and when the salary is revised after the lapse of five years, the only thing that the justices are to regard is "the average number of inquests held by any such coroner in the five years immediately preceding," subject to "such appeal to the Home Secretary as before mentioned." Such a clause could not fail to give rise to all sorts of claims, and accordingly we learn by the report of a committee of justices in Derbyshire in 1861, that "each of the coroners claimed that, in addition to the average receipts for the five years preceding the 31st December, 1859, the salary should be increased by further allowances under all or some of the following heads, viz., 1. Increase of population; 2. Increase of information by the police; 3. Increase of collieries and ironworks, and consequently of accidents; 4. Adjourned inquests; 5. Additional fees in cases of murder and manslaughter; 6. Extent of districts; 7. Mileage: the railways not always affording the means of travelling to and from the place of holding inquests." The committee considered each of these claims, and decided against every one of them, and with reference to the increase of inquests, they observed that the attention of the court had frequently been called to the number of inquests alleged to have been unnecessarily held, and they give the following table, showing the gross number of inquests in each hundred, and the number of verdicts of "accidental death," and "visitation of God.”

From this table it appears that the gross number of inquests held in the five years was 1,583; that the number of accidental deaths was 783, that the number of deaths by the visitation of God was 589, and that the number from these two causes together was 1,372; which deducted from 1,583 leaves 211 deaths from other causes; and, as the total number of verdicts of murder and manslaughter in the five years are stated to have been only 36, this leaves only 175 deaths from causes that are not stated. No other conclusion can be fairly drawn from these figures than that a very large portion of the inquests were unnecessarily holden. In the well-considered judgment of the Court of Queen's Bench, in Reg. v. The Great Western

Railway Company,* Lord Denman, C. J., said, "If the verdict be death by the visitation of God, nothing more is done; for in truth it appears that there was no occasion for an inquest."| Primâ facie, therefore, at least, wherever the verdict is "death by the visitation of God," the inquest ought not to have been holden; and it lies upon the coroner very clearly to satisfy the sessions that there was "reasonable suspicion of murder or manslaughter;" "for there ought to be a reasonable suspicion that the party came to his death by violent or unnatural means."‡

+ See Rex v. Kent 11 East R., 299; and Reg. v. Gloucestershire, 7 E. & B. 805, where there were like verdicts; and the court held that the justices were warranted in refusing the costs of the inquest.

+ Reg. v. The Great Western R. Co., supra per Lord Denman, C. J. In his judgment the 2 & 3 Ed. VI., c. 24, s. 2 (which, where any person

It may, therefore, safely be concluded that at least 500 of the 589 inquests where a verdict of death by the visitation of God was returned ought not to have been held. Of course this remark applies to all verdicts which found the death to have arisen from natural causes, whatever were the terms of the verdict. In the cases of verdicts of accidental death, we are not warranted in inferring that so large a proportion was unnecessary; as undoubtedly juries very often return such a verdict, where the case is clearly one of manslaughter: but we cannot doubt that a third of these 783 inquests was unnecessary. If then we add this third-261-to the 500 from the 589 deaths by the visitation of God, we shall have 761 inquests to be deducted from the total of 1,583, which will leave 822; and the result is that nearly one-half the inquests were unnecessarily held.

Another remarkable feature in these inquests is the small proportion which the verdicts of murder and manslaughter bear to the number of inquests. The total of these verdicts was only 36, and the proportion they bear to the 1,583 inquests is 1 in every 44 inquests nearly. It is still more remarkable to notice how much this proportion varies in the different hundreds; in Morleston and Litchurch there were 12 in 483, or 1 in 40; in Repton and Gresley 1 in 192; in Appletree 1 in

