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 Cases from the Old English Law Reports. days before the Married Women's Property legislation. He at once set about acting after his kind. He committed all sorts of waste on the estates, raised large sums of money by cutting down great quantities of timber and by granting annuities payable out of the rents and profits of the property, and com pelled his unfortunate wife to execute what ever deeds he thought necessary by way of security. After some years his wife left him, and with the exception of a short period during which, having had her seized and forcibly carried away to a castle by armed men, he detained her there, maltreating her as before, she never lived with him again. At length the Countess appealed to the law. She instituted a suit for divorce—not, it need scarcely be said, a vinculo (in those days there was no tribunal that could grant that), but a mensa et toro, in the Consistory Court of London. She applied to the Court of King's Bench to compel him to "keep the peace" in regard to her, and she moved the Court of Chancery to establish the ante nuptial settlement of 1777, and to set aside the revocation of it which Bowes had ex tracted from her by coercion. The hour of retribution had at last come. The Con sistory Court granted a degree of judicial separation, and first the Court of Arches and afterwards the Court of Delegates affirmed the sentence. The King's Bench bound Bowes over to "keep the peace." In the

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Court of Chancery he met the Countess's claim with a plea of extraordinary im pudence. The man who owed his position as her husband to fraud of the grossest kind, actually maintained that the Countess's ante nuptial settlement—not having been comnumicated to him before marriage, was in valid as being a "fraud on his marital rights." The Court of Chancery promptly rejected this contention, and the House of Lords met with an equally uncompromising negative. The head-note of the case is worth citing. A settlement made by a woman while unmarried, is not in all cases void against any husband she may afterwards take. To avoid such a settlement the husband must show to the court that he has been deceived : mere concealment alone is not enough. And if he demands to have the deed set aside without offering to make any provision for the wife, this is a ground for refusing relief. In all cases where a husband comes into Chancery for his wife's fortune, he must make a settlement. A man who marries without a treaty must be content to take a wife as he finds her.

Thus, even in the days of Stoney, alias Bowes, was the law quick to deprive fraudu lent and avaricious husbands of their prey wherever the opportunity offered itself. Xow the Married Women's Property Act, 1882 (S. 2), prevents husbands who have married since that year from acquiring by marriage any title to their wives' property. So have the sorrows of the Countess of Strathmore yielded the peaceable fruits of justice to her sex in the years to come.