the estate in question was sold in lots at different times, and different lots were subject to different restrictions, and some were not subject to any, and the judgment is valuable as dealing with a mode of sale that is now by no means uncommon, a large property offered in what may be called tracts of different classes of eligibility but all forming part of a general harmonious scheme.

9

Assuming that the right to enforce restrictive covenauts orginally exists, that right may, under some circumstances, be lost. In the case of The Duke of Bedford v. The Trustees of the British Museum, the purchaser of certain land entered into a covenant not to use the land in certain specified ways, the object being to prevent interference with certain adjoining land retained by the vendor. Afterwards the vendor used the adjoining lands in such a way as to make the restriction of no value, and it was held that the covenant could not be enforced in equity. The vendor was left to whatever rights Le might have at law. So in Roper v. Williams,8 it is stated that where a laudlord relaxes in favour of some tenauts a covenant entered into for the benefit of all, be is not afterwards entitled to restrain other tenants from infringing the covenants; and in Eastwood v. Lever, acquiescence in a previous breach of a building restriction was held to be fatal to the right to enforce it, though the covenants in question were expressly stated to be for the benefit of all persons taking under conveyances from the covenantee. Peek v. Matthews, 10 is a case frequently referred to in this connection. There the vendor took from each of several purchasers of plots of building land a covenant to build only in a certain manner, but afterwards permitted material breaches of the covenant to be committed by some of the purchasers. It was held that he could not afterwards enforce the covenant as against other purchasers, and that it was immaterial whether the covenant had been entered into with the vendor alone or by each purchaser with all the other purchasers; or whether the breaches acquiesced in had or bad not been committed before the purchase by the particular defendant who happened to be attacked. If however the previous breaches are unimportant, there is no objection to afterwards enforcing the observance of the covenants,12 Nor if the previous breach acquiesced in is one that did not really affect the person who complains of the subsequent one, for example, if it is something affecting a part of the estate at a distance from that part owned by the person complaining, 13

So, too, the person complaining may himself have committed slight breaches of the building restrictions and yet be entitled to restrain important breaches by any co-purchaser. Thus in Chitty v. Bray,14 there were restrictions as to the frontage and rear lines of buildings to be erected. The plaintiff had slightly deviated from the frontage line covenanted to be observed, and had deviated very substantially from the rear line covenanted to be observed. It was held however that these deviations might be looked upon as divisible, and that the plaintiff was entitled to restrain the defendant from a threatened substantial deviation from the froutage line.

15

In Sayers v. Collyer, a building estate was sold in lots, each purchaser eutering into a restrictive covenant with the vendor, and with the owners of the other lots entitled to the benefit of the covenant, for the purpose of preserving the property as residential property. There were numerous infractions of this covenant, and it was beld that a purchaser who sought to restrain a certain infraction of the covenant that had gone on to his knowledge for three years could not succeed, the Court being of opinion that the character of the property had so

changed that the purpose of the covenant failed and could not be enforced. On appeal,16 it was held that a change in the character of the property is not a reason for depriving the plaintiff of his right of enforcing the covenant, unless the plaintiff himself has done acts causing or tending to cause that change, but that the plaintiff must fail on the ground of acquiescence in the particular breach complained of.

So, too, it may happen that owing to peculiar relations between the parties, the one cannot enforce a restrictive covenant as against the other. In King v. Dickeson,17 a purchaser of a lot, subject to restrictive covenants entered into with the vendor and the purchasers of other lots, mortgaged part of it, the mortgagee taking with notice of the restrictions, but not being expressly bound to observe them. After foreclosure the defendants por chased with notice of the covenants but it was held that they could not be compelled at the suit of the maker of the mortgage to observe them. An obligation to observe the covenauts could not be implied between mortgagor and mortgagee.

It may be observed in conclusion that before a litigious purchaser, after satisfying himself that there is a restrictive covenant binding his co-purchasers that he is entitled to enforce, proceeds to enjoy the luxury of compelling some supposed delinquent to observe that covenaut, he should be very careful to see that the covenant is in fact broken. If not he may find himself in the unpleasant position of the plaintiff in Worsley v. Swann, 18 who was told that a person who has covenanted not to use land for certain purposes will not be restrained from erecting a building seemingly adapted only for such purposes.-Canadian Law Times.

