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battle, which had nothing to do with chivalry or knightly weapons, and the later chivalrous duel. We trust, indeed, that an admiral who talks of using six-inch guns against torpedo boats has no living counterpart in the service; but that is outside the faculty of law. The general tendency of the book is what the French call 'pacifiste.' We admire the intention, but cannot accept all the reasons. From a literary point of view we should have preferred the dialogues not to be introduced by the fiction of a posthumous publication, which is now too common to deceive the most innocent reader.

The General Principles of the Law of Corporations (being the Yorke Prize Essay for the year 1902). By C. T. CARR. Cambridge: at the University Press. 1905. xiv and 211 pp.-This little volume, the Yorke Prize Essay for 1902-only slightly altered, as the author states in his preface, for publication-is a creditable production, though without any claim to originality. The subject of the true nature of the corporation, and the rights and liabilities of unincorporate bodies of persons endowed with a greater or less degree of organization, is one which is attracting a good deal of attention at the present moment, and will probably attract a good deal more in the near future. Mr. Carr's book contains a useful summary of the principles of English law relating to Corporations, and references to authorities which should also prove useful. Something has been done in the way of illustration from American writers. If, however, the author desires to go beyond merely English home authorities, he can still find ample fields for research within the British Empire, and might usefully pursue the subject of corporations, statutory and otherwise, in their development in Canada, Australia and South Africa.

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Der Nachweis von Schriftfälschungen, Blut, Sperma u. s. w. . . mit einem Anhange über Brandstiftungen. Von Prof. Dr. M. DERNSTEDT and Dr. F. VOIGTLÄNDER. Braunschweig: F. Vieweg u. Sohn. 1906. 8vo. 248 pp. (M. 9.)-A monograph for experts and criminal investigators on the modern processes of what may be called forensic laboratory work: detection of forgeries by magnified photographs revealing, with or without chemical aid, erasures or differences between original and superposed ink; identification of human or other blood by spectroscopy, and so forth. Many illustrations of micro-photography are given. There is an appendix on the methods of incendiarism. A really skilful case of arson is, it appears, not easily traced. Fire-raisers are happily for the most part not less clumsy than other criminals. The book may be recommended to specialists who are well enough versed in technical German to make use of it.

Principles of the Law of Partnership. By ARTHUR UNDERHILL. Second Edition. London: Butterworth & Co. 1906. 8vo. XX, 154 and 22 (index) pp. (58. net.)—There does not appear to be any material change in this edition, except that the form of lectures has been dropped. Perhaps the recent and not unimportant decision in Garner v. Murray [1904] 1 Ch. 57 might have been more fully explained with advantage.

The Elements of Criminal Law and Procedure, for the use of Students. By A. M. WILSHERE. London: Sweet & Maxwell, Lim. 1906. 8vo. XX and 259 pp. (78. 6d.)—This book affects to set out in about 250 pp. the whole body of both the substantive and adjective criminal law, and so aims at an impossibility. The enormous scope of the book renders inexactness in detail almost an inherent necessity; but this does not excuse such grave

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misstatements of law as we find at p. 176, where it is said that in the 'statement' of an indictment, any of the following when they are of the essence of the offence must be correctly set out. Time, as in . . . bigamy, murder, and all offences in which the indictment must be preferred within a certain time.' We cannot honestly recommend a work containing mistakes of which this is only a sample.

Inequalities of English Law as applied to Men and Women respectively. By A. W. COLSTON KNEE. Penzance: F. Rodda. 1906. 12 pp.-The writer advocates female suffrage, and ultimately the admission of women to Parliament, as the only certain remedies for the inequalities mentioned. We should like to know his authority for the statement (which we have seen before) that women had equal political rights with men before the reign of Elizabeth.

The Law of Torts. By J. F. CLERK and W. H. B. LINDSELL. Fourth Edition by WYATT PAINE. London: Sweet & Maxwell, Lim, xcviii and 880 pp. (308.)-Review will follow.

A Treatise on the Law relating to Ownership and Incumbrance of registered Land. By JAMES EDWARD HOGG. London: Wm. Clowes & Sons, Lim. 1906. 8vo. xix and 474 pp. (208. net.)-Review will follow.

The Rule against Perpetuities. By JOHN CHIPMAN GRAY. Second Edition. Boston, Mass.: Little, Brown & Co. 1906. La. 8vo. xlvii and 664 pp.-Review will follow.

