no less than 86,038,000l. since July, 1914. At the end of the year, when a somewhat belated rally occurred, due mainly to the satisfactory Irish and Washington news, and to the announcement of the lowering of railway freights, which together imparted buoyancy to stock markets generally, the aggregate was 2,332,346,000l., as compared with 2,319,777,000l. a year previously. This represents an average rise of approximately per cent. The figures at the end of each quarter were :

In October there was a reaction, due mainly to the violent movements in the German exchange and the uncertain political outlook.

The outstanding feature. of the year was the substantial advance in British funds, an average rise of approximately 12 per cent. being recorded. This buoyancy was very largely due to the investment in giltedged securities of enormous sums of money which in better circumstances of trade would have been employed in industrial enterprises. Other factors in the rise were the good sentimental feeling produced by the Washington Disarmament Conference, and the signing of the Irish Treaty, and low money rates. The quotation for the premier British security, the Five per Cent. War Loan, at the end of the year was 92 3/16, as compared with 82 15/16 at the close of 1920, and a rise of 11 points above the lowest point touched.

The coal stoppage, though exercising, of course, a very wide influence upon industry as a whole, naturally affected the coal, iron, and steel trades most severely, and values of these securities suffered an average fall of more than 25 per cent., by far the biggest home individual depreciation. The speculative foreign mining shares experienced an average depreciation of approximately 20 per cent. Next on the black list were American railroad securities, which showed a fall of just under 17 per cent., largely due to Grand Trunk affairs. A fall of nearly 10 per cent., attributed to American exchange fluctuations, occurred in railways in British possessions. Home railways were better by about 3 per cent. on balance, shipping shares fell away to the extent of 63 per cent., the rest generally showed firmness on the year, notably those of brewery and electric power companies. Rubber shares were latterly quite a bright spot, although the industry itself passed through the most acute crisis it had ever experienced, distinct improvement being made in the last few months.

and

Insurance companies had a very lean year. The heavy, all-round fall in values, and the acute trade stagnation not only made it extremely difficult for the marine underwriter to keep his books adequately filled with satisfactory risks, but added many other difficulties to his task. Burn-outs and losses at sea not entirely above suspicion were numerous, and more than a few doubtful claims had to be met, "artificial" realisation of insurance policies being for many unprincipled people the only means of averting insolvency. Cargo underwriting was, of course, only negligibly existent, the fidelity guarantee manager had his worst year, and the "life" manager, though faring, perhaps, best, experienced a big falling off in premiums, owing to the comparative poverty of the public generally.

LAW.

ALTHOUGH no event of outstanding importance in the legal world occurred in 1921, yet the number of noteworthy incidents was, perhaps, more than usually large. The Courts started the year with the largest amount of business on record. No fewer than 4,378 cases stood in the High Court lists when the Judges reassembled in January, considerably more than half of them being for hearing in the Divorce Court. At the end of the year the number of matrimonial cases had been reduced from 2,450 to 1,032, the huge accumulation of arrears with which the Divorce Court commenced the year having been removed mainly through the voluntary help which the Lord Chancellor and Lord Mersey gave the Court. In the King's Bench Division, on the other hand, notw thstanding the transfer of its bankruptcy work to the Chancery Division, arrears were so persistent that the King's Bench Judges were induced to resume their judicial labours a week before the official close of the Long Vacation. This temporary curtailment of the Long Vacation-which aroused much interest on account of the oft-repeated demand for a permanent reduction of the legal holidays-did not, however, enable the Judges to achieve their purpose. At the close of the year, as at its beginning, a large number of actions were awaiting trial which had lingered in the King's Bench lists more than six months.

To this pressure of work in the King's Bench Division was officially ascribed the failure of the Lord Chancellor, the Lord Chief Justice, and the President of the Probate, Divorce, and Admiralty Division to make the necessary Rules for instituting the system of divorce trials at Assizes contemplated by Parliament when it passed the Administration of Justice Act, 1920. "While," said the Attorney-General, "the pressure of work in the King's Bench Courts remains as heavy as it is, it is not practicable to increase the amount of work to be done by the King's Bench Judges at Assizes." Throughout the year, therefore, the Administration of Justice Act, so far as it relates to the local trial of matrimonial cases, was allowed to remain a dead letter. The obvious reply was made in many quarters that if the King's Bench Judges were not numerically equal to their work, their number ought to be increased. More than once the Lord Chancellor intimated than an increase in the judicial staff was necessary. At the Lord Mayor's banquet to the Judges, in particular, he deemed it opportune to urge that "speedy justice" is a fundamental necessity of a civilised community. But the Government took no steps to fulfil the expectation that additional Judges would be appointed with the double object of removing the

arrears in the King's Bench Courts and carrying out the will of Parliament concerning the trial of divorce cases at Assizes.

