EDITORIAL DEPARTMENT the common law and equity expand to meet all practical needs." POOR LAWS (England). "The Consoli dation and Amendment of the Poor Law Statutes " is advocated by Lewis Sinclair in the February Law Magazine and Review (V. xxxi, p. 147). This again calls attention to abuses of the English statutes which have re sulted in a great increase in pauperism due, the author thinks, to a multiplicity of authori ties, a multiplicity of acts, orders, and legal de cisions, an obsolete law of settlement, and wasteful administration. PRACTICE (Imprisonment for Debt). In the February Law Magazine and Review (V. xxxi, p. 129) Charles M. Atkinson produces startling evidence to show a great increase in imprisonment for debt in modern England, under what we call poor debtor process, which the author regards as due to a failure to ad minister the law in the spirit in which it was framed. Personal service not being required the debtor frequently has no notice of the proceeding. It has not been required that his means of payment shall be strictly proved. The result is an expansion of small local credits and the support of large numbers of working men by the public. PRACTICE. "Execution of Decrees Against Holders of Impartible Estates," Aladras Law Journal (V. xvi, p. i). PROCEDURE. "The Plea of Set-Off," by Satya Chandra Mukerji, Allahabad Law Journal (V. iii, p. i). PROPERTY. "Alien and Corporate Ownership of Land in Texas," by Hon. M. H. Gossett, American Lawyer (V. xiv, p. 66). PROPERTY. " Intermediate Landholders and the Madras Rent Recovery Act," by P. R. Ganapathy Aiyar, Madras Law Journal (V. xv, p. 375). PROPERTY. "The Rule against Perpe tuities," by John Chipman Gray, second edi tion in one volume. Boston, Little, Brown & Company, 1906, pp. xlvii, 664. If we may judge by the way the first edition of this work has been received, the second edi tion will be welcomed by the Bench and Bar of both England and America. The ideal set for attainment in the original execution of this work and the manner in which that ideal has been fulfilled, has made the first edition during twenty years a constantly increasing
241
book of authority both here and in England. It has been in constant use not alone as a means of finding authorities, but as guide to principles. Indeed the admirer of Professor Gray's work observes with the greatest satis faction and pleasure that in two recent Eng lish cases — In re the Trustees of Hollis Hos pital [1899], 2 Ch. Div. 540, 552, and In re Ashforth's Trusts, 21 Times Law Reports 329, 331 (1905) — eminent English Chancery judges have expressly adopted Professor Gray's views on controverted points as against the positions taken by English authors whose opinions Engish lawyers and judges have al ways held in great respect. In the first of these cases Professor Gray's opinion was expressly preferred to that of Mr. Challis, and in the second to that of Mr. Joshua Williams. The important additions to this work con sist of a further word on whether determinable fees can exist since the Statute of Quia Einptores (§31 et scq. and Appendix E, §§774, 788); an Essay on Future Interests in Personal Property contained in Appendix F, §§789856 (supplementary to §§71-97); the Mean ing of Perpetuity as an attempted restraint on the barring of ap estate tail, §§i4ia-i4if; an interesting answer in Appendix G, §§857— 893, to the effort of the New Hampshire court to get round the doctrine of Leake v. Robinson (supplementary to §§373-374); two other appendixes on Gifts to Indefinite Persons for non-Charitable Purposes, and Conversion and the Rule against Perpetuities. Chapter IV on Postponement of Enjoyment and the Rule against Perpetuities (§§n8a1213) has been entirely rewritten. The most interesting of the new problems dealt with appears in §izib. There the learned author puts the case of an immediate vested bequest to the grandchildren of A,1 a living person, to be paid to them at twentyfive. He supposes that there is one grand child in esse not yet four years old. He says "Here the number of the class may not be determined till too remote a period, the Rule 1 The actual language used by the learned author is " testator" instead of "A," but the case actually discussed would require the limitations to be either to the great-grandchildren of the testator or to the grandchildren of " A," the living person at the testator's death.
