of opinion there should be a new trial on the question of estoppel. Mrs. Lloyd then appealed to the House of Lords, and her appeal was allowed by the House (Earl Loreburn, the Earl of Halsbury, Lord Macnaghten, Lord Atkinson, and Lord Shaw of Dunfermline). That court expressed their opinion that the language of Mr. Justice Willes in Barwick v. English Joint Stock Bank had been misunderstood, and that that case was not an authority for the proposition that a master was not liable for the wrong of his servant or agent committed in the course of his service, if it were not committed for the master's benefit. They stated the true principle to be that a principal is liable for the act of his agent in the course of his employment, whether he is acting for the benefit of his principal or not. In this they dissented from the dicta of Lord Bowen in British Mutual Banking Company v. Charnwood Forest Railway Company (ubi sup.) and of Lord Davey in Ruben v. Great Fingall Consolidated (ubi sup.).

This decision of the House of Lords affirms the view taken by Mr. Justice Quain of the decision in Barwick v. London Joint Stock Bank (ubi sup.) in Swift v. Winterbotham (28 L. T. Rep. 339; L. Rep. 8 Q. B. 244)—that is to say, provided only that the agent's fraud is committed in carrying out one of the "class of acts" which his principal employs him to do, the principal is liable; and the fact that the principal reaps no benefit from the agent's fraud has no effect on that liability.

THE PARLIAMENTARY RECORD.

ON reassembling for the continuation of its legislative programme, Parliament will find itself confronted with a task of immense difficulty unless it is content to jettison some of its weightier burdens.

The list of Acts which thus far have, amid the special preoccupations of Parliament, reached the statute-book is not a long one, and we will now deal with them in their capitular order. Cap. 1 is entitled the Consolidated Fund (No. 1) Act. It is a formal measure applying certain sums to the service of the year, but it involved some rather animated debate, for the rules of the House enabled the discussion to travel along somewhat devious paths. Consequently there was debate not only on financial transactions, but also by way of protest against the decision of the Attorney-General to institute proceedings against the parties responsible for the " open letter" in the Syndicalist and the arrest of Mr. Tom Mann. After these questions had been disposed of, the Bill passed through its stages with no further difficulty.

The Coal Mines (Minimum Wage) Act forms cap. 2. The history of the industrial upheaval which brought this measure into existence is one, of course, within the memory of all. It was introduced by the Government with reluctance, and only because in their opinion all hope of an agreed settlement had passed away. The Act makes it an implied term of every contract for the employment of a workman underground in a coal mine that the employer is to pay him wages at not less than the minimum rate settled under the Act and applicable to that workman. This is subject, however, to a certificate that the workman is a person excluded under the district rules from the operation of this provision, and subject, moreover, to the workman not having forfeited his right to the minimum wages by reason of his failure to comply with the conditions with respect to the regularity or efficiency of the work to be performed by workmen laid down by those rules. Any agreement for the payment of wages in so far as it contravenes these provisions is void. "District rules mean rules made by a joint district board under the Act. These rules lay down conditions in regard to their appropriate districts as to the exclusion from the right to wages at the minimum rate so far as concerns aged workmen and infirm workmen, amongst whom are included men partially disabled by illness or accident.