But it has been decided in the Court of Appeal that in this respect the operation of a deed of grant is exactly the same as that of a feoffment, and that a freehold in futuro cannot be created by a direct grant of land without recourse to the Statute of Uses; Savill Bros. Ld. v. Bethell [1902] 2 Ch. 523, 540, 71 L. J. Ch. 652. T. C. W.

The final decision of Villar v. Gilbey in the House of Lords [1907] A. C. 139, 76 L. J. Ch. 339, reversing that of the Court of Appeal and affirming the original judgment of Swinfen Eady J., seems exactly to confirm the opinion of the late Lord Justice (then Justice) Chitty in Re Burrows [1895] 2 Ch. 497, 65 L. J. Ch. 52. It was there pointed out that the word 'living' may be understood as including, in its natural meaning, a child en ventre sa mère, and will therefore include it unless restrained by the context; but that this is quite consistent with holding-as the House of Lords has now done, following Lord Westbury in Blasson v. Blasson, 2 D. J. & S. 665, 34 L. J. Ch. 18-that the natural meaning of 'born' does not include an unborn child, and the artificial extension of it to a child en ventre sa mère can be justified only by a kind of judicial charity, on the ground of apparent benefit to the child, or by some very clear indication of the larger intention. It might have been more convenient for conveyancers to have a uniform presumption, as desired by the Court of Appeal; but the distinction approved by the House of Lords cannot be said to be without substance, or to run counter to the accustomed use of language. And see Re Salaman [1907] 2 Ch. 46, 76 L. J. Ch. 419.

The consequences of Colls v. Home and Colonial Stores, now the leading case on the right to light, are still being unfolded in the reports. Ankerson v. Connelly [1907] 1 Ch. 678, 76 L. J. Ch. 402, C. A. is the last example; as the case, which at first looked complicated, was straightened out in the Court of Appeal, it does not give us any new law, but it shows the material difference made in fact when the decision of the House of Lords is applied. It seems plain, without any aid from Colls v. Home and Colonial Stores, that the occupier of a dominant tenement cannot by his own acts increase the burden of the servient tenement. Therefore, if I so alter my windows that, in the result, some building which my neighbour could have lawfully put up before the alteration is much more inconvenient to me when put up afterwards, I have only my own folly to complain of. Then, what could he have put up? Since Colls v. Home and Colonial Stores abolished the doctrine of a quasi property in a definite amount of light the burden is on me to show that the new building would have amounted to a substantial privation of my light even before the alterations. Hence a man

who alters his own ancient lights must, as the law stands at this day, consider very carefully the risk he may be incurring of leaving himself without protection.

A liquidator has under s. 131 of the Companies Act, 1862, a power of sanctioning transfers of shares after a voluntary winding up; but such a power, involving as it does the release of contributories, is one which clearly calls for great circumspection. So little of this commodity was forthcoming in the case of In re National Bank of Wales, Massey & Giffin's case ([1907] 1 Ch. 582, 76 L. J. Ch. 290), that two successive transfers to infants were actually passed by the liquidator. The interest of the case centred in the first of these. It was a transfer to an office-boy. His principals-a firm of Cardiff stockbrokersfollowing an apparently well-established practice at that centre of industry, preferred, while keeping the control of the shares, to be represented on the share register of the company by the officeboy. There is no objection in law to this arrangement; indeed it is a highly convenient one if only the company or the liquidator can be got to assent to it; but it is distinctly disadvantageous to the company; and the liquidator, having at last awakened to this fact, sought to retrieve his false step by asking the Court to put the stockbrokers on the register, on the ground that they had taken the shares under an alias. This argument has been more than once successfully used. In Pugh and Sherman's case (L. R. 13 Eq. 566) a man applied for shares in the name of his married daughter, who signed the application, without knowing what it was, by the direction of her father. In Richardson's case (L. R. 19 Eq. 588) a man took a transfer of shares for which he paid in the name of his infant son, and signed the transfer in the son's name. But in each of these cases the Court was able to discover a contractual relation between the parent and the company, without which, as Jessel M. R. long ago said, no one can be made a contributory. But where, as in Massey & Giffin's case, a person buys shares from a registered holder and takes a transfer of them in the name of a nominee approved by the company, what privity is there between the company and the buyer entitling the company to put the buyer on the register? The buyer is a mere cestui que trust of whom the company can take no official cognizance. The obvious moral is that companies-and liquidators-must take care who they accept as transferees.

A receiver and manager appointed by the Court in a debenture holders' action is personally liable on contracts entered into by him in carrying on the business: he accepts the appointment on

those terms. At the same time he is entitled to be indemnified out of the assets for all expenses properly incurred. This phrase 'properly incurred' is one of those which come glibly from the tongue, but which in their practical application involve the exercise of a very nice judicial discretion, as In re British Power Traction and Lighting Co., No. 2 [1907], 1 Ch. 528, 76 L. J. Ch. 423, illustrates. The receiver and manager there in the course of carrying on the business-which included the manufacture of motors-asked and obtained the sanction of the Court to borrow a sum of £3,000. That proved insufficient, and thereupon the receiver and manager went on, without getting the leave of the Court, to incur further liability by completing some motor cars which had been ordered from the company, by preparing others for a show, and by borrowing from a bank a sum of £1,500, and in respect of all this expenditure he claimed to be indemnified out of the assets. A part of his prayer the Court granted-but a part, and the greater part, it dispersed into thin air. A receiver and manager may very properly expend money in completing an order. It is bound to bring in a safe return, in the shape of the purchase money. But exhibiting at a show is another matter. It is speculative expenditure, and such expenditure the Court has long ago said it will not sanction. The extra £1,500 borrowed involved more difficulty because the moneys. were, speaking generally, spent on items such as wages and rates, necessary to carrying on the business. Yet the Court, with Rhadamanthine severity, disallowed the claim because its leave had not been first obtained. The principle of the Court's control must be vindicated whatever the consequences to receivers. It is a harsh but, perhaps, salutary lesson.

