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 EDITORIAL DEPARTMENT some day a book will be written which will claim for its special field " Legal Acts; their Formation and Interpretation," and will demonstrate that the subject is as much en titled to a separate treatment as " Contracts" or " Corporations," a claim, indeed, which our Continental brethren, more given to juristic analysis than ourselves, have long ago con ceded, even in their Codes. Mr. Gulson is also under no illusions as' to the true nature of an extra judicial admission; it is (pp. 402, 404) merely " a statement made by the party against whom it is offered by his adversary in a legal trial; " moreover, it is merely " an evidentiary fact." This ought to help banish the ancient unthinking phrases of Starkie and Greenleaf, which still becloud our judicial opinions, though wholly inconsistent with the rules of law. Incidentally, Mr. Gulson here adds some just comments (p. 412) on the rule in Slatterie v. Pooley. There are other good things which space forbids our noticing, on estoppel (p. 422), burden of proof (p. 445), best evidence (pp. 450, 452), res inter alios acta (pp. 457, 461), res gestae (pp. 466-468), and opinion (pp. 470, 473). We trust that the science of the subject in England will be advanced by Mr. Gulson 's wholesome criticisms. J. H. W. JURISPRUDENCE (Mohammedan). The third and last installment of "A Historical Sketch of Mohammedan Jurisprudence," by Abdur Rahim, appears in the April Columbia Law Review (V. vii, p. 255). It deals with the " Jurists " who gained authority after the death of the Prophet, the modern writers, and the British Indian courts. JURISPRUDENCE (The Spanish Code). "A Spanish Object-Lesson in Code-Making," by Charles S. Lobingier in the April Yale Law Journal (V. xvi, p. 411) is a brief and highly eulogistic article on the Spanish Code of 1889, which is in force in Cuba, Porto Rico, and the Philippines. The author, who is himself a judge of the Court of First Instance in the Philippines, says of it: " When it first came to the attention of critical American judges and lawyers in our new possessions they were amazed at its comprehensiveness and com pleteness — charmed with its clearness, con ciseness, and simplicity. They, who were wont to engage in the tedious and reason

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stifling process of pursuing, through the maze of precedent, with the lame assistance of cumbrous digests, voluminous treatises, and multitudinous reports, some fine point in the law of contracts or real property, found in this brief Spanish Code, smaller than almost the least of American text-books, a logically arranged group of principles from which the law applicable to a given case could be de duced rationally and with little difficulty. Coming at an epoch when business interests as well as the legal profession are beginning to demand relief from "The lawless science of our law The Codeless myriad of precedent," this discovery of the achievement of the hitherto unappreciated Spaniard is most timely and serviceable. It is one of the far-reaching consequences of the Spanish-American War which was never foreseen and is even now little suspected. Much has been said and rightly of the improvements of the courts of our insular possessions through the introduc tion of the simpler and more practical Ameri can system of procedure. The benefits will not be altogether one-sided if through this contact of legal systems the American people shall learn the merits of the Spanish Cddigo Civil and from it the feasibility and gain of codifying their private substantive law. JURISPRUDENCE. " Conformity of Legal Decisions to Ethical Standards of Right," by A. G. Tibbetts, Canadian Law Review (V. vi, p. 141). LABOR LITIGATION. Jeremiah Smith concludes in the April Harvard Law Review his valuable article on " Crucial Issues in. Labor Litigation " (V. xx, p. 429). In the previous installments general propositions as to the requisites for justification were stated; in the present one these tests are applied to thirteen hypothetical cases as Judge Smith conceives they must be worked out. These disposed of he takes up the unsettled ques tion, " Whether bad motive operates as a rebuttal of an otherwise sufficient justifica tion?" On grounds of public policy the author thinks it should not so operate, "as in fact personal enmity is very seldom the real motive in labor disputes, and in the only cases where it would be of importance, those where