international arbitration, the laws and customs of war, the Geneva Convention, and the prohibition of projectiles containing asphyxiating gas, etc., though some of the signatures are subject to unimportant reservations. But on March 15th the Dutch Ministry of Foreign Affairs was unaware of any Power having ratified the conventions. It may be added that the Arbitral Court cannot come into operation until nine States have ratified the Arbitration Convention.

Mr. Haldane's Proposal as to the Final Court of Appeal of the Empire.— In an address which Mr. Haldane, Q.C., delivered the other day to the Scots Law Society, he threw out suggestions as to what should be a composition. of the final Court of Appeal for the Empire.

He would add to them (the present members) three representative great lawyers from different parts of the Empire, giving them a sufficient but moderate salary from the Imperial Exchequer to compensate them for their general services, and leave it to the Colonies which they represented to make up the salaries to an amount sufficient to maintain the dignity and importance of the position. He would make these new Colonial representatives life peers in the House of Lords, so that they might sit there as well as at Downing Street, and he would thereby take the first step towards infusing new blood into that body, and making it a convenient Chamber for Colonial representation. In this way there would be one great Imperial tribunal sitting when necessary in two divisions, and hearing the appeals not only of Scotland, England, and Ireland, but of India and all the Colonies. The Colonies would take pride in such a body, because it would become in part their own. There was a larger view of Imperialism than that which was talked of at elections, and one which was less controversial. That view refused to recognise in the Crown and the system of Imperial defence the only features of our existence as an Empire. It might be that in the sphere of education, in the foundation which some were at present endeavouring to compass of an Imperial University, a new link could be added, but this at least Imperialists, such as he himself desired to be reckoned, held to be certain, that in the administration of justice and in the existence of a great but too scantily recognised central tribunal they had one of the most real bonds that could hold together the distant parts of the Queen's dominions in those relations which only a common heritage could give.

Injuries by Animals and the Law of Canada.-In Canada the law as to injuries by animals approximates closely to the law of France and of the Continental nations, and knows nothing of the English law of "Scienter." By Art. 1055 of the Civil Code of the Dominion, "Le propriétaire d'un animal est responsable du dommage que l'animal a causé soit qu'il fût sous sa garde ou sous celle de ses domestiques, soit qu'il fût égaré ou échappé.” On the face of it, this article imports an absolute liability; but as interpreted in the light of Art. 1053 of the Code, fault on the part of the proprietor is an essential element of responsibility. The result is that it is open to the proprietor of an animal which has committed any mischief to show that he has done everything to prevent an injury, and that no fault, negligence, or imprudence is imputable to him. In a recent case in the Superior Court at Montreal, where a stableman had been kicked by a mare which

was not vicious, but only skittish or ticklish (chatouilleuse), an ingenious. attempt was made to neutralise this doctrine by putting this dilemma: "De deux choses l'une; ou le propriétaire n'a pas pris toutes les précautions que la prudence commandait et alors il est en faute; ou il s'agit d'un animal tellement méchant que toutes les précautions imaginables pour l'empêcher de nuire sont inefficaces; et alors il est en faute par cela seul qu'il le conserve." In other words, the very fact that harm has been done postulates the existence of fault. But the Court very plainly exposed the fallacy: "Human affairs are not to be governed by syllogisms. It is no doubt true that every accident could be prevented if human beings could foresee every circumstance and event of life. Legal fault does not depend upon any such theoretical perfection of human intelligence." All that the law requires of a man is that he should exercise an intelligent foresight, but the standard of intelligence it exacts is that of the average man.

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Gang Rape in India.-Rape under the Indian Penal Code is already heavily punished. The penalty is transportation for life; but even this has been found inadequate to deal with a very atrocious form of the offencegang rape "-where a number of men join together to violate a woman. The offence, according to a minute of Mr. Justice Wilkins, is prevalent only in certain districts of Eastern Bengal, and is committed in a peculiarly brutal and inhuman manner. The perpetrators have always been Mohammedans of the lower classes. Their victim is generally a young married girl. They wait till she is left unprotected, by the absence of her husband or parents, and they then attack her, and forcibly carry her off. The motive is not always the same, at times it is revenge, at times merely the gratification of their own passions,-but the consequences to the victim are of course terrible and irreparable. The Legislative Council of India have now passed a clause for punishing with whipping (in addition to any other punishment) any member of such a rape gang who abets or commits a rape of this kind.

An English School of Law in Egypt.-By far the most interesting passage in the latest report by Mr. McIlwraith, the Judicial Adviser of the Egyptian Government, is the announcement that an English school of law has been established at Cairo. Hitherto only two languages were employed as mediums of instruction-French and Arabic; the native codes had not been translated into English, and the commentaries in use were the works of French and Belgian lawyers. Now, however, provision has been made for an English section in the Khedivial school of law on lines similar to those of the French section. Instead of being dependent solely on French commentaries and French decisions, which are "often more misleading than helpful to the student of Egyptian law, which is gradually acquiring a distinct and separate individuality of its own," an authoritative commentary in English is to be published. The English section of the school of law is, says Mr. McIlwraith, "an accomplished fact"-though, by the way, the attendance is smaller than the attendance in the French section.