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521 NOTES. S2I taken or the business changed. Judge Doe, noting that the statutes providing for amendment were passed because of the decision in the Darttnouth College Case, approaches the other extreme, taking the view that they were intended merely to enable the legislature to repeal the charter. On a fair construction of the contract, it would seem as if it were intended to reserve an additional control over the corporation, and, while many of the cases support the first theory considered above by dida^ it is yet generally held that all alterations must be consistent with the scope and objects of the corporation's existence as originally chartered. It must be a change, not a substitution. Judge Thompson considers this a possible way of modifying his first view. In the principal case the cor- poration, a railroad, was given authority to lease its entire property. The court held, and it would seem correctly, that the change from an operator of a road to a mere lessor was a fundamental one, and therefore in excess of the power that had been reserved. So much as to the correct construction of the agreement. Judge Doe goes on to say, that, even if the parties did suppose that the legislature stipulated for an unlimited right to amend, the result would be the same, for this would be an attempt to obtain a power greater than the Constitu- tion allows. Judge Thompson also holds this view, and thereby his theories are substantially modified, but its soundness has been much disputed. See The Smking Fund Cases, 99 U. S. 700. It should be added, that the opinion contains a long and masterly discussion of the Dartmouth College Case, in which the Chief Justice disagrees with the decisions of both State and Federal Courts. Representative English Judges of To-day. — This brief sketch of four leading judges is intended to supplement the note on the Principal Courts of England, published in the last number of the Review. Neither a biography nor a satisfactory diagnosis of character can be given within the limits of a note ; but to vitalize and make individual certain famil- iar names is an object perhaps possible of attainment. The present Lord High Chancellor, Baron Halsbury, now at the head of the English judicial system for the third time, is a noteworthy exception to the common saying of the English bar, that a criminal practitioner never reaches the Woolsack. He was educated at Oxford, was made Queen's Counsel in 1865, Solicitor General under Mr. Disraeli in 1875, and sat as Conservative member for Launceston from 1877 till he was raised to the peerage and made Lord Chancellor in 1885. As Mr. Hardinge Giffard, he had a large criminal practice, and was particularly successful in addressing a jury. Eloquent and emotional, he often appeared so touched with his own appeals that he was given the nickname of the " Weeping Counsel." He appeared for the plaintiff in the famous Tichborne case, and held a brief in most of the important causes that came to trial when he was at the bar. Lord Halsbury is of genial and kindly temperament, a keen partisan, and very prominent socially. His career in the House of Commons was not brilliant, and he owes his high office rather to his legal abilities than to political eminence. The most attractive figure on the English bench to-day is Lord Russell of Killowen, the Lord Chief Justice of England. For years he was the unquestioned leader of the English bar, and the list of causes in which he was leading counsel comprises nearly all the famous cases