A Treatise on the Law of Evidence. By His Honour the late Judge PITT TAYLOR. Tenth Edition by W. E. HUME-WILLIAMS. Two Vols. London Sweet & Maxwell, Lim. 1906. La. 8vo. ccxlii, 1351 and 228 (index) pp. (£3 38.)-Review will follow.

The Customs Laws. By NATHANIEL J. HIGHMORE. Published for H.M. Stationery Office by Stevens & Sons, Lim. 1906. 8vo. xxxvi and 383 pp. (68.)

Stone's Justices' Manual; being the Justices' Yearly Practice for 1906. Thirty-eighth Edition. By J. R. ROBERTS. London: Shaw & Sons. ; Butterworth & Co. 1906. 8vo. cxliii and 1309 pp. (258.)

The Law and Practice relating to Letters Patent for Inventions. By THOMAS TERRELL, K.C. Fourth Edition by COURTNEY TERRELL. London: Sweet & Maxwell, Lim. 1906. La. 8vo. xxxviii and 689 pp. (308.)

Trial of Dr. Pritchard. Edited by WILLIAM ROUGHEAD. Sweet & Maxwell, Lim. 1906. 8vo. 343 pp. (58. net.)


The Revised Reports. Edited by Sir F. POLLOCK, assisted by 0. A. SAUNDERS, J. G. PEASE and A. B. CANE. Vol. LXXX. 1847-1850 (16 Simons; 14 Queen's Bench; 4 Exchequer; 2 Carrington & Kirwan; 17 Law Journal). London Sweet & Maxwell, Lim.; Boston, Mass.: Little, Brown & Co. 1906. La. 8vo. xv and 888 pp. (258.)

The Victorian Chancellors. By J. B. ATLAY. Two Vols. Lyndhurst; Lord Brougham; Lord Cottenham; Lord Truro. London: Smith, Elder & Co. 1906. 8vo. x and 466 pp.

Vol. I. Lord With portraits. (148. net.)

English and Roman-Dutch Law. Second Edition. By GEORGE T. MORICE. Grahamstown, Cape Colony: The African Book Company, Lim.; London: Butterworth & Co. 1905. 8vo. xxxi and 410 pp. (278. 6d.) Magistrates' Courts in the Transvaal. By Grahamstown, Cape Colony: The African Book Company, Lim. 1905. 8vo. xlvi and 393 pp. (218.)

The Civil Practice of the HARRY OSBORNE BUCKLE.

A Treatise on the Law of Sale of Personal Property. By JUDAH PHILIP BENJAMIN, Q.C. Fifth Edition. By WALTER CHARLES ALAN KER and ARTHUR REGINALD BUTTERWORTH. London: Sweet & Maxwell, Lim.

1906. La. 8vo. clv and 1160 pp. (£2 28.)-Review will follow.

A Treatise on Deeds. By ROBERT F. NORTON, K.C., assisted by R. H. DUNN and DIGBY L. F. KOE. London: Sweet & Maxwell, Lim. 1906. La. 8vo. lxx and 694 pp. (308.)-Review will follow.

La Colpa nel Diritto Civile Odierno. By G. P. CHIRONI. 2a edizione interamente rifatta. Vol. II. Colpa Extra-Contrattuale. Torino: Fratelli Bocca. 1906. La. 8vo. 748 pp. (l. 15.)

The Practice at Parliamentary Elections and the Law relating thereto. By D. WARD. Third Edition. By S. G. LUSHINGTON, assisted by F. J. COLTMAN. London: Butterworth & Co.; Shaw & Sons. 1906. 8vo. XXXV, 344 and 51 pp. (98.)

The Law of Corporate Executors and Trustees. By ERNEST KING ALLEN. London: Stevens & Sons, Lim. 1906. 8vo. xv and 93 pp.


The A. B. C. of Parliamentary Procedure: a handbook for use in public debate. By Wm. Marshall FREEMAN and J. CARSON ABBOTT. Butterworth & Co. 1906. 8vo. 127 pp. (28. 6d. net.)

The Law of Heavy and Light Mechanical Traction on Highways. By C. A. MONTAGUE BARLOw and W. JOYNSON HICKS. London: Sir Isaac Pitman & Sons, Lim. 1906. 8vo. xv and 302 pp. (88. 6d. net.)

