THE Outcome of the arguments in the recent case went to show that the value of each individual debenture must depend on the incidents attending and the method of its execution. One thing is certain, that a debenture-holder, unless the document which he holds expressly states the contrary, is in no better position than an ordinary creditor, and must rank as such. It is not pretended that this was the intention of those creating or of those taking debentures. Another fact is clear-that a debenture is not created by simply affixing the name. It becomes clearly, then, the duty of those who are the holders of debentures to examine carefully the nature and wording of each particular document, and satisfy themselves whether they have got what they fancied they were getting-that is to say, a preferential security; or whether, after all, they have not paid too dearly for what are but admissions of debt, and in many instances cannot be worth more than the paper on which they are printed.

As the average investor is a peculiarly indolent individual, content to believe all he is told, from sheer lack of energy to investigate the truth, or the reverse, of statements, for himself, we commend this case to the careful attention of all who are not thoroughly posted up in such matters, as the information which it elicited was undeniably of the first importance.

We have received the following communication, and shall endeavour to find an early opportunity of referring to Mr. Dunderdale's interesting address at some length

MANCHESTER LAW STUDENTS' Debating Society,
LAW LIBRARY, Kennedy STREET, MANCHESTER.
June 22, 1888.

LAW STUDENTS' CONGRESS, 1888, OLD HALL,
LINCOLN'S INN.

To the Editor of PUMP COURt.

He

An action was recently brought by a member of the Salvation Army against the Governor of Strangeways Goal, Manchester, to recover damages for alleged false imprisonment. The case was Henderson v. Preston, and it appeared that on the 24th of August last, Henderson was convicted at Rochdale of obstructing the public highway, and was fined 5s. and costs, with the alternative of seven days' imprisonment. On the 25th he was received at Strangeways prison, from which he was released on the 31st. now claimed that he had been imprisoned for eight days instead of seven, as the sentence began to run from the time of his arrest on the 24th. The governor submitted that the law and practice for the last 40 years had been to count the imprisonment from the day on which the offender was actually lodged in prison. Justices Stephen and Manisty took this view and gave judgment in favour of the defendant, pointing out that the order of the magistrates was that Henderson should be received in gaol and there be detained for the space of seven days, which meant that he was really to be detained within the prison walls for seven days.

SOME useful hints may be obtained from an interesting lecture on Trustees' Investments, recently read before the Manchester Accountants Students' Society. After referring to a trustee's liability in case of uninvested trust funds, the lecturer went on to remark that a trustee should, however, retain sufficient funds to answer liabilities, and for this purpose make temporary deposits with banks of good credit of cash necessary for the purposes of the trust, and should also deposit the income in a bank until required. Money might be left in the bank pending investment, but not for a very long period; and it was necessary for a trustee to keep a separate banking account for trust purposes. A trustee could only delegate his duties when compelled to do so from necessity, or when, by doing so, he was acting in conformity to the common usage of mankind in such

cases, and according to this rule he might delegate his powers or duties to a stranger or to his co-trustees or cotrustee. Of course delegation is permitted when authorised by the will or settlement, but a duty which, involves the exercise of a special personal direction, such as the choice of investments, could not be delegated. A trustee in selecting an investment should have two objects in view-one the security of the capital; two, the return in the shape of interest. He should also consider if the principal would be liable to depreciation, what annual return he would obtain, what facilities would exist for realising the capital, and whether there would be any liability beyond the sum invested. As a general rule a trustee has power to vary investments, though curiously enough the usual Trustee Acts do not give any power of varying them.

A TRUSTEE cannot lend money on personal credit or on personal security; and as to the stock or shares of a private company, a trustee should never invest in them, inasmuch as the capital of such a company is embarked in trade and is liable to be reduced by losses or to be entirely traded away. The articles of such companies too often contain special provision which would render the company's shares an improper investment by trustees; and even where authorised by the trust instrument, the trustee should have regard to the financial position of the company or the conditions on which its shares are held. A trustee cannot, unless specially authorised, hold a stock certificate to bearer, though where a particular authorised stock is issued in no other form a trustee might hold such stock. Should the trust investment require investments to be made in the name of the trustee he would not be able to hold certificates of this description, though it might be otherwise if investments were required to be in his name or under his legal control.

