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THE Right Honorable Christopher Palles, Lord Chief Baron of the Exchequer in Ire land, whose learned charge in the recent Tal low case—O'Keeffe v. Walsh—is quoted at considerable length in Mr. Wyman's article on the Boycott in this number of THE GREEN BAG, is one of the notable figures among English-speaking judges of the present day. Not only has the Lord Chief Baron sat on the Bench for twenty-nine years, but during that long period his judicial work has shown an intellectual keenness and vigor which has given him high rank among his contem poraries on the English, as well as on the Irish, Bench. That in this late case of O'Keeffe r. Walsh the learned Chief Baron should take ad vanced ground on the boycott question is no surprise to those who remember his vigor ous dissenting opinion in Quinn v. Craig (1809, 2 Irish Rep. 667)—entitled Quinn v. Leathern in the House of Lords. In that opinion he carried Allen v. Flood to what he believed to be its logical conclusion, but ex pressed regret because he felt himself "co erced by the judgment of the House of Lords in Allen v. Flood (1898, A. C. i), to hold that the law is powerless to protect, from that which the jury has found to be the tyranny of a trades union, the sacred right of a workman to save himself and his family from starvation by the work of his hands." Nbw, however, when Allen T'. Flood has been deprived by later decisions of much of the authority which, at first, it
was supposed to have,—when, in the words of Lord Halsbury in Quinn v. Leathern, it has become "only an authority for what it actually decides"—the Lord Chief Baron has been free, in the Tallow case, to treat the questions of conspiracy and boycott with the vigor, the courage and the breadth of view which these subjects demand. His clear and logical charge has attracted much attention and approval in England; but in 'Mr. Wyman's article it is now brought for the first time to the notice of the profession on this side of the water. The United Irish League has been directly interested in the case of O'Keeffe v. Walsh in the sense that the) defendants were officers or members of the League and were sued for acts clone in pursuance of the usual plan of campaign of the League. This decision was a sharp blow at such methods; anci the inter esting query suggests itself whether the de cision has not been an important factor in making the Irish political leaders willing to accept the pending Land Bill. NOTES
THE following question and finding was put to and given by a Halifax, N. S., jury: Question: Was the illness of the said John H. Mills, and of which he died, of a temporary character? Answer: Temporary. LITTLE Marion heard her father telling about some trouble he was having with a neighbor concerning a piece of land. "He threatens to sue me," said her father. The next day the neighbor in question was com ing toward the house with a bundle in his hand. Marion saw him coming and ran ex citedly to her mother, exclaiming: "O, mamma. Mr. Brown is coming now
