as follows: "subject to such laws requiring and regulating the registration of electors as the General Assembly may enact"_

1. Citizenship of the United States at least one month.

2. Residence in the State one year immediately preceding the election, or having been previously a qualified elector or native born citizen of the State and having removed therefrom and returned wtihin six months.

3. Residence in the election district two months immediately preceding the election.

4. Payment of a State or county tax if twenty-two years of age and upwards, which shall have been assessed at least two months and paid at least one month before election.

All women, therefore, possessing these constitutional qualifications are eligible to vote. All of these requirements may be inherently possessed by a woman, except assessment, registration and the payment of a tax.

The question then arises, can women, under the law as it now stands, be assessed, pay a tax and register where registration is required.

The Acts of Assembly on the subject of assessment, liability to taxation and registration, beginning with the Act of April 15, 1834, P. L. 509, point out a method by which all citizens of the Commonwealth can be assessed, pay taxes and register. No one who is a citizen, and, of course, women are just as much citizens as men, can be denied the right to be assessed, to pay taxes, to be enrolled or to be registered in accordance with the law. Indeed, the Constitution provides that all laws on the subject of elections "shall be uniform throughout the State," and it will now be incumbent upon county commissioners, assessors and registration officers to meet the condition which has arisen out of the enfranchisement of women, and to afford every facility to them to qualify themselves as electors.

It is urged that the women themselves shall be diligent to see that they are assessed in due time and form. They should not be content to assume that this will be done, but everywhere make inquiry to see that it actually has been done. The situation is a novel and unprecedented one in our Commonwealth, and without their vigilant and

intelligent co-operation it may happen that many assessors, however faithful or anxious to do their full duty, will overlook some names.

It being obvious from a reading of these Acts that women can be assessed and have the right to pay a county tax, and it being the duty of county commissioners and the assessors throughout the State to see that they are enrolled and assessed and do pay a tax, and this enrollment and tax payment, when otherwise qualified, in boroughs and townships entitling them to vote and to register in cities, I am of the opinion that under existing laws the right to vote at the general election in November is vested in all the women of the State who possess the necessary constitutional qualifications, and who pay a county tax and are enrolled and register.

IN RE SOLDIERS.

Disabled Soldiers-Vocational Education-Rehabilitation Act -Employment-Injury-Compensation.

Disabled soldiers and sailors, placed in industrial plants, under the Rehabilitation Act by the Federal Board for Vocational Education, and thereafter injured in such plants, come under the provisions of the Pennsylvania Compensation Law.

Before the Workmen's Compensation Board. In re Rehabilitation of Disabled Soldiers and Sailors.

OPINION

Mackey, Chairman, June 21, 1920.

Under the Rehabilitation Act the Federal Board for Vocational Education deals with disabled soldiers and sailors who are vocationally handicapped and whom they seek to educate and train in some profession, trade or business by which they may return to some specific gainful occupation in civil life.

These men are given either:

(1) Institutional Training in some college, school or institution of learning. The United States Government pays for the tuition, books and gives $80.00 per month to the man while in training.

(2) Placement Training, (job training) in some trade, industry, business or profession, the Government furnishing the necessary books and tools, and gives $80.00 per month to the man while in training.

This second phase of training involves:

(a) Job Training, with no wages paid by the proprietor or management.

(b) Job Training, with a nominal or beginner's wage paid by the proprietor or management voluntarily.

The question that has been presented to the Board is as to the status of the men so placed in industrial plants in respect to the Pennsylvania Compensation Law, in case an accident should happen.

Section 104 of the Pennsylvania Workmen's Compensation Act of 1915, as Amended June 26, 1919, provides:

"The term 'employe' as used in this act is declared to be synonymous with servant, and includes all natural persons who perform services for another for a valuable consideration, etc."

The important words in this definition are "valuable consideration." In some states, as for instance New Jersey, a "financial consideration" is the test of the employment for the purpose of compensation.