Up to quite recently, indeed at the present moment, trademarks in Austria have only received protection from the common law, but now a Bill has been introduced into the Austrian Chamber for their protection by the imposition of heavy penalties for any infringement. This Bill, however, deals only with marks which are strictly proprietary, and takes no cognisance of false descriptions of goods; if it is passed, a stop will be put to the imitation of foreign trademarks, which is now regularly carried on by certain manufacturers and others in Vienna and Pesth. One of the provisions of the Bill prohibits the placing of any trademark upon an article, except by the actual producer of the article, and he only has the right to use his own name and can put it only upon such goods as he himself manufactures. In the Hungarian Parliament a somewhat similar Bill is now being discussed, but it follows more closely the English Merchandise Marks Act.

EVERYONE knows now-a-days what waste is, more especially as recent legislation has enacted many important provisions on the subject. A somewhat unusual case on this question was recently tried in the Chancery Court of the County Palatine of Lancaster. It appeared that a tenant, after having stipulated not to do so, had ploughed up a twenty years' pasture, and for this he was sued for damages for "waste." He submitted that the act was one of good husbandry, and the evidence that he adduced on his behalf supported this view. Judgment was given for him, and he was also awarded damages in consequence of loss occasioned by his agreement to discontinue ploughing pending the action. In an agricultural case such as this it is imperative that a judge, who has probably no special knowledge on the subject, should rely on the witnesses and be, indeed, almost in their hands. So it was here, though had the case been tried anywhere else than in Lancashire, it would probably have been decided that it would be waste to plough up an old pasture, even though it were a bad one.

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PUMP COURT.

The Temple Newspaper and Review.

EDITORIAL, ADVERTISEMENT AND PUBLISHING OFFICES, 33, Exeter Street, Strand, W.C.

JUNE 30, 1888.

Pro Lege.

THE KING MOVES.

It would seem, after all, that the manifestoes of Wilhelm II. to the German people and the Reichstag were but mechanical things, inspired from without, and that the promise of peace which all the world hoped that they could read in them was little better than an illusion. Acts speak more plainly than words. The King has moved, and, we regret to say, his very first act is of an aggressive, truculent character, in accord with the reported disposition of the man, rather than in harmony with the pacific policy which would, without doubt, have actuated his father, had he been spared to govern the Empire created by Wilhelm I.

Nothing could well be more ungracious, nothing, certainly, more indiscreet, than the expulsion of the French journalists, MM. Ransom and de Bonnefon, from Berlin, at a time when every word and the minutest action of the young Emperor is being watched with microscopic eyes, ready to exaggerate any tendency towards war which it might display. Even had the provocation offered by these two newspaper men been grave and well-nigh intolerable, a policy of expediency should have compelled the Emperor to have quietly ignored anything that might have been said or done, at all events until such time as he had been enabled in other ways to satisfy his people and the world that he had no belligerent intentions. With the whole of Europe in a condition of alarming inflammability unparalleled during the present generation, only waiting for the dropping of a match to burst out into a conflagration which may mean-which, in truth, must mean-a hideous sacrifice of life and treasure, and the throwing-back of civilisation for a decade, this headstrong young monarch seizes the very earliest opportunity which presents itself to insult, in the persons of two Parisians, the nation which is regarded, not unreasonably, as the hereditary foe of Germany. Nothing could be more unfortunate, nothing of more evil portent, in the strained condition of European affairs which at present prevails. No wonder that thoughtful men are becoming infected by the panicmongers, and are beginning to admit that with the accession of Wilhelm II. to the German throne it behoves all the nations to put their houses in order, and, while hoping for the best, to be prepared for anything that may happen-even the worst.

We had hoped, in common with all but the persistently pessimistic, that the late Emperor had at all events lived long enough to set his mark upon his son's heart and upon the policy of his successor. We had hoped, too, that the shadow of death would have blotted out the minor differences of feeling and opinion which, regrettably enough, had been known to exist between the new Emperor and the

Dowager Empress Victoria. But it would seem very much as if the noble example of his father and the exalted life and supreme devotion of his mother, and all the sublime lessons of the last few months of suffering and suspense so nobly borne, were to prove powerless against the arrogant, aggressive, we had almost said revengeful instincts of this boyEmperor, whose youthful folly and stubborn vanity may yet precipitate a terrible war.