QUASHING ORDERS OF CORPORATE BODIES:

As all corporations have some charter or statute defining more or less vaguely the limits within which they may act, and as it is common experience that those limits are often transgressed, there are certain legal consequences incident to the latter situation. A certiorari to bring up the order or resolution involving the illegal exercise of power for the judgment of the High Court is a usual remedy, and after the main point is settled by that process as to whether the corporation has or has not acted beyond its powers, then, if the decision is that the corporation has acted ultra vires there is another supplemental inquiry as to who is to pay the costs. Both these points are of great interest and importance to the members of the local body whose acts have been impugned.

The doctrine of ultra vires is about as wide and vague as the variety of circumstances under which corporations and local bodies act, and a volume would be required in order to collect the decisions of the High Court as to the particular occasions when the alleged illegal acts have been questioned and adjudicated upon one way or the other. It may be useful to refer only to one recent example which comes home to most of our readers, namely, how far overseers of the poor may be said to have the power of spending the poor rates in opposing some supposed burden about to be imposed on the ratepayers. In the case of R. v. White, 14 Q. B. D. 358, a parish near Bristol was about to be affected by a scheme in Parliament promoted by a dock company. The details of the scheme need not be stated, but the effect produced, if the bill should be passed by Parlia ment, would be to increase the poor rate considerably, in certain contingencies. The overseers being of this opinion took counsel with the vestry and were authorised by that body to oppose the bill in Parliament, Everyone knows that this course involves considerable expenditure, and the overseers incurred an expense of £327, but they were successful in getting the bill thrown out by a committee of the House of Lords. Then arose the question, how was this large bill of costs to be paid?

(16) 28 Ch. D. 103. (17) 40 Ch. D. 596. (18) 51 L. J. Ch. 576.

The overseers thought that as they acted gratuitously, and in general defence of the ratepayers, the costs incurred should come out of the poor rates. But as may be supposed, ratepayers are moved by divers interests, and it happened that one indignant ratepayer insisted that the overseers must not dip their hands into the public purse, but must find the money elsewhere. The poor law auditor thought it so meritorious a case that he allowed the sum out of the poor rate. The Court of Queen's Bench Division was then applied to for a certiorari, and it was contended that the overseers had gone beyond their powers; that they had no business to incur any such expense; that they were ministerial agents; that the poor rate was not a fund in which they had a right of property; that they had no power and no duty either to increase or diminish the percentage that must fall upon the ratepayers by a decree of Parliament, aud therefore, that the allowance out of the poor rate must be quashed. The Queen's Bench Division agreed with the view that the overseers had overstepped their duty, but, ou appeal, the Court of Appeal thought the overseers and the auditor were quite right. That court held that the expenditure that may be incurred rightly by overseers was not confined to defraying the expense of poor law litigations and the maintenance of paupers, but that it was also their duty, over and above those particular claims, to see that no improper or illegal burden was put on the rates. The court said that they are to defend the rates for the benefit of the parish. As Brett, M.R., said: "Here the attempt was to throw a burden upon the rates in favour of persons who were promoting a private bill in parliament. The principle might not apply to a public bill, which has to be considered by the legislature as for the benefit of the whole country; but this was not a public, it was only a private bill. It is true they may not have power to originate litigation. But here what the overseers did was pure matter of defence against a project by private persons by which the rates might have been burdened. They acted reasonably and incurred no immoderate expense. Therefore the overseers were justified in incurring the expense." And as Lindley, L.J., put it: "This was a scheme promoted by private individuals for the purpose of profit to themselves, and they sought to burden the rates of the parish for their own individual benefit. The vestry having authorised the overseers to oppose the bill, the expense was properly paid out of the poor rate."

