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THE GREEN BAG

PRACTICE. "Finality of the Award — and of the Decree Passed upon the Award," by D. C. Banerjie, Allahabad Law Journal (V. iii, p. 131). PRACTICE. " Practice in the Municipal Court of Chicago," by Hiram T. Gilbert, Illi nois Law Review (V. i, p. 94). PROPERTY. " Third Parties Consent in the Law of Alienation of Property in India." by S. Varadachariar, Madras Law Journal (V. xvi, p. 83). PROPERTY (Restraints on Alienation). "Vested Gifts to a Class and the Rule against Perpetuities," by Albert Martin Kales, in the June Harvard Law Review (V. xix, p. 598), is an analysis of a problem put by Professor Gray in the second edition of his Rule against Perpetuities, where he supposes an immedi ate vested bequest to the grandchildren of a living person to be paid to them at twentyfive. In England such restraints on aliena tion are invalid. "The result reached by the English cases is simply the establishment of a special rule — entirely distinct from the Rule against Perpetuities — limiting the extent to which restraints on alienation, usually valid, may be created. In the same way, when you come to an American jurisdiction where Clafliri v. Claflin is law, it becomes absolutely necessary to put some limits upon the length of time that the trust of an absolute indefeasible equitable interest may be made indestruc tible. The direct authority of the English cases which have dealt with the restraints on anticipation attached to a married woman's estate, and the suggestion of the courts of Massachusetts, Illinois, and Pennsylvania, all indicate that the rule will probably be well settled here that language which, if carried out as expressed, may possibly cause the trust of an absolute indefeasible equitable interest to be or remain indestructible at a time beyond the period of a life or lives in being and twentyone years, will be unenforceable. It cannot of course be too emphatically stated that this is not the Rule against Perpetuities, but a new rule limiting the time that the trust of an absolute indefeasible equitable interest may be made indestructible."

The interest in the article is enhanced by a delightfully amusing commentary in a note by Professor Gray. PROPERTY (Torrens Law). An interesting account of the operation of the Torrens law for " Land Registration in the Territory of Hawaii," by Philip L. Weaver, appears in the May American Law Review (V. xl, p. 321). He concludes that, — "The system of land registration has proved itself a practical working success, well adapted to the needs of a rough country, poorly sur veyed, where titles are often difficult to ascer tain. "The lawyers are its greatest advocates, and bankers, incorporated estates, and home own ers are registering their titles, as they acquire new lands." PUBLIC POLICY. " Judge-Made Ignorance in Pennsylvania," by Florence Kelley, Chari ties and the Commons (V. xvi, p. 189). RAILWAYS. American Street Railway Re ports (Annotated). Vol. iii. Edited by Frank B. Gilbert, of Albany Bar. Published Albany, N. Y. Matthew Bender & Co. 1906. The introduction of electricity as a motor power into street cars has not only revolu tionized street transportation, but it has diversified the practice of law by developing a new line of decisions applicable to the new circumstances and conditions; so that now in the case of street railways, as in other branches of industrial and commercial enterprise, like admiralty and insurance, there is a special ized body of law which defines the legal status of street railway companies in relation to the public in the use of streets above and below ground and to passengers, employees, travellers, municipalities, and others through out the gamut of street railwaydom. Is is always to the inestimable advantage of the practising lawyer to have at hand re cent decisions in his own and other jurisdictions with which he has to deal; and in view of the great number of decisions made each year relating to street railways, it is very difficult to discover and keep at hand such cases as will be of service. By this system of reports the editor of Street Railway Reports has minimized this difficulty.