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 THE GREEN BAG or concurrence into unpleasant relationship with the bank as one of its customers. When the note referred to reached them the damage complained of had in part been done. When three days later they learned that their sig nature to the note in question had been forged the whole damage had been done, and yet, in consequence of subsequent silence, they were compelled to pay the note in full and thus make full reparation for the entire damage. As the damages assessed were neither ex emplary or punitive, the judgment can be defended only on the ground of the applica tion of a rigorous rule of evidence, which ex cludes a finding of the actual loss sustained by the plaintiff and places the person relying upon the estoppel in a better position than that which his own initiative materially as sisted in generating. In fact, the estoppel goes to the extent of preventing an adjustment of the damage actually incurred or of ascertain ing in how much worse condition the plain tiff has been placed by reason of the conduct of the one sought to be estopped. K EVIDENCE. " Photographs in Evidence," by J. C. M., Law Notes (V. ix, p. 165). EVIDENCE (See Practice). FEDERAL COURTS. " The Jurisdiction of Federal Courts in Actions in which Corpora tions are Parties," by Hon. Jacob Trieber, American Lawyer (V. xiii, p. 477). HISTORY. " The Land of Newfoundland," by Alex. J. W. McNeely, K.C., Canadian Law Review (V. iv, p. 539). A collection of an cient rights and customs of its settlers. INSURANCE. "Life Insurance: The Abuses and the Remedies," by Louis D. Brandeis, Policy-holder's Protective Commit tee, Boston, 1905. INTERNATIONAL LAW. Theodore J. Grayson, in the November American Law Reg ister (V. liii, p. 672) discusses " War in the Orient in the Light of International Law." Among other suggestions he insists that " fair play and the business interests of neutral na tions demand that a definite time shall be fixed by the belligerents themselves as the startingpoint of their controversy, and the only accu rate and satisfactory way of fixing such time is by some kind of a declaration of war made prior to any military or naval operations what soever."

He thinks that the restrictions by Japan on the newspaper correspondents were justi fied in the present status of the law, though Japan probably exaggerated the necessity therefor. He believes that the correspon dents should be neutralized as the surgeons and chaplains have been, for he thinks " that the world has a right to know the principal events of a great war just as they take place." In future wars wireless stations should be treated like the ordinary telegraph and cable lines by belligerents. INTERNATIONAL LAW (Arbitration). In the December Michigan Law Review (V. iv, p. 92 ) W. P. Rogers writes of " War, Arbitra tion and Peace." He forcibly presents the unanswerable analogy between private com bat and international war. He shows by statistics the tremendous burden of modern wars, and what might be done with the money now spent in preparation for war. He re counts the history of international arbitra tion, and shows the present status of the authority of the Hague Court in this respect. INTERNATIONAL LAW (History). A commentary on the relative importance and achievements of the great writers on inter national law by Edwin Maxey entitled " The Development of International Law " appears in the December American Law Review (V. xxxix, p. 815). JURISPRUDENCE (Custom). "Custom ary Law in Modern England " is the title of an interesting article by W. Jethro Brown in the December Columbia Law Review (V. 5, p. 56). He contends that custom will neces sarily be a source of legal rules since the offi cial agency for meeting the needs of new regulations will necessarily be imperfect. After calling attention to various views as to the relation of custom to law and as to the tests by which you may know a custom that is law he says: "The general conclusion at which I have arrived may be expressed in a sentence. When judges, in applying a custom which is not yet judicially authenticated, declare the custom to have been law previously to the decision, they are merely displaying a special form of the fiction of judicial incompetence. In the relatively developed character of modern institutions, more especially in regard.