This last case showing the ground on which public bodies may act in novel situations, we may now look at the other side and assume that the public body has acted illegally and beyond their powers, and then trace the consequences in the final reckoning as to the costs. In the case of R. v. Dunn, 5 Q. B. 959, considerable litigation arose as to costs after a successful certiorari against the corporation of Lichfield. Some persons had assaulted the mayor while in the execution of his duty, and were indicted at the assizes and acquitted. At a meeting of the town council resolutions were adopted to pay out of the borough fund £165, the amount of the bill of costs incurred for the prosecution. Some councillors dissented on the ground that the proposed payment was illegal. It appeared that the opinion of the town council had not been taken before the prosecution was instituted. A certiorari having been moved for, the resolution of the town council was quashed. Lord Denman, C.J., said that it might be proper that a corporation should incur expense to protect its officers in the performance of any necessary duty, but the council of the borough should previously authorise the expenditure. Afterwards, a rule was obtained for the costs of defending the illegal expenditure. Then several parties sought to be made liable complained that they had never taken any part in the illegal resolution; others, like the town clerk and the treasurer, said that they merely acted officially, and were not responsible. And it appeared that at the time of making the order absolute for a certiorari, no names of the persons liable to pay costs were specified. A number of persons, however, being proceeded against for costs, an attachment was sought against them for

not paying these costs. In the end the Court decided that the wrong course had been followed. The right course was said to be, that where the persons doing the illegal acts are not expressly defined, the Court should be asked to decide what persons should pay the costs. It was not proper that the individual succeeding in quashing the orders should be able to call on whom he pleased as liable for the costs. Hence, the Court would not assist the successful party in seeking to compel by attachment a number of persons whom he thought liable for the costs.

In the recent case arising at Ramsgate, the subject of costs incurred in like circumstances has been disposed of after considerable litigation. The litigation has been reported at three stages, and each stage contains important lessons to all municipal corporations and local boards, the Public Health Act in this instance supplying the statutory provisions involved. The first stage was that of Whiteley v. Barley, 21 Q. B. D. 154. An action had been brought to recover penalties under the Public Health Act, 1875, s. 193, against the defendant, who was the town surveyor of Ramsgate, the corporation of which town were the local authority. The surveyor's appointment was made in 1880, and his duties bad been duly defined. The corporation afterwards were engaged in making certain improvements, and in order to do the work they directed the surveyor to take out quantities of the work to be done, upon which the contractors were to tender. It was admitted that this was extra work not within the scope of his employment. But in each instauce the contractors were to pay 21 per cent. on the contract price to the surveyor. There was no contract between the surveyor and corporation that they should pay him for the extra work, and no contract between him and each contractor; but the corporation and contractors so agreed. The question raised afterwards was, whether the surveyor became thereby interested in each contract, for if so, then he would be liable to the penalty sued for. judge at the trial held that a penalty was incurred; and the Court of Appeal agreed in that judgment. Lord Esher, M.R., said that as the surveyor was to be paid by a percentage on the contract price, the larger that percentage was, the larger would be his remuneration, and hence that it would be to his interest that he should make the quantities as large as they could be made. But the Court took care to say that the point involved was a mere question of law and that there was no reflection on the honour or integrity of the surveyor. The Court regretted indeed to come to the decision they did, namely, that the surveyor was immediately interested in the contract and so liable to the statutory penalty.

The

The next stage of the litigation was R. v. Mayor of Ramsgate, 23 Q. B. D. 66, when a rule for a certiorari was obtained to quash certain resolutions and orders of the corporation. It appeared that in pursuance of the former arrangement the corporation had paid to their surveyor £300 out of the borough fund to account of his commission on the contracts. Moreover after the result of the action for penalties, the corporation ordered a further sum of £300, to be paid to their surveyor for his costs in defending that action. It was contended on the one hand that both these orders were illegal aud ultra vires, aud ought to be quashed. It was contended, on the other hand, on the part of the corporation, that as the money had been bond file paid by the corporation for services rendered, and such sam was nothing more than a fair and just sum to be paid for the benefits received, the High Court would not interfere merely because it was technically forbidden by the Public Health Act. But the court held that however fair and reasonable might be the payment for the surveyor's services, still it was more than a mere harmless irregularity, because it was expressly prohibited by the Act. The court therefore had no other course than to make the rule absolute to quash the orders of the corporation.

The third and last stage of this litigation is to be found in R. v. Vaile, reported in another column and in 23 Q.