For what, let us inquire, were the crimes of MM. Ransom and de Bonnefon? Have they been guilty of writing inflammatory or insulting articles against the beloved Fatherland, or inspiring their countrymen with sentiments of envy, hatred, or malice against the Germans? Nothing of the kind. In M. Ransom's case he is apparently ignorant entirely of the nature of his offence. All that has been told him is, "You are important"-a flattering tale, per se, but unpleasantly qualified by expulsion, the sentiment of which must always be offensive to a man of spirit, even though the act may be carried out with perfect politeness, and may amount, as M. Ransom patriotically puts it, to a removal from the hell of Berlin to the heaven of Paris. M. Ransom's own idea of the cause of his expulsion is that he is regarded as a secret agent of the French Ministry of War; and further that he once reported in his journal some remarks made by a Russian officer, uncomplimentary to the German army. In M. Bonnefon's case a full official statement of the reasons for his expulsion were afforded him. M. Bonnefon published in the Gaulois, in April last, a personal description of the young Emperor's great friend, the Arch-duke Rudolph, the Austrian Crown Prince, and drew "odorous" comparisons, to the disadvantage of Wilhelm II., and so is held to have calumniated the new Emperor. In the second place he is accused of having kept up secret and intimate relations with Sir Morell Mackenzie; and thirdly that he has written a series of articles on the affairs of Alsace and Lorraine, and dedicated them to the Dowager-Empress Victoria.

Now the unpromising spirit which breathes in an order of expulsion based upon such grounds as these displays all the elements of danger most distinctly to be dreaded. We can read in the expulsions, as illumined by the sickly light now thrown upon them, the overweening vanity, the fanatic militarism and the innate hatred of the English and of the liberal-minded party of which his mother is the most illustrious representative in Germany, in which lie dormant all the seeds of a war, engaged in from no worthy motives, and therefore likely to produce all the more disastrous results. The incident comes as a surprise and something of revelation, and as a most lamentable and peril-fraught specimen of each.

It is easy to understand that MM. Ransom and de Bonnefon treat the affair with nonchalance, and even with secret approval, for the journalist is not yet born who would not be rather glad of such an amount of notoriety as will fall to their share during the next few days or weeks or months, as the case may be. But those who look beneath the surface are gravely concerned at the incident, and dread lest it should prove the "small spark" from which will presently burst a "great fire;" as it certainly contains evidence that the prophets of evil who predict war of the wilful and wanton kind from the pugnacious instincts and personal vanity and obstinacy of the young Emperor have some reason for their dismal prognostications. The one element of hope is that Wilhelm II. is very young. "Grizzling hair the brain doth cool," but the mischief which may be wrought in the years which must intervene before the new Emperor attains the calm wisdom of "forty years," may be world-wide and irreparable.

THE STARTLING DISCLOSURES FROM INDIA.

WE have no desire to harass the Government, and therefore we shall give them time to make their explanation before dealing further with this subject. In the meantime we are content to leave to the careful attention of the Executive the important and significant facts which we have already revealed.

THE TEMPLE NEWSPAPER LAW

REPORTS.

COURT OF APPEAL.

CHARLESTON V. LONDON TRAMWAYS CO. LIMITED.-Tram Conductor.-Arrest of Passenger for passing Counterfeit Coin.Mistake.-Liability of Company for Acts of their Servants.-33 & 34 Vict., c. 78, ss. 51 and 52.-Powers of Company.-Scope of Servant's implied Authority.-Conductor of one of defendant company's tramcars received from plaintiff a half-crown in payment of fare and gave 2s. 4d. change. On plaintiff desiring soon afterwards to be put down, conductor refused and took plaintiff to police station, and charged her with giving a bad half-crown to him. The half-crown was in fact a good one; the police inspector saw this, and plaintiff was at once released. Plaintiff brought this action for assault and false imprisonment, and at the trial (Cor. Stephen, J.) obtained a verdict, and judgment was entered pursuant to it. The judgment was however set aside by the Divisional Court, and

judgment entered for defendant Company, on the ground that the plaintiff had a remedy against the conductor only. Held (by Lord Esher, M.R., Lindley and Lopes, L.JJ.): That the Tramway Company had not expressly authorised their servant's acts: and that no authority could be implied to do that which the Company were not authorised to do. Poulton v. London and South Western Railway Company, L.R., 2 Q.B., 534. That plaintiff had in fact been arrested for passing counterfeit coin, and the powers conferred by The Tramways Act, 1870 (33 and 34 Vict., c. 78), did not extend to such a case. Appeal dismissed.

