tion of persons and property within its own jurisdiction, unless restrained by some provision in the charter, or unless what is done amounts to a regulation of foreign or interstate commerce. N. & W. R. R. Co. v. Pendleton, 86 Va. 1004.

The rights conferred by corporate charters, or by municipal contracts, as respects the mode of their exercise, are subject to control under the police powers of the State, or of municipal corporations. R. F. & P. R. R. Co. v. Richmond, 26 Gratt. 83; Davenport v. Richmond, 81 Va. 636; Roanoke Gas Co. v. Roanoke, 88 Va. 810; Charlottesville v. So. Ry. Co., 97 Va. 428 ; Roller v. Harrisonburg, Id. 582; Washington &c. Ry. Co. v. Alexandria, 2 Va. Sup. Ct. Rep. 309.

The obligation of contracts is not impaired by an act scaling debts payable in Confederate money to their gold value, and depriving the creditor of all legal remedy for a greater amount, including the remedy by sale under a deed of trust, Pharis v. Dice, 21 Gratt. 303; Compton v. Major, 30 Gratt. 180; or by an act requiring an officer selling personal property to satisfy a debt contracted before April 10, 1865, to sell on a credit of twelve months at the request of the debtor, Garland v. Brown, 23 Gratt. 173; or by a law authorizing a creditor to compromise with and release any debtor bound jointly with others, without impairing his rights against the other joint contractors or co-obligors, or the right of the joint contractors or co-obligors to contribution among themselves, Yuille's Adm'r v. Wimbish's Adm'r, 77 Va. 308; or by laws changing the remedy, or the forms of actions, or modes of proceeding, or the rules of evidence, if an adequate and efficacious remedy is provided, Garland v. Brown, 23 Gratt. 173; Poindexter v. Greenhow, 84 Va. 441; Commonwealth v. Weller, 82 Va. 721; McGahey v. Commonwealth, 85 Va. 519.

The obligation of contracts is impaired by a law authorizing the courts and juries in suits on contracts made prior to April 10, 1865, to remit interest accrued during the war, and empowering the courts to open and review final judgments on such contracts, and reduce the amount of principal or interest due thereon, Roberts v. Cocke, 28 Gratt. 207; Cecil v. Deyerle, Id. 775; Kent v. Kent, Id. 840; Pretlow v. Bailey, 29 Gratt. 212; Rat

cliffe v. Anderson, 31 Gratt. 105; Marpole v. Cather, 78 Va. 239; Marshall v. Cheatham, 88 Va. 31; or by a law authorizing debts to be paid at a place different from that agreed on, to an agent not appointed by the creditor, and in a depreciated currency not in circulation at the agreed place of payment, Bank of Old Dominion v. McVeigh, 20 Gratt. 457; or by an act authorizing a majority of a religious congregation, in the event of a division, to transfer the church property contrary to the terms of the trust under which it is held, Finley v. Brent, 87 Va. 103; or by a law allowing exemptions which were not allowed when the contract was made. Homestead Exemption Cases, 22 Gratt. 266.

The Coupon Cases. In a notable series of cases it was held that the Funding Act of March 30, 1871, created an inviolable contract between the State and its creditors who accepted bonds issued under that act, and that the contract, as to the interest coupons attached to the bonds, was self-executing, said coupons being by the terms of the act receivable for all taxes, debts and demands due the State. Antoni v. Wright, 22 Gratt. 833, in which the act of March 7, 1872, requiring all taxes and demands due the State to be paid in money, was declared void; Clarke v. Tyler, 30 Gratt. 147; Williamson v. Massey, 33 Gratt. 237. All these cases were decided by three judges, Moncure, P., not sitting, and Staples, J., dissenting, and in the first two cases filing strong dissenting opinions. The coupons being thus held to be beyond the reach of direct legislation, a painful struggle followed between the State and its creditors, in the course of which act after act was passed for the purpose of securing adequate revenues to the State by making it difficult and expensive to use coupons in the payment of taxes, &c., and these acts, as often as they came before the Court of Appeals, were declared to be constitutional. Commonwealth v. Maury, 82 Va. 883; Commonwealth v. Larkin, 84 Va. 517; Commonwealth v. Plunkett, Id. 519; Commonwealth v. Krise, Id. 521; in which a law requiring a special license tax of $1,000 on the privilege of selling coupons, and imposing a tax of twenty per cent. on the face value of the coupons when sold, was sustained; Poindexter v. Greenhow, 84 Va. 441, in

which it was held competent for the legislature to take away from coupon holders their remedy by mandamus; and Commonwealth v. Weller, 82 Va. 721, and McGahey v. Commonwealth, 85 Va. 519, in which a law making expert testimony inadmissible to prove the genuineness of coupons was held valid. In Maury v. Commonwealth, 92 Va. 310, such legislation was upheld on the broad ground that the privilege of suing the State is not an absolute right, but is allowed as a matter of grace; and may be extended or withheld, or when extended may be recalled, at the pleasure of the State, unless rights have vested during its existence which the State is forbidden by the State or Federal Constitution to defeat or impair. In this case the repeal of the act authorizing a judicial inquiry into the genuineness of coupons was held to be constitutional. Finally, the Funding Act itself, the source of so much litigation, was declared to be invalid, first partially so in Greenhow v. Vashon, 81 Va. 336, and then wholly so in Commonwealth v. McCullough, 90 Va. 597, on the ground that it was in conflict with sections 7 and 8 of Article VIII. of the State Constitution.

