The Stock Exchange had a good year. In the early part of the period there was great activity in fixed interest bearing securities and other high-class investment stocks, such as Home Railway Ordinary Securities, and the tone was very buoyant. Prices rose substantially. After the disbursement of the June dividend on the 5 per cent. War Loan the tone weakened, owing to efforts to deflate currency, and the rise was arrested by the resultant scarcity of credit. A reaction occurred in the autumn, but towards the end of December money became more plentiful and a fresh rise took place. The Bankers' Magazine calculations of Stock Exchange values bring out clearly the course of markets.

At the end of December, 1921, the total value of 387 representative securities (having a par value of about 6,500,000,000l.) was 5,393,349,000l.

On the year, there was an increase of 712,000,000l., equal to 13.2 per cent. The rise in British and Indian funds was equal to 11.8 per cent. Taking 94 fixed interest-bearing stocks, having a value at the end of 1920 of 3,966,850,000l., an increase of 394,737,000l., equal to 11 per cent., is shown. The increase in variable dividend securities was much greater. The value at the end of 1922 of 293 such securities was 2,138,585,0001. an increase of 317,349,000l., or 17.6 per cent. 28 British railway ordinary stocks showed an appreciation of 54.9 per cent., 20 foreign railway stocks of 59.5 per cent., 38 industrial and commercial shares 34.3 per cent., and 7 tramways and omnibus securities 454 per cent. Gas stocks show a rise of 34.7 per cent. and South African mining shares of 32.4 per cent. Oil shares were an exception to the general rule, the values of ten of them showing an average depreciation of 19-4 per cent.

The year was an eventful one in the insurance world. There were one or two regrettable incidents. The failure of the City Equitable Fire Insurance Company, which did a large insurance business in marine and fire risks, was a shock to the insurance world, especially as official inquiry showed that the failure was due not only to unfortunate business, but to the improper administration of the company's funds. The failure involved a number of associated offices. One or two fusions were arranged, the principal being the acquisition of the London Guarantee and Accident Company by the Phoenix Assurance Company. Marine underwriters had a bad year. The tendency of rates was weak, because the agreement among underwriters for the maintenance of rates was abandoned, and the market is now entirely free. The fire insurance companies also had a bad year. Premium incomes fell off considerably. Losses in the United Kingdom were 6,218,000l. against 8,128,000l. in 1921, but losses in North America were very heavy, the total being about $400,000,000, against $330,000,000 in 1921. Business in life assurance was fairly well maintained, but the companies' mortality experience was less favourable than that of 1921, which was the most favourable year ever known. On the other hand, the companies' funds gained by the appreciation in fixed interest-bearing securities.

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THE legal chronicle for 1922 includes an unusually large number of noteworthy events. A year which witnessed the admission of the first woman to the English Bar must always be memorable in the long annals of one of the most conservative professions in the world. distinction of being the first member of her sex to become a barrister was achieved by Miss Ivy Williams, who was called at the Inner Temple in Easter Term. How ancient are the traditions of the Inns of Court, of which several other women became the heiresses before the year was out, was indicated by the celebration of the quincentenary of Lincoln's Inn, the main feature of which was an impressive service in the historic chapel of the Inn, at which the King, accompanied by the Queen, was present in his capacity of a Bencher. Another event which, in a minor degree, served to illustrate the continuity of legal things amid "the change and chance of Time" was the centenary of the Law Journal, in the celebration of which the Lord Chancellor and many other distinguished lawyers took part.

Some important changes in the legal offices of the Government followed the resignation of Mr. Lloyd George. Lord Birkenhead, who had created during his four years on the Woolsack a great reputation as a law reformer, and upon whom an Earldom was bestowed on his retirement, was succeeded by Lord Cave, who was the first Lord of Appeal in Ordinary to be promoted to the position of Lord Chancellor. The new Lord Chancellor was not slow to indicate his readiness to proceed with the reforms which his predecessor had initiated. At the Guildhall banquet, within a few weeks of the formation of Mr. Bonar Law's Ministry, he foreshadowed a consolidation of the law of real property, a simplification of the rules of procedure, a rearrangement of the circuits of the judges, and a reform of the County Court system. Sir Ernest Pollock, K.C., M.P., and Sir Leslie Scott, K.C., M.P., followed Lord Birkenhead into retirement, whereupon Mr. Douglas Hogg, K. C., and Mr. T. W. H. Inskip, K.C., M. P., both of whom subsequently received the honour of knighthood, became Attorney-General and SolicitorGeneral respectively. Earlier in the year a change occurred in the highest strictly judicial office in the land. Lord Trevethin, who resigned the position of Lord Chief Justice after occupying it less than twelve months, was succeeded by Sir Gordon Hewart, whose place as AttorneyGeneral was taken by Sir Ernest Pollock, who, in his turn, was succeeded as Solicitor-General by Sir Leslie Scott. Upon his elevation to the peerage the new Lord Chief Justice, following the example of most of his predecessors in their preference for preserving their family names, adopted the title of Lord Hewart of Bury. The only other change in the High

