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Rh attainment.' The schools were bound by a conscience clause and had to be open to government inspectors, who could report whether the conditions laid down by the central authority as precedent to a grant had been complied with. This new system comprised two kinds of schools—the schools supported by voluntary subscriptions, which were in existence at the date of the passing of the act, and board schools. These latter schools came into existence in districts where there was Insufficient voluntary school accommodation and where in consequence the rate payers had elected a school board. This board erected, at the expense of the rate payers, schools sufficient to supply the wants of the district, and these schools were maintained out of the rates, central grants and school fees. In the board schools, in addition to the conscience clause in use in voluntary schools, the Cowper-Temple clause of the act of 1870 enforced the rule that 'no religious catechism or religious formulary which is distinctive of any particular denomination shall be taught in the school.' Thus the effect of the act of 1870 was to place side by side two great school systems—a denominational system, the schools of which had for the most part been built and were maintained by voluntary subscriptions, to some extent supplemented by grants—and an undenominational rate-supported system independent of voluntary subscriptions. The passage of years saw the rapid increase and development of both systems. The act of 1870 gave the various school boards power to compel parents by by-laws to send children to school between the ages of five and thirteen years, but it was not until 1876 that the legislature created the universal parental duty of causing all children to 'receive sufficient elementary instruction in reading, writing and arithmetic' This was followed in 1891 by an act granting to practically all the public elementary schools a fee-grant in lieu of the fees hitherto paid by the parents. This important step of creating free elementary education was an almost necessary corollary of the institution of compulsory education, and it was essential for the reason that those children who most needed school life were the offspring of the most needy parents. The result of these various acts was to create vast school board systems in London and the great towns which in certain areas crushed the voluntary schools out of existence. The standard imposed by the Education Department rapidly rose, and the number of subjects taught greatly increased. Gradually the great school boards endeavored, by the creation of what were known as higher elementary schools, to bring secondary education within their control and to supply this education out of the rates in competition with the newly-efficient endowed secondary schools of their districts. In 1901, in the famous case of Cockerton, it was held that this was illegal, and it became necessary at once to create by statute a national system that should control and develop both primary and secondary education. The school board system, while it had been