Corporate Charters.-These charters, as above shown, constitute contracts, the obligation of which cannot be impaired; and where the legislature, in grånting such a charter, reserves the right to repeal or amend it, it may repeal it but it cannot amend or modify its terms without the consent of the incorporators. Yeaton v. Bank of Old Dominion, 21 Gratt. 593.

It is one of the omissions of the present Constitution that it contains no provision prohibiting the grant of a charter which may not be amended or repealed. "As the power to grant unamendable and irrepealable charters is one readily susceptible of being greatly abused, to the prejudice of important public interests, and has been greatly abused in the past, the people in a majority of the States, in framing or amending their constitutions, have prudently guarded against it by reserving the right to alter, amend, or repeal all laws that may be passed, conferring corporate powers. These provisions give protection from the time of their adoption, but the improvident grants theretofore made are beyond

their reach. In many States the constitutions also prohibit special charters, and all corporations are formed by the voluntary association of individuals under general laws." Cooley's Const. Lim., p. 335.

Retroactive Laws.-The passage of retroactive laws is not forbidden, and statutes which validate contracts, otherwise invalid, are sustained where they go no further than to bind a party by a contract which he has attempted to enter into, but which was invalid by reason of some personal inability on his part to make it, or through neglect of some legal formality, or in consequence of some ingredient in the contract forbidden by law. The legislature may declare valid contracts which were usurious at the time they were entered into, and may remove a disability to contract which it had previously imposed. Danville v. Pace, 25 Gratt. 1; Smoot v. Building Association, 95 Va. 686; and Bosang v. Building Association, 96 Va. 119.

Taking Private Property.—An individual may be authorized by the legislature to build a toll bridge, and incidentally to condemn land for that purpose. Plecker v. Rhodes, 30 Gratt. 798. Where a statute authorizes the condemnation of a fee simple estate, a less estate cannot be taken. Roanoke v. Burkowitz, 80 Va. 616. The construction of a telegraph line along a public road, in which the public owns only a right of way, imposes an additional servitude, and cannot be authorized without providing for just compensation to the owner of the fee simple. W. U. Telegraph Co. v. Williams, 86 Va. 696. But raising the grade of a street so as to give an approach to an overhead bridge, though it may impair the use of the street for some purposes, does not impose an additional servitude, and is not a taking of private property. Home Building Co. v. Roanoke, 91 Va. 52.

Taxation is a taking of property which must be done by due process of law. Violett v. Alexandria, 92 Va. 561, and Heth v. Radford, 96 Va. 272.

Freedom of the Press.-" A tax imposed on the business of publishing a newspaper is not an abridgment of the freedom of the press. The guaranties of the Constitution and Bill of Rights in

favor of the freedom of the press, freedom of speech and personal liberty were never intended to restrict the right of taxation for the support of the government. If these guaranties did restrict the power of taxation, the government would soon be insolvent and powerless to furnish the protection claimed." Harrison, J., Norfolk v. Norfolk Landmark Co., 95 Va. 564.

This decision was rendered January 27, 1898, and on the 26th of February following the newspapers secured themselves against the tax thereby declared valid by an act of legislature depriving the local authorities of the right to impose such a tax. In securing this exemption, on the ground that its freedom was invaded, the press not only gave proof of its power to protect itself, but furnished at the same time a good illustration of how a great principle may be turned to a thrifty use.

Religious Belief.—No person is incapacitated from being a witness on account of religious belief, or the absence of it. Perry v. Commonwealth, 3 Gratt. 632.

SEC. 15. No law shall embrace more than one object, which shall be expressed in its title; nor shall any law be revived or amended with reference to its title, but the act revived or the section amended shall be re-enacted and published at length.

Same as Article IV., sec. 16, Constitutions 1851 and 1864.

This section makes the title a necessary part of every act, and the conclusive index of the intent of the legislature in passing it. Its purpose is to prevent fraud and surprise in legislation by means of provisions in bills, which are not indicated in the titles. But it is not intended to obstruct honest legislation by preventing the incorporation into a single act of the entire statutory law on any general subject; and the title is not required to be a complete index of the contents of a bill. It is sufficient if the subjects not specified, however numerous and diverse they may be, have congruity or natural connection with the subject stated in the title, or are cognate or germane thereto, and may fairly be regarded as in furtherance of the object expressed in the title. When they are not of this character, and the act is broader than its title, the act is void, unless that part of it indicated in the title is complete in itself and capable of being executed, in which case it will be en