B. D. 483. A rule was obtained calling on certain members of the corporation of Ramsgate to pay the costs of the certiorari last mentioned. It was urged in defence that the members now sought to be made liable were not parties to the rule for a certiorari, and ought not to be made liable for costs. But the Queen's Bench Division held that the persons liable were those persons who initiated the proceedings, who made the orders afterwards declared to be illegal, and who defended them with money taken out of the borough fund. Accordingly the order was made absolute against those members and those only who actually took part in making the illegal orders. -Justice of the Peace.

NOTES OF ENGLISH CASES. [From the Law Journal.]

HIGH COURT OF JUSTICE.

CHANCERY DIVISION,

(Before STIRLING, J.)

BAIRD V. WELLS.

Feb. 28, March 1, 7.-Club-Proprietary club-Expulsion of member by resolution of committee-Election of committee-Rules-Irregularity-Jurisdiction of Court to interfere-No property in member.

The Pelican Club was a proprietary club, of which the plaintiff was a member, The club, as such, had no property, the house and furniture belonging to the defendant Wells, by whom all subscriptions and entrance fees were taken.

The committee of the club was first nominated by the proprietor, who asked certain members to act upon it. They afterwards added to their numbers, and their election was confirmed at a general meeting, which, however, the Court held had not been properly convened in accordance with the rules of the club. Rule 17 provided that any member whose conduct in or out of the club should be unbecoming a gentleman in the opinion of the committee, or with respect to whom any matter might have transpired which might be calculated to reuder his continued membership of the club injurious to its character or interests, should, if the committee on inquiry found the same to be substantiated, be requested to resign; and, in case of his non-compliance, he should be subject to expulsion.

Charges of misconduct having been made against the plaintiff the committee prosecuted an inquiry, and, in the first instance, having examined the plaintiff, came to the decision that there was not such a case against him as to call for the application of rule 17. This was reported to a general meeting of the club, at which a resolution was passed to refer the matter back to the committee. The committee thereupon resigned, but at an adjourned general meeting were re-elected en bloc. They then reopened the inquiry, in the course of which (as the Court held) fresh evidence was before them; and, without giving the plaintiff an opportunity of being heard, they decided to put rule 17 into force.

The plaintiff then brought this action, and applied for an injuuction against the defendaut Wells and the secretary of the olub, to restrain them from interfering with his use and enjoyment of the club as a member thereof.

It was argued for the defendants that the Court had no jurisdiction to interfere in such a case, inasmuch as the members of the club had no property in the club, and it was upon the ground of property alone that the jurisdiction in such cases was founded,

Sir Charles Russell, Q.C., Sir Horace Davey, Q.C., and de Witt for the plaintiff.

Graham Hastings, Q.C., and Levett for the defendants. STIRLING, J., after holding that the election and proceedings of the committee were irregular, and not binding on the plaintiff, said that the question arose whether the case was one in which the Court would grant relief by injunction. In all cases in which an in

junction had hitberto been granted the club had been possessed of property vested in trustees upon trust to permit the members for the time being to use and enjoy the olub-house and effects. But the interest of the members was not confined to that merely personal right. They might, if all agreed, put an end to the club and divide the assets between them. In the present case the club had no property; the house and furniture belonged to the defendant Wells, and by him the subscriptions were taken. The principle laid down in Forbes v. Eden, 2 Sc. App. 581, and Rigby v. Connoll, 49 Law J. Rep. Chanc. 328; L. R. 14 Chanc. Div. 487, was that, except for the disposal and administration of property, there was no authority in the Courts to take cognisance of the rules of a voluntary society entered into merely for the regulation of its own affairs. In this case the plaintiff had no right of property in the club for the protection of which the Court would interfere. Each member was entitled by contract with Wells to use or enjoy the club (in common with others) so long as he paid his subscription and was not excluded under rule 17. That was a personal right the infringement of which might give rise to a claim for damages. It was contended that damages were an insufficient remedy where the character of the plaintiff was affected; but there was no case in which the existence of such cir cumstances had been held to afford ground for the granting of an injunction to restrain the proceedings of a voluntary society. There would be no order on the motion,

