time a dogged determination in the interests of his clients.

Mr Munro stepped on to the ladder of official preferment in 1906 when he became Sheriff Court Depute; and later, after a short period as Extra Advocate-Depute on the Western Circuit, he was appointed Junior Counsel to the Treasury. The duties and responsibilities of that post have been growing in recent times, and Mr Munro had his full share of important revenue cases, in which his gifts of clear exposition and trenchant statement shewed to full advantage.

In January 1910 Mr Munro began his parliamentary career as member for the Wick Burghs, and since then he has taken a conspicuous place as an effective platform speaker. A Liberal in politics, he became Lord Advocate in 1913 in Mr Asquith's Government. When the first Coalition Government was formed he became Secretary for Scotland-a post which he still holds in the present Coalition, with a seat in the Cabinet. The conditions of Government in time of war threw heavy additional burdens on all the administrative departments, and both as Lord Advocate and as Secretary for Scotland Mr Munro's posts have been no sinecures. In the legislative sphere the greatest statute for which Mr Munro's department has been responsible during his tenure has been the recent Scottish Education Act, and with that measure his name will be long associated.

FACULTY OF ADVOCATES.--Mr Arthur Hunter Denholm Gillies, B.A.(Oxon.), LL.B.(Edin.), was admitted to the Faculty of Advocates on Friday, 19th December.

WRITERS TO THE SIGNET.-The following have been admitted members of the Society of Writers to the Signet: George W. Wallace, 7 Inverleith Row; Adrian H. Cook, 22 Eglinton Crescent; Charles L. P. Grace, St Andrews; Anthony T. Mackenzie, Harecraig, Broughty Ferry; and William R. Rainnie, 3 Carlton Street.

AT the Annual Meeting of the Society of Solicitors of Banffshire the following officebearers were appointed: Mr Alexander Brodie, President; Mr R. G. Shirreffs, Treasurer; and Mr A. F. Spence, Secretary.

NEW SHERIFF-SUBSTITUTE IN SHETLAND.On 13th December last Mr J. W. Forbes, Advocate, was installed at Lerwick as Sheriff-Substitute there. On presenting his commission the new Sheriff-Substitute was introduced by Hon. SheriffSubstitute Leisk in presence of the local Bar, the Convener of the County and the Provost of Lerwick. Speeches of welcome were delivered, to which the Sheriff-Substitute replied. A letter was read from Sheriff Constable.

MESSRS BOYD, JAMESON & YOUNG, W.S., Leith, have assumed as partners Mr R. F. Duncan, solicitor, Mr D. Sturrock, solicitor, and Mr J. S. Bayne, solicitor, who have been associated with them in the conduct of the business for a number of years as heads of their cash, conveyancing, and factory and trust departments respectively. The firm name will remain unaltered.

MR A. N. MACAULAY, solicitor, Golspie, has assumed as partners Mr James Hynd and Mr W. G. Davidson who have been his principal assistants for some years past. The business will be carried on under the name of A. N. Macaulay & Co.

THE LATE MR C. E. GREEN.-It is with great regret that we announce the death, on 6th January, of Mr C. E. Green, of Gracemount, the sole partner of the firm of Messrs William Green & Sons, publishers. Mr Green from the time he first took over the management of this business displayed great enterprise and energy. He extended the field of its operations into the region of English law-publishing with much success. It was he who in succession inaugurated the "Juridical Review," the "Scots Law Times," the "Encyclopædia of Scots Law," the "English Reports," the "Encyclopædia of English Law," and other publications too numerous to detail.

THE LATE MR J. M. DICKSON, W.S.-We regret to announce the death of Mr James Macbride Dickson, W.S., which took place at his residence in Edinburgh. Mr Dickson was a son of Mr A. J. Dickson, W.S., and was born in 1852. He was a distinguished student both at school and college, taking most of the prizes in his time in the University of Edinburgh. He and bursaries which were open to law students took in that University the degrees of Master of Arts and Bachelor of Laws. In 1875 Mr Dickson, after an apprenticeship served with Mr Robert Burt Ranken, W.S., was admitted to the Society of Writers to the Signet. He afterwards became a partner with his father in the firm of A. J. & J. Dickson, W.S. Dickson was at one time an examiner for the W.S. Society. He was widely known in musical circles, and was elected in 1909 as President of the Amateur Orchestral Society.

