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 Rh declaring judgment of forfeiture, proceeds upon the ground that the corporation has entered into a combination and exercised privileges and fran chises not conferred upon it by law; that any act of a corporation which is forbidden by its charter or by a general rule of law, and strictly every act which the charter does not expressly or impliedly authorize, is unlawful. This was the gist of the decision; and so far as that case was concerned, it was sufficient. But the court thereafter entered into an extended consideration of the question whether such combination, into which the corpo ration unlawfully entered, is an injury to the public and unlawful in itself. This question was decided in the affirmative. Judge Barrett and Professor Dwight are thus at issue on the latter question; and we are frank to admit that a study of the arguments of both leaves the student much in doubt. — The Central Law jfournal.

The consideration of the application of Made moiselle Popelin to be permitted to plead in the Belgium courts was disposed of on December 12. The court refused Mademoiselle Popelin's demand, holding that the laws and manners of the country were opposed to the exercise of the advocate's profession by a woman, who has other and social duties to perform.

Accent SDcatljjBf. Dr. Francis Wharton, Solicitor of the State Department and author of the " Standard Digest of International Law," " American Criminal Law," "The Law of Negligence," "Criminal Pleading and Practice," and many other standard works, died at his residence in Washington, February 21, aged sixty-eight years. Dr. Wharton graduated at Yale in 1839, arK* practised law in his native city. He was professor of English Literature, etc., in Kenyon College, Ohio, from 1856 to 1863, when he was ordained a minister of the Episcopal Church and became rector of St. Paul's Church, Brookline, Mass. He was afterwards connected with the Episcopal Theological School at Cambridge, Mass., professor at the Boston Law School, and associate editor of the Philadelphia " Episcopal Recorder." An excellent portrait of Df. Wharton, and an ac count of his connection with the Boston University Law School, will be found in this number.

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Hon. Samuel N. Bell, of Manchester, N. H., a well-known lawyer, and one of the wealthiest and most prominent citizens in the State, who died suddenly at Deer Park Hotel, North Wood stock, was born in Chester, March 25, 1829. He was graduated at Dartmouth in 1847 > studied law with, and became a partner of, State Attorney William C. Clarke. In 1871 he was the Demo cratic candidate in the second congressional dis trict, and was elected over Gen. A. F. Stevens, Republican candidate. He also served in the Forty- fourth Congress. Mr. Albion K. P. Joy, a well-known lawyer of Boston, died at Winchester, February 17. He was a graduate of the Harvard Law School, Class of 1848, and in 1855 was a member of the Boston Board of Aldermen. About thirty years ago, when he lived in Boston, he was a member of the Legis lature. At one time he was attorney for the Union Pacific Railroad Company. He was one of the in corporators and trustees of the Winchester Savings Bank, and for a number of years acted as the bank's attorney. Mr. Joy was a native of Maine, where he was born about sixty-four years ago.

REVIEWS. Johns Hopkins University Studies, seventh series, II., III. This double number contains an historical account of " The Establishment of Muni cipal Government in San Francisco," by Bernard Moses, Ph.D. The events described extend over three quarters of a century, from the foundation of the Spanish pueblo, in 1776, to the adoption of the city charter, in 1851. This history is of ex treme interest, and the paper is a most valuable addition to the many excellent articles published in this series of studies. We make one brief extract, showing the contrast between the San Francisco of fifty years ago and the city of to day. "In 1839 San Francisco had been founded more than sixty years; still it was without a jail, from which it is to be inferred that but little progress had been made in civilization. Finding the criminal Galindo on their hands, the inhabitants of San Fran cisco, through Justice De Hare, asked of the governor that he might be sent to San Josd, which was already provided with a prison. Besides the lack of a jail, another reason for the request was that the inhab