is feloniously stricken or poisoned in one county, and dies in another, makes an inquisition of a coroner taken where the death happened valid), was much relied upon to show that the coroner's jurisdiction applied only to cases of felony, and it was observed that "the Act seems to assume the existence of the felony; for it makes good an indictment found for feloniously striking or poisoning, but is silent entirely as to what is to be done by coroner or jury if no such indictment be found;" and the court seem to have been very clear that at all events there must be some reasonable suspicion of manslaughter or murder to warrant the holding of an inquest. It is very remarkable that this case was not cited either in Reg. v. Gloucestershire, 7 E. & B. 805, or in Reg. v. Carmarthenshire, 10 Q. B., 796. It is equally remarkable that neither the court nor the counsel in Reg. v. The Great Western R. Co. were aware that the 2 & 3 Edw. VI. c. 24, had been wholly repealed by the 7 Geo. IV., c. 64, s. 32. It would seem, however, that the decision in that case would have been the same as it was, under sec. 12 of the latter statute; as that in terms only applies to any felony or misdemeanour begun in one county and completed in another.

78; in High Peak 2 in 303, or 1 in 151; and in Scarsdale 20 in 527, or 1 in 26. So that the average is the greatest in the hundred where the largest number of inquests were held. We cannot pretend to offer any solution for these discrepancies.

Five years having expired since the coroners' salaries were fixed, they again applied to the sessions for Derbyshire for an advance in their salaries, and the committee to whom the matter was referred, reported that, acting under the authority of Reg. v. Gloucestershire" We have very carefully examined the statement of the coroners, and the verdicts returned lead us to the conclusion that many of those inquests were held where there was no reasonable ground to suspect that the death was not a natural death,' and therefore, as decided by the Court of Queen's Bench, not properly held. Some of the instances we allude to are those of deaths, the causes of which are stated in the inquisitions to be ague, apoplexy, asthma, bronchitis, congestion of brain, congestion of lungs, consumption, decay of nature, diarrhœa, general debility, diphtheria, dropsy, excessive drinking, heart disease, low fever, natural causes, typhus fever, visitation of God." And in a letter from the committee, which was read at the last October Sessions, they state that the following are some of these cases.

“Mr. Bennett-Disease of the heart, 28; visitation of God, 4; natural causes, 56; decay of nature, 1; convulsions, 7; apoplexy 11; total, 107.

"Mr. Busby-Disease of the heart, 58; natural causes, 4; decay of nature, 3; convulsions, 34; apoplexy, 25; total, 124.

"Mr. Sale-Disease of the heart, 20; visitation of God, 48; natural causes, 11: decay of nature, 1; convulsions, 22: apoplexy, 7; total, 109.

"Mr. Whiston-Disease of the heart, 71; natural causes, 6; decay of nature, 15; nervous depression, 2; convulsions, 46; apoplexy, 17; total, 157."

And the committee say that

"All the coroners found their claims to an increase of salary upon

the number of inquests actually held during the last five years, and the greater number which they say may be expected to be held during the next five years. But that is not the question raised. The question really is whether all those inquests were necessarily and properly held. None of the coroners allege that they were. We submit that they were not, for the reasons assigned in the Report above referred to, and as is shown by the under-mentioned table, and that if unnecessary inquests were not paid for they would not be held, and that the salaries proposed by us will be a sufficient compensation for all inquests legally and necessarily held.

"Deducting only half of these inquests as unnecessary, the receipts of the coroners would have been much less than their salaries; and we are satisfied that the continuance of their present salaries will, as we desire, abundantly remunerate them for all inquests properly held."

We have now before us the table of the inquests referred to by the committee, which contains the number of inquests held by each coroner during the last five years, with the verdict in each case. The total number of inquests is 1,784; but one coroner made no return for one quarter, and if we add twenty-seven for that quarter, which will bring the number of inquests held by him for last year up to the number held in the previous year, we shall have 1,811 as the proper number for the five years. This number exceeds 1,583, the number for the previous five years, by 228; so that the number has increased oneseventh nearly in the last five years, an extraordinary increase in such a county as Derby; but whilst the number of inquests has increased, the number of verdicts of murder and manslaughter has decreased. In the former five years they were thirty-six; in the latter they are only twelve; so that in the latter period there is only one such verdict in 148 inquests, on an average. The verdicts, as given in the paper before us, are in many cases so uncertainly expressed, that it is very difficult to specify, with anything like the confidence we could wish, how many verdicts were really verdicts of natural, and how many of accidental deaths. Sundry verdicts are "suffocation,"