DECISIONS IN THE ENGLISH COURTS.

The "Hamborn."

Mr

INTERNATIONAL LAW-PRIZE-VESSEL OWNED

BY NEUTRAL COMPANY AND FLYING NEUTRAL FLAG-COMPANY UNDER ENEMY CONTROL.-A vessel owned by a Dutch company, on the Dutch

register of shipping, and flying the Dutch flag, was captured as prize. The shares of the company were held by two other Dutch companies, the shares of which in turn were all held by German companies. In substance the vessel and her trade were part of the commerce and shipping of the German Empire, and her Dutch flag, ownership, and management were adopted merely for convenience. Held that as the centre and whole effective control of the business of the owning company were in Germany the vessel was to be regarded as belonging to German subjects, and must be condemned. Decision of the Prize Court (Evans P.) affirmed.-Judicial Committee of the Privy Council (Lord Sumner, Lord Parmoor, Lord Wrenbury, Lord Sterndale, and Sir Arthur Channell).-31st July 1919.

Britain Steamship Co. v. the King. British India Steam Navigation Co. v. Green.

SHIP-CHARTER-PARTY-POLICY OF MARINE INSURANCE - "WARLIKE OPERATIONS.' Held that the expression "warlike operations" used in a clause in a charter-party or policy of marine insurance, inserted for the purpose of excluding risks arising therefrom or for defining the risks undertaken or insured against, implies the commission of an act of belligerency or an act done with the object of meeting or avoiding an actual or threatened act of belligerency, and (affirming decision of Bailhache J., 1919 S.L.T. 55) does not cover navigating without lights under Admiralty orders or (reversing decision of Bailhache J., 1919 S.L.T. 55) obeying the orders of the officer in command of a convoy which are not given in consequence of an actual or threatened hostile attack, provided the occupation of the vessel is a peaceful one.-Court of Appeal (Warrington, Duke, and Atkin L.JJ.).-31st July 1919.

In re Thellusson--Ex parte Abdy. BANKRUPTCY-LOAN TO BANKRUPT-LENDER AND BORROWER UNAWARE OF RECEIVING ORDER

AGAINST BANKRUPT-JURISDICTION OF COURT TO SET ASIDE TRANSACTION AND ORDER REPAYMENT BY TRUSTEE IN BANKRUPTCY-A loan was made to a bankrupt, the lender and borrower both being unaware that on the previous day a receiving order had been made against the bankrupt. Held in an application by the lender to have the transaction set aside and the official receiver, as trustee in bankruptcy, ordered to repay to him so much of the money as had come into his hands that the Court was entitled to order the trustee, as an officer of Court, to repay the lender, on the principle of fair and honourable dealing as between man and man. Decision of Horridge J. (1919 S.L.T. 75) reversed. -Court of Appeal (Warrington, Duke, and Atkin L.JJ.). 31st July 1919.

Hepworth Manufacturing Co. v. Ryott.

CONTRACT-RESTRAINT OF TRADE-USE OF

ACTOR'S STAGE NAME-CONTRACT PROHIBITING USE OF NAME BY ACTOR ON TERMINATION OF CONTRACT.-An actor entered into an agreement with a cinematograph film-producing company to perform for them in connection with their production. The contract provided that if the company advertised the actor they would do so under the pseudonym of Stewart Rome; that the right to use such pseudonym should be the sole property of the company; and that upon the termination of the contract the actor should not use the name for any purpose whatever. Held that the agreement not to use the name was unenforceable as being in restraint of trade, oppressive, and affording more than reasonable protection to the company. Decision of Astbury J. (1919 S.L.T. 77) affirmed.-Court of Appeal (Warrington and Atkin L.JJ., and Eve J.).— 16th October 1919.

his duty to insure up to the sum for which a reasonably prudent owner would have been content to insure.-K.B. Div. (Roche J).-20th October 1919.

