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 EDITORIAL DEPARTMENT destination in a belligerent state. In Hobbs v. Henning, however, the court seem to have been of opinion that goods can only be con demned as contraband when they have been seized on their way to an enemy's port, i.e., when their transport to the enemy's country is intended to be effected entirely by water. . . I fail to see any logical distinction between the case of goods which the owner intends to send by inland navigation from a neutral place to the territory of a belligerent and goods which he intends to send thither by road or rail." INTERNATIONAL LAW (Jurisdiction in Bays). " Claims of Territorial Jurisdiction in Wide Bays," by A. H. Charteris, in the May Yale Law Journal (V. xvi, p. 471), is sug gested by a recent decision (Mortensen v. Peters, Scots Law Times, xiv, p. 227) of the High Court of Justiciary in Edinburgh, whereby " a clause in an imperial statute has been interpreted as an affirmation by the British Parliament of territorial jurisdiction, at least for the purpose of fishery regulation, over an area of water on the northeast coast of Scotland more than two thousand geographi cal square miles in extent, and bounded by an imaginary line drawn between headlands eighty miles apart. Correct as the decision no doubt was, it arrested the attention of those interested in international law by its attribution to the British Parliament of a reaffirmation of the theory of the ' King's Chambers,' which, though at one time sup ported by Kent, Wheaton and Phillimore, has found but little support from more recent English authorities like Hall and Westlake, and has been regarded by continental writers as having been abandoned as a general prin ciple by Great Britain and the United States in the second half of the nineteenth century." With this as a text, Mr. Charteris reviews the general question of jurisdiction over bays at much length and with copious citation of cases. He regards the decision itself as in evitable for it "is not the business of a British court to decide whether an imperial statute does or does not contravene a rule of inter national law." . . . "To international lawyers the interest of this case lies less in the decision than in the legislation on which it turned. And here one

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cannot help feeling that the British Parlia ment, without perhaps being fully aware of what it was doing, has made, in reference to the Moray Firth, a claim to jurisdiction to which there is almost no parallel. The near est claim is that made by Russia for purposes of war and neutrality over the White Sea, whose headlands are more than sixty miles apart, but other states are not particularly con cerned with claims which a neighbor may make over waters within the Arctic Circle." INTERNATIONAL LAW. In the American Political Science Review (V. i, p. 410) is an article on " The Recent Controversy as to the British Jurisdiction over Foreign Fishermen More than Three Miles from Shore; Mortensen v. Peters," by Charles Noble Gregory. The author criticises the doctrine involved in the decision of this case, which he contends "would make all indentations in the coast, however wide and however open, capable of appropriation by the adjoining countries and the present limitation of littoral dominion to three miles from shore, would apply solely to the extreme headlands. The fishing grounds of the world would substantially all pass into local control, a circumstance which would tend greatly to limit the freedom of the seas which ever since the voice of Grotius was lifted in its defense has grown and ought to grow." INTERNATIONAL LAW (Mexican Extradi tion). " Note Sur L'Extradition au Mexique Pendant Les Annees, 1897 a 1906," by M. P Le Boucq, in the January-February Revue de Droit International Prive (V. iii, p. 145), is an examination of the Mexican decisions in ex tradition cases. The article is to be con tinued. INSURANCE (France). The legal position of foreign life insurance organizations in France under the law of March 17, 1905, is expounded at length by an anonymous writer in the January-February Revue de Droit In ternational Prive (V. iii, p. 85), under the title " De la Condition Legale en France des Soci^tes Etrangeres d'Assurance Sur la Vie." The text of the law is appended. INSURANCE. " An Interesting Insurance Case," by F. Beecher, Central Law Journal (V. lxiv, p. 325). JURISPRUDENCE. " Possession and Own ership," by Albert S. Thayer, in the April