As we view such a case, the owner of a plant in which such injured soldier or sailor is placed for the purpose of rehabilitation, is moved to accept from the Federal Board such men because of the fact that these men are learning a trade in the plant, and while they are so learning, will be producing and the employer will receive the benefit of their efforts in this respect, and this valuable result to the owner of the establishment will increase from day to day as the workmen, thus assigned, increases his efficiency. In other words, the Federal Board takes the ward, the injured soldier or sailor, secures a place in a shop or a mill or a factory where the owner of such establishment receives the benefit of the soldier's or sailor's work, for which he need not pay anything of money value, for the consideration going out from him to the injured man, is the opportunity to acquire a trade.

Therefore, should a man in this relationship to the Federal Board and to the owner, be injured, we would

have a case where a man was injured upon the owner's premises, by the operation of the owner's business, while the one injured was there giving the owner the benefit of his work, and therefore, the valuable consideration takes the place of the wage, and such a man must be considered as an employe while thus occupied. The employer certainly has full control of him. He can assign him to any particular work. He can direct the hours during which he works, or he can expel him from his establishment and not allow him to return. He gets the full value of his services, therefore should be responsible for compensation should he be injured while thus at work.

HAHN v. BRUSH BROS.

Workmen's Compensation-Final Receipt-Setting AsideModification.

When a claimant for workmen's compensation was unaware of the nature of the final receipt he signed, had no intention of signing away his rights, and merely believed that he was signing the ordinary receipt for compensation, it will be set aside on the ground of mistake. Compensation agreement modefied to provide for the loss of claimant's leg.

Workmen's Compensation Board. Petition by Claimant for Review of C. A. No. 688452, Dated October 28, 1918.

Insurance Carrier: U. S. Fidelity & Guaranty Co., 321 Walnut St., Philadelphia.

Claimant represented by E. C. Ammerman, Esq., Geo. Morrow, Esq., Scranton, Pa.

Defendant represented by G. W. Bradford, Jr., Adjuster, U. S. Fidelity & Guaranty Co., 321 Walnut St., Philadelphia.

OPINION.

Mackey, Chairman, June 21, 1920:

This is a petition of the claimant to set aside a final receipt, restore a compensation agreement and to modify the said agreement to provide for the loss of a leg.

Under the contradicted evidence in the case, we find that the allegation in the petition has been substantiated that when the petitioner signed a paper, which now appears as a final receipt, he was unaware of the nature of the same, had no intention of signing away his rights, and merely believed that he was signing the ordinary receipt for compensation. There was no justification for the presentation of any other receipt, and there was no suggestion made by the insurance carrier at the time this paper was signed, that it ought to bind the claimant as a final receipt, nor did the condition of the claimant warrant the intimation that a final receipt was in order.

We therefore set aside the final receipt on the ground of mistake on the part of the claimant at the time he signed the paper.

It will be noticed that under the original Act of 1915, there was no mention of the words "final receipt." Such a paper becomes the final adjudication of a case when the minds of the parties have met, and there was a clear intention to finally liquidate the employer's obligation, but such intention of both parties must have been based upon the assured fact that the injured man's condition warranted the conclusion of the payments of compensation. Therefore, if this paper called a final receipt is received, it was merely as an acknowledgment of money paid on account of compensation, and will not affect the obligation of the employer to continue the compensation under the agreement, if the facts of the case warrant further compensation.

We find from the evidence that the claimant suffered the loss of his leg by amputation in the Binghamton City Hospital on August 23, 1919, and from the uncontradicted testimony of three medical witnesses, we find that the infection, which eventually caused the amputation of the leg as the necessary means of saving the claimant's life, was the natural development of the injury he received at the time of the accident provided for at the time by the compensation agreement.

It is therefore ordered that the compensation agreement be modified to provide for the loss of the claimant's leg, credit to be given the insurance carrier for the money already paid as compensation.