Roman Private Law. By R. W. LEAGE. London: Macmillan & Co., Lim. 1906. 8vo. xiii and 429 pp. (108. net.)

The London Building Acts, 1894 to 1905. By E. ARAKIE COHEN. London: Stevens & Sons, Lim. 1906. La. 8vo. lxiii and 444 PP. (258.)

The Editor cannot undertake the return or safe custody of MSS. sent to him without previous communication.

His address is 13 Old Square, Lincoln's Inn, not Oxford.

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No. LXXXVII. July, 1906.



HE profound respect rightly entertained by all English lawyers for the Supreme Court of the United States makes it impossible to read the full report of Haddock v. Haddock [1906] 26 Sup. Ct. Reporter, 525, with any other feeling than that of sheer amazement. That case decides that, to cite the headnote,' the mere domicil within the State [namely Connecticut] of one party to the marriage [in the particular instance the husband] does not give the Courts of that State jurisdiction to render a decree of divorce enforceable in all other States [e. g. in New York] by virtue of the full faith and credit clause of the Federal Constitution [Art. IV, s. 1, cl. 1] against a nonresident who did not appear, and who was only constructively served with notice of the pendency of the action.' And this principle, which is strange enough in itself, is in the judgment delivered by the majority of the Court combined with another principle even more startling, namely, that a divorce may be valid in Connecticut, where it is given, whilst it is invalid in New York, though not necessarily in all other States of the Union. Hence seem to follow some curious conclusions. Thus H is a bachelor in Connecticut, but he may be a married man in New York; W, his wife, on the other hand, is a married woman at New York, but an unmarried woman in Connecticut; in Massachusetts again, the parts may be once more interchanged. Whether under these circumstances H is in any part of America, say in the district of Columbia, guilty of bigamy, if, as a citizen of Connecticut, he holds he has the privileges of a bachelor, and at Paris marries, during the lifetime of W, Y а Frenchwoman, we do not pretend to conjecture. What is the proper and legal behaviour of H who, according to the majority of the Supreme Court, occupies the ambiguous position of a husband who is not a husband, we must leave to be decided by the wisdom or . the originality of Mr. Justice White and the colleagues whose views he represents. This inquiry, be it noted, is one which may any day

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come before an English Court. It is impossible to examine with anything like thorough care the effect or bearing of a case whereof the full report has only just reached us. Many of the points raised, such for instance as the proper interpretation of the 'full faith and credit clause,' perplex even American lawyers and assuredly cannot be solved by any one except an American lawyer intimately acquainted with the constitutional law of the United States. It may, however, be allowable for an Englishman who has devoted some attention to the problems raised by the conflict of laws, to hazard several observations suggested by the first reading of Haddock v. Haddock.

1. The judgment of the Supreme Court carries great weight simply because it is the judgment of that high tribunal, but the force of argument, though not of numbers, seems to lie with the minority of judges, whose views are carefully elaborated by Mr. Justice Brown, and expressed with brilliant pungency by Mr. Justice Holmes.

2. The very idea of a divorce, which in the eyes of the Supreme Court itself is valid in Connecticut and invalid in New York, is so novel and so startling that it needs to be supported by the very strongest arguments, but a conclusion which can only with great difficulty find acceptance is unfortunately based in part upon the utterly untenable premiss that a judgment of divorce is analogous to a judgment in personam and not, as every jurist holds, to a judgment in rem.

3. It is one of the many astounding results of this amazing judgment that under the 'full faith and credit' clause, a Connecticut judgment apparently receives and ought to receive in the State of New York less respect than the same judgment would receive in England. The point is one of great importance, which ought to be worked out when the time comes for a fuller consideration of Haddock v. Haddock.

4. The majority of the Supreme Court were, we may suspect, influenced by two considerations which cannot affect an English tribunal. The one is the difficulty, which appears under the Constitution of the United States to be a real one, of reconciling the 'full faith and credit clause,' which must have been intended to make judgments pronounced in any one State effective throughout the whole of the Union, with the legislative authority almost (or, as some American publicists hold, quite) amounting to sovereignty which under the Federal Constitution was left for each State. The other is the natural indisposition to allow any one State to relax, in reality though not in name, the terms of divorce throughout the whole Union; it may well be thought undesirable that the divorce

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