Two of the most interesting events of the year were associated with our time-honoured system of trial by jury. Women made their first appearance as jurors in the High Court. Upon more than one occasion, even in civil cases, the Judges exercised their power to order a trial before male jurors only where the evidence was regarded as unsuitable for presentation to a mixed jury. Very few women were, however, called upon to serve, not because there was any objection to their presence in the jury box, but because, as the result of the war restrictions upon the right to trial by jury having been made permanent, the number of actions tried with juries was unprecedently small. Of the 1,603 actions in the King's Bench lists when the Courts were re-opened after the Long Vacation, only sixty-three were entered to be tried by juries. In the Divorce Court, where some 5,000 cases-most of them, it is true, undefended-were disposed of during the year, only about a dozen juries were empanelled. This decline of trial by jury in the civil courts was in rather strange contrast to an official recognition of its importance in the criminal courts. Grand Juries, which were suspended during the war period, were restored by an Order in Council, notwithstanding a widely-expressed view that they had long ceased to be an essential part of the administration of justice.

No measure of law reform will make the year memorable in legal annals. The Lord Chancellor re-introduced the Law of Property Bill, by which the tenure and transfer of land are to be simplified, but the Bill, which is one of the bulkiest ever presented to Parliament, again failed to get beyond its preliminary stages. But the year, though it yielded nothing of real achievement in the way of law reform, was not lacking in promise. A committee was appointed, with Mr. Justice Horridge as chairman, to consider the long delays in criminal trials at Assizes, through which a considerable number of accused persons are kept in prison three or four months before they are brought to trial, some of whom are found to be innocent when at length they come before a jury. During the closing days of the year another Committee was appointed by the Lord Chancellor to consider the special privileges which the Crown enjoys as a litigant in the courts. Both the Bar Council and the Council of the Law Society, in view of the extended functions of Government Departments, condemned the ancient procedure of "petition of right" as costly, inconvenient, and dilatory.

Several noteworthy changes in the Judiciary occurred. The Earl of Reading, whose appointment as Viceroy of India created a fresh record in the widening field of the lawyer's influence in public affairs, was succeeded in the office of Lord Chief Justice by Mr. Justice A. T. Lawrence, the first Puisne Judge to be promoted to the office since Lord Tenterden was appointed nearly 100 years ago. Sir Gordon Hewart, who as Attorney-General had unchallengeable claims to the high position, was not appointed to succeed Lord Reading, because the Prime Minister was unwilling that the Government should lose his Parliamentary services, and Sir A. T. Lawrence-who was raised to the peerage

under the title of Lord Trevethin-in acknowledging the AttorneyGeneral's welcome at his swearing-in, made this graceful allusion to his compliance with the Prime Minister's request: "It is only your high sense of duty that prevents you being the welcomed instead of the welcomer." Before his departure to India the Earl of Reading was entertained by the Bench and Bar in the Middle Temple Hall. The death of Lord Moulton, distinguished alike as a lawyer and a scientist, who rendered the country the most valuable service at the Ministry of Munitions during the war, created a vacancy in the ranks of the Lords of Appeal in Ordinary, which Sir Edward Carson, more famous as an advocate than as a jurist, and still more famous as a Parliamentarian, was appointed to fill. The only other change in the higher branches of the Judiciary was that occasioned by the promotion of Mr. Justice A. T. Lawrence to the Lord Chief Justiceship, his place as a Puisne Judge of the King's Bench Division being taken by Mr. G. H. Branson, who was the Attorney-General's "devil" on the Common Law side. Six new County Court Judges were appointed. Judge Shand, Judge Mulligan, Judge Rowland Roberts, and Judge Bryn Roberts resigned, and Judge Dowdall, K.C., Judge Herbert Smith, Judge Dobb, and Judge Caradoc Rees succeeded them. The vacancies caused by the deaths of Judge Mackarness and Judge Macklin were filled by Judge Randolph, K.C., and Judge Bradley. In the personnel of the Metropolitan Bench two changes took place, Mr. Bros, who retired after thirty years' service, being succeeded by Mr. Samuel Fleming, and the late Mr. Ralph Bankes, K. C., whose tragic death was widely regretted, by Mr. Samuel Pope. On the Railway and Canal Commission, a judicial body little known to the public but charged with very important duties, the late Lord Terrington was succeeded by Sir John Lewis Coward, K. C., a well-known member of the Parliamentary Bar, while the office of Registrar of the Commission, made vacant by the death of Master Macnamara, was filled by Sir Robert McCall, K. C., one of the oldest leaders of the Common Law Bar. Of larger interest was the election of Lord Finlay, the ex-Lord Chancellor, as the British Member of the Court of Permanent Arbitration at the Hague.