Court judiciary was occasioned by the death of Mr. Justice Peterson, whose place in the Chancery Division was filled by Mr. Mark Romer, K.C., who, like Mr. Justice Russell, one of his younger colleagues in the same Division, is the son of a judge.

One great measure of law reform will help to make the year conspicuous in legal annals-would, indeed, have been sufficient to make it memorable even if no other noteworthy event had occurred in the course of it. The Law of Property Act, with which more than one Lord Chancellor had been concerned, was, largely owing to Lord Birkenhead's skill as a parliamentarian, placed on the Statute Book, and the tenure and transfer of land will be much simplified and cheapened when the Act-one of the bulkiest and most complicated ever passed-comes into operation at the beginning of 1925. Another noteworthy change was the initiation of the trial of matrimonial causes at Assizes. Although the principle of the local trial of divorce cases was expressely recognized by the Administration of Justice Act, 1920, yet it was not until about the middle of 1922 that the necessary Rules were passed for carrying out the will of Parliament. At eleven Assize towns-Newcastle, Leeds, Liverpool, Manchester, Chester, Birmingham, Nottingham, Norwich, Cardiff, Swansea, and Exeter-a limited class of matrimonial suits, chiefly "poor persons" and undefended cases, became triable by virtue of these Rules. The new system was successfully introduced at the Autumn Assizes, and several large towns, notably Bristol, complained of their omission from the scheme. Two strongly constituted Committees considered other aspects of the Assize system during the year. One, under the chairmanship of Mr. Justice Horridge, appointed to consider the long delays in criminal cases, through which many prisoners, some of whom are innocent, are kept in prison three or four months before they are brought to trial, recommended, among other changes, that more trials should take place at Quarter Sessions and that bail should be granted more freely; the other, with Mr. Justice Swift as its chairman, appointed to consider by what rearrangement of the circuits of the judges more economy and expedition in the administration of justice might be secured, had not completed its labours when the year came to a close. The fear of a drastic reduction in the number of circuit towns led not a few grand juries at the Autumn Assizes, encouraged in many instances by the judges, to pass resolutions protesting against any interference with the ancient privileges of their own cities.

Several minor changes affecting the administration of justice were made by Parliament. Foremost among them is the Act under which judges are no longer required to pass the sentence of death upon women who kill their newly-born infants. The frequent protests made by judges against the statutory requirement to try in closed courts all persons charged with incest were not without their effect, and an Act was passed which provides that all such cases shall now be tried in public. In response to the general demand for economy, the Legislature permitted the jury lists to be prepared without the full particulars which formerly enabled the sheriffs to refrain from summoning certain classes of the community, such as farmers and boarding-housekeepers, at seasons of the year when jury service would be most inconvenient to

them. By the passing of an Act of more professional interest-the Solicitors Act, 1922-a further step was taken in the cause of legal education. The Act requires all clerks articled after December 31 last, unless they are relieved of the obligation, to attend at least one year's course at a recognised Law School before they sit for their final examination. A fresh interest was given to the oft-discussed proposal to create a great School of Law in London by an announcement at Gray's Inn that the late Lady Holker, the widow of Lord Justice Holker, had, subject to a certain life interest, left to the Inn property of the approximate value of 100,000l. for the purposes of legal education.

Of legal appointments, apart from the High Court changes already chronicled, there were not a few. Seven new County Court judges were appointed. Judge Rose-Innes, K.C., Judge Stanger, K.C., Judge Graham, K.C., Judge Lush-Wilson, K.C., and Judge Shortt resigned, and Judge Hargreaves, Judge Whitmore Richards, Judge Staveley Hill, Judge Gurdon, and Judge Higgins succeeded them. The two vacancies caused by the deaths of Judge Elliott and Judge Fossett-Lock were filled by Judge Head and Judge Lias. On the retirement of Sir Forrest Fulton, K.C., after twenty-two years' service, Sir Ernest Wild, K.C., was appointed Recorder of London. In another City judicial office-one of the Judgeships of the Mayor's and City of London Court-the late Judge Jackson was succeeded by Judge Shewell Cooper. On the Metropolitan Bench two vacancies arose, Mr. Denman, who retired after thirty years' service, being succeeded by Mr. K. M. Marshall, and the late Mr. Chester Jones, whose death deprived the London Police Courts of one of their ablest magistrates, by Mr. Radcliffe Cousins. At the close of the year, upon the retirement of Mr. H. S. Theobald, K.C., who, notwithstanding his blindness, had discharged the duties of Master in Lunacy with conspicuous ability, Mr. Hildyard, K.C., was appointed to succeed him.