ATTESTING WITNESSES OF BILLS OF SALE,

It speaks well for the courage of solicitors that notwithstanding the cases in which, again and again, bills of sale have been invalidated, they should still undertake the preparation of these bewildering docu. ments. The case of Parsons v. Brand (noted this week)→ to say nothing of Coulson v. Dickson-recently discussed before the Court of Appeal, furuishes yet another illustration of the pitfalls into which the bill of sale holder may fall. The attesting witnesses had simply subscribed their names, neither of them having added either his address, his description, or occupation, although the affidavit filed with the copy bill of sale at the time of registration contained all these particulars. In these circumstances could it be said that the bill of sale complied with the requirements of the Act, namely, that the document should be duly attested, and in accordance with the "form" in the schedule to the Act? A divisional court, consisting of Lord Justice Fry and Justice Mathew, held, upon appeal from the Woolwich County Court, that the bill of sale did not so comply, and therefore was void. In thus deciding the Court followed a previous decision (iu Blankenstein v. Robertson, noted ante, p. 255) to the same effect by another divisional court, and this ruling has now been sustained by the Court of Appeal. To one at least of the Lords Justices the necessity of invalidating the bill of sale was extremely distasteful. Lord Justice Lindley, in a case decided long ago under these Acts, referred to a point which governed the case as "a miserable technicality"a phrase adopted by Mr. Justice Mathew only a few weeks ago in another bill of sale case. On this last occasion the learned Lord Justice frankly said he was sorry he did not see his way to arrive at any other conclusion. "It was always a painful thing," his Lordship remarked, "to hold that bona fide transactions were void because some t's were not crossed and some i's not dotted." With this view the public, and we should imagine the majority of the Legal Profession, will fully concur.-Law Times.

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pages, cloth gilt, containing the names of 70,000 persons advertised for to claim property and money since 1700. Price 1s. 6d. post free. Every man and woman in the world should buy this book, as instructions are given how to recover property from Chancery free of all charges or fees. DOUGAL & Co., 62 Strand, London. A fortune 44 Wills searched. may await you.

AMERICAN JUSTICE.

To the English reader there is something delightfully refreshing about the American administration of justice. The courts have none of that solemnity and dignity which render legal proceedings in Great Britain so impressive. Thus, for instance, the other week at Wilkesbarre, an important town of Pennsylvania, with a popu lation of 30,000, the principal judge of the district became so indignant upon hearing the testimony as to the cruel treatment to which the prisoner at the bar had subjected his wife, that he found himself unable to wait for justice to take its slow course. Bouncing from the bench he locked the door of the court-room, tore off his coat, and then and there polished off the prisoner in the most approved style, while the specators present rent the air with approving cheers. He then reascended the bench and proceeded to discharge the prisoner, on the ground that it is unconstitutional that a man shall be punished twice for the same offence. Far from rendering himself liable in damages or to reproaches on the part of the public by this extraordinary method of legal procedure, the judge in question is today the most popular man in Wilkesbare, and is pointed out by his admiring fellow-citizens as a man who lives up to his highest sense of duty, and who, by his energetic action, has conferred a public benefit. California judge achieved notoriety a fortnight ago by getting druuk, and afterwards fining himself £10 for the offence. This is, in truth, a sample of high old Roman virtue. The stern magistrate, moreover, has publicly promised in court to resign if his thirst should ever again crowd his judicial dignity off the bench. Meanwhile, his struggle not to be hauled up again before himself is being watched with anxiety by the California philanthropists. Even in New York there is much amusement and instruction to be derived from the administration of justice. One night Judge Ford, who is one of the principal police magistrates in the city, found a burglar in his house. As there was no policeman within hail, Judge Ford, who is an extremely powerful man, arrested his nocturnal visitor, took him off to the station, and entered a complaint. He then got on the bench and remanded his prisoner for three days, after which he quietly returned home, set his house in order, and then went to bed.-Pall Mall Gazette.

INTERPRETATAION OF STATUTES.