Fletcher & Son v. Jubb, Booth & Helliwell.

LAW AGENT-NEGLIGENCE-ACTION AGAINST PUBLIC AUTHORITY-PUBLIC AUTHORITIES PROTECTION ACT 1893 (56 & 57 VICT. CAP. 61),

SECTION 1-DUTY ΤΟ INFORM CLIENTS OF STATUTORY LIMITATION OF RIGHT OF ACTION.

Held that solicitors who were instructed to negotiate a claim of damages against a city corporation were bound to keep the provisions of the Public Authorities Protection Act 1893, section 1, in view and were negligent in failing to inform their clients, when intimating an offer in settlement by the corporation, of the effect of the provisions of the statute in the event of an action not being timeously raised. Decision of Lawrence J. reversed.-Court of Appeal (Bankes, Scrutton, and Duke L.JJ.).-21st October 1919.

Ashrody v. Owners of S.S. "Edinburgh Castle."

DE

WORKMEN'S COMPENSATION SEAMAN CLARATORY AWARD-MERCHANT SHIPPING ACT

1906 (6 EDW. VII. CAP. 48), SECTION 34 (1)— WORKMEN'S COMPENSATION ACT 1906 (6 EDW. VII. CAP. 58), SECTION 7 (i) (e).-Held that the fact that employers were paying his wages, maintenance, and medical expenses, under section 34 (1) of the Merchant Shipping Act 1906, to an injured seamen did not disentitle the seaman to compensation under the Workmen's Compensation Act 1906, although under section 7 (i) (e) of that Act the weekly payment was not payable, and that the arbitrator was entitled to make a declaration of liability against the employers.-Court of Appeal (Warrington and Atkin L.JJ., and Eve J.).-31st October 1919.

Woodfield Steam Shipping Co. Ltd. v. J. L. Thompson & Sons Ltd.

CONTRACT

PERFORMANCE - DELAY DUE TO GOVERNMENT INTERFERENCE-FRUSTRATION OF CONTRACT.—In 1916 a firm of shipbuilders contracted to build two vessels for the plaintiffs. The contracts provided that "whereas no delivery date can be specified the builders will make their best endeavours to give as early delivery as possible, which they anticipate will be in 1918 [in one contract early in 1918']. If the builders be delayed or prevented by strikes, combinations, or lock-outs, whether partial or general. . . . or by fire, war, riots, insurrection or any other unforeseen

occurrence of any kind whatever. . . . the builders shall be allowed an extension of time for all time lost directly or indirectly by reason of the aforesaid matters. . . ." At the date of these contracts the Government was encouraging the building of ships under private contracts; but before the defendants started work on the vessels, orders were issued forbidding the construction of any but standard ships. It was impossible therefore at that time for the defendants to proceed with the building of the ships.

In November and December 1918 the plaintiffs claimed that the defendants should proceed with the contracts; but the latter refused. In an action by the plaintiffs for a declaration that the two contracts were valid and subsisting, and that the defendants were bound to perform the contracts, held (affirming judgment of Rowlatt J., 1919 S.L.T. 76) that the interference on the part of the Government had so changed the circumstances in contemplation of which the parties had contracted that the doctrine of frustration applied, and the action must therefore fail.-Court of Appeal (Lord Sterndale M.R., Atkin L.J., and Eve J.).-4th November 1919.

The latest issue of the "Juridical Review" is a double number, containing articles of very various interest. Antiquarian interests, scientific jurisprudence, modern law, both British and foreign, and even personal gossip are represented. On the more serious side Mr F. P. Walton's learned article on "The French Administrative Courts" deserves a special word of notice, for it touches on a vital difference between British and Continental jurisprudence which deserves to be further studied. Antiquarian research is represented by an article by Mr Hilton Brown on "The Old Scots Law of Heresy" and by an interesting study on "An Elizabethan Precedent Book." It is to be regretted that the notes of decided cases, both Scottish and English, and also the reviews of books have been held over so long that they have somewhat lost the freshness of their interest. Mr Roughead contributes in his familar vein a readable account of Macdonell of Glengarry and Lord Guthrie continues his reminiscences of R. L. Stevenson.