Comparatively few leading decisions of general interest were delivered during the year. The decision which attracted the greatest amount of public attention was that delivered by the House of Lords in Sutters v. Briggs, where the Law Lords held that a cheque given for a racing bet was given for an illegal consideration, and that money paid to the indorsee or holder of the cheque was recoverable by action at law. The legality of "whist drives" was again the subject of argument in the courts. A promoter of "whist drives" for money prizes being indicted at the Surrey Sessions under the Gaming Houses Act, 1854, for keeping a gaming house, the Deputy Chairman, notwithstanding a finding of the jury that "skill predominated," directed a verdict of "guilty." Against this verdict there was an appeal to the Court of Criminal Appeal, which quashed the conviction on the ground that the Deputy Chairman was not justified in dictating the verdict. This case (Rex v. Hendrick) cannot, therefore, be regarded as establishing the legality of "whist drives." On the contrary, the three Judges of the Court declared that there was no evidence to support the finding of the jury that "skill predominated,"

and that the finding did not of itself entitle the appellant to an acquittal. Apart from these gaming cases, no proceedings in the High Court excited more interest than those arising out of the refusal of the Poplar Borough Council to pay the precepts of the London County Council and the Metropolitan Asylums Board. A writ of mandamus was granted to compel the Poplar Borough Council to perform its statutory duty to pay the precepts, and, the order of the Court not being complied with, a writ of attachment was issued, not against the members of the Council as a whole, but against those who had expressed their unwillingness or inability to comply with it. Most of the members of the Council eventually went to prison for contempt of Court, but were released on giving an undertaking to consider an arrangement by which the precepts of the London County Council and the Metropolitan Asylums Board might be met.

A novel question of some constitutional importance was raised in another contempt of court case (Rex v. Editor of" Daily Mail"). The words complained of had reference to a court-martial, and the jurisdiction of the High Court to deal with the matter was challenged. The King's Bench judges by whom the motion was heard decided that, a courtmartial having no authority to punish for contempt of court, the King's Bench had the power to protect it. They decided, in the end, that the published words were calculated to prejudice the trial before the courtmartial, and imposed a fine of 2001. upon the editor. Another case of some constitutional importance was Johnstone v. Pedlar, in which the House of Lords had to determine the claim of an American citizen, who took part in the Irish rebellion in 1916, against the police authorities for the return of certain moneys which they took from him when he was arrested. His claim was resisted on the ground that the moneys were seized and detained by an officer of the Crown as an "Act of State," but the House of Lords decided that the mere assertion that the claimant was an alien did not entitle the authorities to rely upon this defence, and emphasised the principle that "the subject of a State at peace with His Majesty, while permitted to reside in this country, is under the King's protection."

A much discussed decision was given in Rex v. Lyon, in which the Divisional Court held that theatres were not "places of educational interest or value" within the meaning of the Education Code, and that education authorities who spent the ratepayers' money on taking children to see a Shakespeare play at a theatre were liable to be surcharged. Another Local Government case affecting the interests of children created some surprise. It was decided by the House of Lords, in Glasgow Corporation v. Taylor, that if a child picks a poisonous berry in a public park and dies in consequence of eating it, the child's father has a right of action against the park authority. Among other cases of general interest may be mentioned Grant v. Cardiff Hotels Company, in which it was held that a traveller who enters an inn with the object of becoming a guest, and has some of his property stolen before he is actually accepted as a guest, is entitled to be indemnified by the innkeeper for his loss; and Great Western Railway Company v. Evans, in which it was decided that a professional violoncello player is not entitled to have his instrument carried