A

In Coxhead v. Mullis, 47 Law J. Rep. C. P. 761, Lord Coleridge said that the tendency of his mind in dealing with statutes is "to suppose that Parliament meant what Parliament has clearly said, and not to limit plain words in an Act of Parliament by considerations of policy, if it be policy, as to which minds may differ and decisions may vary." "With the canon of construction thus enunciated few will be disposed to find fault. It well expresses the qualification which modern authorities have placed on the almost legislative freedom of interpretation formerly claimed by the Courts (see Stradling v. Morgan, Plowd. 204, 205; Heydon's Case, 3 Rep. 7b). But the difficulty, as usual, lies in the application. Unfortunately, opinions may and do differ, and decisions vary not only as to considerations of policy, but also as to the degree of clearness of language used by the Legislature. Coxhead v. Mullis itself furnishes an illustration in point. section 2 of the Infants' Relief Act, 1874, stood alone, the words "any promise or contract" would necessarily bear the wide meaning attributed to them in that case; but does not the context require that they should be limited to contracts and promises which are within section 1 and the earlier part of section 2? Mr. Justice Lopes hesitated to agree, though ultimately he did agree in the decision given; Mr. Justice Denman has intimated his dissent from it in Ditcham v. Worral, 49 Law J. Rep. C. P. 688; and now Mr. Justice Kekewick, in a recent judgment, Duncan v. Dixon, has binted his doubts of its correctness. In the last case the learned

If

judge seems to have been invited to enlarge the scope of section 1, so as to make it commensurate with section 2, as interpreted in Coxhead v. Mullis; but he naturally declined thus to put the cart before the horse. The question of the construction of section 2 was not directly raised, bat some words in the judgment appear to indicate that it may be raised at a later stage of the action. Its further discussion will be awaited with interest.-Law Journal.

THE INCORPORATED LAW SOCIETY OF

IRELAND.

A general meeting of the Council of this Society was held on 26th, the President, Mr. W. Burroughs Stanley, in the chair, and 18 other members present. A letter from the Registrar of Deeds, in reply to suggestions of the Council for expediting business in that office, was read and referred to the Court and Offices Committee. Two letters were read from the Secretary of Land Commission, both in reply to suggestions from the Council, the one stating that the Record Office of the Commission will, until further order, be open to the public until 4 o'clock, p.m.; the other was in reference to the order of the 15th February, 1889, under the Labourers' Act, and was referred to the Costs Committee for consideration. Reports were read from the House Committee and Parliamentary Committee, the latter being in reference to the Public Trustee and Trust Companies Bills at present before the House of Lords, and both reports were adopted. The Council adjourned till 16th prox.

ADMISSION OF SOLICITORS.

The following gentlemen have been admitted Solicitors of the Court of Judicature:

Mr. David Dunwoody, of Ballynahinch, son of John Dunwoody, Esq., of Moorhall, Cargycreevy, in the county of Down.

Mr. Edward F. Doran, of 120 Pembroke-road, son of the late J. C. Doran, solicitor.

Mr. M. J. M'Donnell, fourth son of Mr. James M'Donnell, of Court Lodge, Rathkeale.

Mr. Samuel Ross, of Belfast, son of William Ross, Esq., of Strandtown, in the county of Down.

Mr. Richard W. Elgee, junior, of Carcur-road, Wexford, eldest son of Richard W. Elgee, Esq., solicitor, of Wexford, and 110 Graftou-street, Dublin.

CORRESPONDENCE.

We throw open the columns of this Journal most willingly for the discussion of subjects of interest to the Profession; but it must be understood that we do not necessarily agree with all the opinions expressed by our correspondents.

Letters and communications intended for publication, and addressed to THE EDITOR, 53 Upper Sackville-street, Dublin, must be authenticated by the name of the writer, not necessarily for publication, but as a guarantee of good faith.

*.* Letters intended for publication in the same week should reach the Office not later than Thursday morning.

THE LATE BARON DOWSE.

TO THE EDITOR OF THE IRISH LAW TIMES.

