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and may prove it. But it certainly goes this length—that the church must prove it. The presumption is henceforth against it, even in the case of a Scottish church, which claims in its creed a Christ-given government, and has once in its history given up everything for freedom. But does not the presumption against it go further still? Some parts of the Lord Chancellor's opinion might suggest that a creed or confession, being the foun dation of a church, cannot be revised even by a body which originally claimed the right to do it. And Lord Robertson repeatedly hints, even while dealing with a church which from its birth had ear-marked its churches and manses for a future "united body," that there may be much in the view taken in the old cases of Kirkintilloch and Thurso, that unless a church is absolutely unanimous, it may be prevented from unit ing with another, even when no difference in doctrine or principle is alleged between the two. But probably neither judge is quite committed to either extreme position. And neither made part of the judgment of the House. The privilege or latitude of Scottish churches may be henceforth no greater than that of ordinary trusts. But it is, at any rate, no less. And it is by no means re stricted to that of statutory companies with their memorandum and prospectus. But it is doubtful whether this judgment of our highest tribunal, assuming it to be exactly just as to all the past, has sufficient illumination for the guidance of such a fu ture. It does not even give (as was ex pected, and as the Lord Chancellor's lumi nous opening seemed to promise) a clear de cision on what has been called, in the nar rowest sense, the Law of Creeds. It prob ably rules that these solemn documents are for ever unrevisable. But this formidable quality is apparently made common to them with some of those casual or annual "testi monies" which Presbyterian Churches put in a far lower place than the Confessions they revere—and revise. What are the docu ments which bind a church, is at least as doubtful after this judgment as before. Yet, with all deductions, this was a great

decision on the law, as well as on the facts. For it rules that Westminster Confession Churches (and no doubt, therefore, all churches under the law of Scotland), so far as law can compel them, must not at their own hand change the form—in particular, the doctrinal form—in which they took ori gin, unless they have reserved powers of change far more explicit than have hitherto been thought necessary. IN The Commomvealth Law Review (Aus tralia) for August, С. Е. Weigall discusses "Industrial Arbitration and Common Law Rights," under the Australian labor laws. Of the "preference clause" he says: Under what is known as the preference clause, s. 36 of the Act, the Court is given power to direct that preference shall be given to members of an industrial union of employés, who offer their services to an employer at the same time as a non-unionist workman, other things being equal. The Arbitration Court has held, in the Breadcarters' case, that this provision does not re strict the general powers which are given in the definition of industrial matters. In that case the Court ordered that any non-union ist employé who was engaged must join the union within a certain time after he en tered upon his employment. The effect of such an order is to prohibit altogether the employment of a non-unionist workman, as such. This, it is submitted, the Court has no power to do, the general power given to the Court by the definition of industrial matters being in this respect subject to the conditions laid down in s. 36 of the Act specifically dealing with such orders. The right of an employer to employ non-unionist workmen has been further restricted by the interpretation placed by the Court upon its awards which contain a preference clause. Thus, on a summons against an employer who. had engaged a non-unionist workman because he said he thought him the most suitable for his requirements, the Court in /11 re Wild, held the employer guiltv of a breach of the preference clause, and laid