No decision in a civil case attracted more attribution than that delivered by the House of Lords in Kerr v. Bryde, in which the Law Lords, confirming the judgment of the Court of Session in Scotland, held that a landlord is not entitled to an increase of rent under the Rent Restrictions Act unless he first serves a notice to quit-a decision which was the subject of much discussion at the General Election, particularly in Glasgow and other large Scottish towns. A question of constitutional importance was decided in Attorney-General v. Wilts United Dairies Ltd., in which it was finally decided that the Food Controller had acted ultra vires in imposing a charge of 2d. per gallon as a condition of granting a licence to dealers in milk in one area to purchase milk imported from another. The House of Lords decided that the charge of the Food Controller, though he purported to act under the Defence of Realm Regulations, was invalid as a levying of money for the use of the Crown without the authority of Parliament. In the most important Revenue case of the year, Davis v. Commissioners of Inland Revenue, the Court of Appeal, approving a judgment of Mr. Justice Sankey, decided that the personal allowance of 2251. deducted for the purpose of income tax cannot be claimed by a person assessed for super-tax. Even wider interest was created by the decision of Mr. Justice Roche in Attorney-General v. Swan

that the subscriptions of the members of the Essex County Cricket Club were liable to Entertainment Duty because the subscribers were entitled to admission to matches to which the public were admitted only on payment. A judgment much discussed by lawyers and golfers was given in Castle v. St. Augustine's Links Ltd., in which the plaintiff, having been injured by a sliced ball driven by one of the members of the club from a tee close to the highway, sued the proprietors of the links for compensation for his injuries. Mr. Justice Sankey decided that the proprietors, as well as the player, were liable, on the ground that the situation of the hole to which the player was driving was so dangerous to the public as to be a nuisance.

The year yielded a considerable crop of betting cases, though their growth was interrupted by the Gaming Act, 1922, which was passed with the object of making it no longer possible for a man who had paid bets by cheques to recover the money. Mr. Justice McCardie decided, however, in Bowling v. Camp that the Act did not prevent the continuance of proceedings started before the Act was passed nor the commencement of fresh proceedings in respect of claims which arose before that date-a decision which the Court of Appeal approved in dismissing a contrary decision by Mr. Justice Greer in Reading v. Goll. A noteworthy decision on the Statute of Limitations was delivered by the House of Lords in Spencer v. Hemmerde, in which the words, "It is not that I won't pay you, but that I can't do so at present," were treated as a sufficient acknowledgment of the debt to take it out of the statute. In Braithwaite v. Amalgamated Society of Carpenters a member of a trade union obtained an injunction to prevent the union from expelling him because he was employed by a company with a profit-sharing scheme, the House of Lords, to which the hard-fought case was carried, deciding that the rules under which he had been expelled-rules providing for the expulsion of any member "working on a co-partnership system" or under a "premium bonus system"-were not infringed by the profit-sharing scheme in question.

The familiar question of the liability of husbands for debts incurred by their wives was dealt with elaborately by Mr. Justice McCardie in Miss Gray Ltd. v. Cathcart, in which he decided that the presumptive authority of a wife to pledge her husband's credit in the purchase of such articles as millinery and dress might, among other considerations, be excluded by extravagance in the orders. Another familiar point was treated exhaustively by Mr. Justice Sankey in Lavie v. Cross, in which a lady who lost a considerable amount of jewellery at a London hotel was held to have contributed to the loss by leaving her bedroom door unlocked, with the result that her claim against the hotel proprietor as a common innkeeper" was unsuccessful. In an important case relating to the carriage of goods, Neilson v. London & North-Western Railway Co., the House of Lords decided that a railway company which, having accepted the carriage of goods "at owner's risk," deviates from the route agreed upon is not protected by the "owner's risk" note from liability for loss occurring "during the transit." The most notable divorce case was Rutherford v. Rutherford, Richardson intervening, in which the House of Lords, affirming the judgment of the Court of Appeal,

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