SIR,-Your statement in last Saturday's Journal in reference to the late Baron Dowse's connection with the Young Ireland movement is accurate in the main, but, instead of his having been brought before the magistrates and let off on his undertaking to appear again when called upon, the fact was that he was merely let out on bail, without being brought before the bench-the magistrate came to him, not he to the magistrate. He was lucky in escaping so easily, for it was an excited time, and compromising communications with the Nation had been found among his papers. As regards the movement with which he sympathised, I shall say nothing, save that there are many who, condemning its spirit by the light of to-day, can yet regard its then followers with more favour: as Kingsley said, in reference to Robert Burns, "a fellow-feeling with the French Revolution, in the mind of a young man of that day, was a sign of moral health, which we should have been sorry to miss in him "-it will apply mutatis mutandis. The writer quoted by you, who says that the Baron consulted ancient authorities chiefly for the purpose of finding something amusing in them, is doubtless right; but, he respected good law wherever found (as Coleridge venerated truth, "from whatever straw moppet its voice proceeds "), while he might say, in Lord Mansfield's words, that his court did not "sit here to take our rules from Siderfin and Keble." He was a lawyer of independent judgment, but sound no less. He certainly made his own career, and is entitled to every encomium in this regard. At the same time, he was not hampered by pecuniary disadvantages, his parents, though not opulent, being in comfortable well-to-do circumstances, while he had wealthy and influential friends. I observe you say pothing about his skill as a cross-examiner, but certainly there were different opinions about it, one being that for ordinary common law cases (unlike Bankruptcy, perhaps, from the nature of things) he was too incautious, especially when led on by his humorous proclivities. Yours truly,

ONE OF THE BARON'S ADMIRERS.

APPOINTMENTS AND PROMOTIONS.

NOTE BENA.-Information intended for publication under the above heading should reach us not later than Friday morning in each week, as publication is otherwise delayed.

Mr. Hillyard, Clerk of Petty Sessions for Castlewellan, has been appointed a Commissioner for Administering Oaths for the district of Castlewellan.

Mr. Larmenie, Petty Sessions Clerk, has been appointed a Commissioner for Administering Oaths in Castlebar, county of Mayo.

Holloway's Pills.-Changes of temperature and weather frequently upset persons who are most careful of their health, and particular in their diet. These corrective, purifying, and gentle aperient Pills are the best remedy for all defective action of the digestive organs. They augment the appetite, strengthen the stomach, correct biliousness, and carry off all that is noxious from the system. Holloway's Pills are composed of rare balsams, unmixed with baser matter, and on that account are peculiarly well adapted for the young, delicate, and aged. As this peerless medicine has gained fame in the past, so will it preserve it in the future by its renovating and invigorating qualities, and the impossibility of its doing harm.

LAW STUDENTS' JOURNAL.

THE INCORPORATED LAW SOCIETY OF

IRELAND.

TRINITY SITTINGS EXAMINATIONS, 1890.

NOTICE.

The Preliminary Examination for Candidates seeking to become Apprentices to Solicitors will be held in the Hall of the Society, Four Courts, Dublin, on Monday and Tuesday, the 19th and 20th days of May, 1890, at Eleven o'clock each day.

N.B.-All Papers to be lodged on or before Saturday, 19th April, 1890.

The FINAL EXAMINATION for Apprentices seeking admission as Solicitors, will be held in the Hall of the Society, Four Courts, Dublin, on Wednesday and Thursday, the 21st and 22nd days of May, 1890, at Eleven o'clock each day.

N.B.-All Papers to be lodged on or before Monday, 21st April, 1890. By Order of the Council,

WM. GEO. WAKELY, Secretary. Solicitors' Buildings, Four Courts, Dublin.

N.B.-The results of the Examinations will be announced on Wednesday, the 18th of June, 1890, at Three o'clock, p.m., and will appear in the Morning Papers of the following day.

COURT PAPERS.

COURT OF BANKRUPTCY.

ADJUDICATIONS IN BANKRUPTCY.

[The dates of Adjudications are first given, the Sittings follow in italics.]

DUBLIN.

Bergin, Patrick, of Kilpatrick, Ballymoyle, in the county of Wicklow, farmer. March 11; Tuesday, April 1, and Friday, April 18. Maxwell, Weldon, & Co., solrs. Dunworth, Robert, of Newcastle West, in the county of Limerick, shopkeeper. March 12; Tuesday, April 1, and Friday, April 18. J. & J. Foley and B. Thompson, solrs, MacLean, Alexander, of Newtownhamilton, in the county of Armagh, grocer, publican and farmer. March 18; Friday, April 11, and Tuesday, April 29. R. A. Mullen and William Carey and Son, solrs.

Rochfort, Daniel, of 38 Townsend-street, in the city of Dublin, pawnbroker. March 15; Friday, April 11, and Tuesday, April 29. Michael Coyle, solr.