A domestic fowl is not a dangerous animal which the owner is bound at his peril to keep from doing mischief, and it seems also that it is not like a man's cattle, which he is bound by a very ancient rule of the Common Law to keep from trespassing. Such is the law to be collected from Hadwell v. Righton [1907] 2 K. B. 345, of which the facts were peculiar. The defendant's fowl, being on the highway, was frightened by a dog not belonging to either party, and thereupon flew into the spokes of the plaintiff's bicycle, which he was riding lawfully and with due care. Common experience shows that fowls try to get run over, but not that they habitually fly into wheels, and this was not an accident of a kind which the owner could foresee. The plaintiff would seem to be without remedy, for an action against the owner of the dog would equally fail on the ground of the damage being

too remote.

In the May number of the Law Magazine and Review is a short and profitable article by Mr. J. Andrew Strahan on 'Some recent copyright decisions.' It should be consulted by any one who still feels doubtful about Macmillan & Co. v. Dent. With regard to Ward, Lock & Co. v. Long [1906] 2 Ch. 550, 75 L. J. Ch. 732, we are not at all sure that Kekewich J. did hold the first assignment to be equitable. At all events the argument which Mr. Strahan thinks ought to have prevailed, namely that an assignment in writing, made for value and without notice, carried a superior legal interest, was quite distinctly presented to the Court (p. 556 of the L. R. report). It may be considerable' whether the distinction between legal and equitable estates should be rigorously applied to such peculiar incorporeal things as copyright.

The January number of the English Historical Review contains an interesting note by Mr. W. H. Stevenson, entitled 'A contemporary description of the Domesday Survey.' This description is contained in a work of Robert, Bishop of Hereford, 1079-96, preserved in two Bodleian MSS., and never printed. The book is a critical discussion of the current 'Dionysian' era of the Incarnation which has survived this and other objections by the fact of being established in the common use of Christendom. Incidentally Robert mentions that he is writing in the twentieth year of King William, the year of the 'totius Angliae descriptio.', 'This strongly supports the evidence of the Peterborough chronicle and of the second volume of the Domesday Book, that the year of the Survey was 1086, and should dispel all doubts as to whether that was the year of the actual survey or merely of the codification of the returns.' The bishop also informs us that the returns were checked by supplementary visits of special commissioners. For the text and further critical discussion the learned reader must consult Mr. Stevenson's valuable paper at large.

ERRATUM.

In January number, p. 45 above, line 15, for diverted' read 'directed'.

It seems convenient to repeat in a conspicuous place that it is not desirable to send MS. on approval without previous communication with the Editor, except in very special circumstances; and that the Editor, except as aforesaid, cannot be in any way answerable for MSS. so sent.

LEGAL EDUCATION IN LONDON.

[The substance of an Address delivered at the opening of the Law Lectures of the University of London: Lord Alverstone C. J. in the chair.]

E are inaugurating to-day a new scheme of lectures, part of a larger scheme, the object of which is to combine the teaching resources of University College, King's College, and the London School of Economics. We are greatly indebted to the Professors concerned for the help they have given in carrying out the plans of the University: I trust that you, who are students, will find that your opportunities have been extended, and that, in every department of legal study, the best teaching has now been made accessible to all. You will, I hope, agree with me in saying that a University which possesses a Faculty of Law is bound to make adequate provision for the subject: a Faculty without a School would be nothing more than a degree-giving machine. We have taken one considerable step towards the formation of a School of Law; but much remains to be done. We still have to bring our teachers together, to make them feel that they are members of one body; and for my own part I think the problem of co-operation will not be solved until we have in this neighbourhood a centre or centres of legal study, where teachers may meet for consultation, where teacher and student may meet for that informal instruction which many of us have found more profitable than set lectures. The most important feature and the chief attraction of such a place ought (we suggest) to be a good library, maintained for the use of students, and kept open to a fairly late hour of the evening. Now, if the University is to provide us with an institution of this kind, the financial difficulties will be great, for we should like to find a home within a convenient distance of the Law Courts-that is to say, in a part of London where land is measured. by the foot, and sold at prices which stagger the confidence of academic reformers. Sir John Macdonell and I have framed a few modest proposals, but we must leave it to the higher powers to consider the question of ways and means.

Even in the Universities, law must be regarded as a professional subject; it is also a subject of much general interest, but we are so successful in concealing its attractions from the public that layinen seldom venture into our domain. There is, indeed, a genuine and even an eager demand for lectures on topics which are connected