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 EDITORIAL DEPARTMENT that makes the work of great value to the practitioner and student. Where there is conflict of authority what appears to the author to be the true doctrine is worked out in the text, while the position of each state with respect to the doctrine discussed is given in the footnote. The commentaries might, with advantage, have taken a fuller view of the English cases on the subject, and it would have been well to discuss the so-called Massa chusetts rule established in Litchfield v. Hutchinson, 117 Mass. 195, adopted in Indiana, Minnesota, Wisconsin, and New Hampshire, and criticized in Boddy v. Henry, 113 Iowa 462. The plan of the work is much to be commended, the entire field seems to be fairly covered, and alike for reading, study, and consultation these volumes offer every reasonable facility. W. E. 'WALZ. University of Maine School of Law.

TORTS. " Cheating in Indian Criminal Law," by Satya Chandra Mukerji, Allahabad Law Journal (V. iii, p. 113). TRADES UNIONS. The English cases on "The Law Relating to Trades Unions" are collected in the May Law Magazine and Review (V. xxxi, p. 272) by J. A. LovatFraser. TRADES UNIONS. " Incorporation of La bor Unions," by Caroll G. Waters, Albany Law Journal (V. Ixviii, p. 68). TRADES UNIONS. A criticism of the Eng lish cases relating to " Trades Unions and Trade Disputes," by F. A. Umpherston, appears in the April Juridical Review (V. xviii, p. 45). While he approves of the " Taff Vale " case as in accordance with reason and common sense, he finds that by its subjection of insurance funds of the unions to actions for damages, it is dangerous in effect. He doubts the possibility of overruling it, but approves of the suggestion of a definition of agency with reference to trades unions. He regards the picketing decisions as the result of a system of applying to acts of parliament canons of construction which exclude consider ation of historical growth or of political movements. He regards as still more serious the decisions regarding the common law of conspiracy. These are criticised as being "based on statements of law so vague and

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indefinite, so different and so fluctuating as to form not a consistent elucidation of any legal principle but a congeries of ill fitting dicta which appear to most people incoherent and unintelligible. "And the fact that the circumstances in which the unions act differ from those sur rounding other forms of trade competition has been used in the recent decisions, not as a reason for adapting the law of conspiracy to all legitimate forms of rivalry in trade, but for narrowing the scope of what is to be held lawful, and so tightening the cord round the neck of trade unionism. "It has been said that a combination to caiise loss to another in his trade or calling is priina facie unlawful. But all the judges admit the possible existence of something they call ' sufficient justification ' or ' a just cause or excuse ' for the conspiracy. What will and what will not amount to such justifi cation or excuse none can say; but all agree that if in any case they find this unknown and undefined consideration, the action will not be allowed to succeed. "If that is the law, it is time that Parlia ment took the matter in hand and declared in definite and intelligible terms what may be done without being considered an undue interference with the rights of others, and what may hot. Otherwise, the only possible method of procuring the fulfilment of trade union agreements, whether with their own members or with outsiders, will disappear. At present that can only be done by bringing such pressure to bear as is likely to cause loss to the default ing party, and that without infringing any legal right which he is entitled to maintain in a court of law." TRUSTS (Capital and Income). The rule of trusts regarding the apportionment of pro fits between capital and income as laid down in England in the case of Howe v. Earl of Dartmouth is held to be no longer the law of Scotland in an analysis of a recent Scotch decision in the April Juridical Review (V. vxiii, p. 30), by Will C. Smith, entitled, " The Rule in Howe v. the Earl of Dartmouth." TRUSTS (Charitable). " American v. Brit ish Ecclesiastical Law," by Epaphroditus Peck, in the April Yale Laiv Journal (V. xv, p. 255) discusses the " Free Church Case in