VINT V. VINT.-Postnuptial Settlement.-Assignment of all goods, &c., in or about certain Dwelling-house, more particularly described in Schedule.-No Schedule ever Appended.-Sufficient Description in body.-Effect of Absence of Schedule.-Parties to postnuptial settlement were married in 1875. Settlement was made in December, 1878. By it, after reciting that "the several goods and chattels intended to be hereby assigned were the personal estate in possession" of the wife before marriage, and that marriage took place on promise by husband to make settle. ment "of the said goods and chattels in manner hereinafter contained" "all the household goods, furniture, linen, glass,

china, pictures, books, ornaments, chattels and effects now in or about the dwelling-house" of V. at S., "and more particularly specified in the schedule hereunder written were assigned on certain trusts for wife's use for life, &c. No schedule had ever been appended to the deed. Held (by Cotton, Bowen and Fry, L.JJ.), affirming Chitty, J., that the absence of the schedule did not render the deed inoperative, but that it took effect as a settlement of all the goods, &c., in the house at the date of its execution-the description not being too vague. Weeks v. Maillardet, 14 East, 567, distinguished.

CHANCERY DIVISION.

NATIONAL PROVINCIAL BANK V. SHEFFIELD et al.-Banker and Customer.-Cumulative or substituted Securities.-Novation of Debt.-Charges by Testator and Executrix.-Insolvent Estate.Claims of Creditors.-At the death, in 1881, of J. F. £3,000 was due to plaintiffs from him and secured by a deposit of deeds, accompanied by a memorandum of charge by way of equitable mortgage executed some time previous to his death. His widow, to whom he devised and bequeathed all his property and appointed sole executrix, survived. Next year she gave bills of exchange for the £3,000, and executed a memorandum declaring that she deposited the deeds by way of equitable charge on the property to which they related, to secure to the plaintiffs any sums of money then or thereafter to be owing by her. She died in 1885: defendants were her executors, and the action was for foreclosure or sale of property comprised in the deeds. Held (by Kekewich, J.): That in such cases the presumption against intention to substitute the second security for the first required cogent evidence to rebut it. That there had been no novation of J. F.'s debt to plaintiffs that the security given by his widow was in addition to that given by J. F., and therefore the former was still subsisting so as to exclude J. F.'s creditors.

IN Re THE BRITISH BURMAH LAND COMPANY LImited.— Prospectus Containing Gross Misstatements.-Shareholder Misled. -Company Worthless.-Application for Removal of Name from Register. Commencement of Winding-up.-Delay. This was an application by S. for the removal of his name from the company's list of shareholders and for the return of his deposit on allotment. The company was incorporated in January, 1886, and a prospectus containing, as subsequently appeared, gross misstatements issued. On the faith of these misstatements applicant applied for shares, which were allotted to him. C., a mining engineer, sent out by the directors, tele. graphed in September that the mine was a failure, and asked whether he should return. Upon receipt of the telegram the directors telegraphed to C. to return at once, and called a meeting about November 1, at which S. was not present. A fortnight after, S. received a printed report of the proceedings. About January 3, 1887, directors received a confirmatory report from C., and issued a circular setting the report out and stating that a meeting of company would take place on January 12; that C. would be present, and that a resolution for voluntary winding-up would be submitted. The meeting was held and the resolution passed. S. on the same day took out this summons. On January 15 a winding-up petition was presented: on January 27 the confirmatory resolution for the voluntary winding-up was passed and a supervision order made on February 1. Kay, J.): That there had been no such delay in repudiating the shares as disentitled the applicant to relief, for awaiting C.'s confirmatory report of his telegram was a reasonable and proper course for S. to take; and that, inasmuch as the winding-up commenced on January 27 (Weston's Case, L. R., 4 Ch. App., 20.), and applicant had instituted proceedings for the removal of his name from the register before that date, he was entitled to the relief sought, and an order for repayment of his deposit, interest, and costs must be made.

QUEEN'S BENCH DIVISION.

Held (by

LEWIS V. KINGSBURY.-Commission to take Evidence Abroad.— Application by defendant for Commission to take his own Evidence. -Special Circumstances.-A commission may issue in very special circumstances at the instance of a defendant for the examination of himself abroad (Per Huddleston, B. and Charles, J. Note, Affirmed on appeal).

HENNESSY V. WRIGHT.-Action for Libel.-Right to Production.-Documents relating to Public Service.-Consent of Head of Department.-Application before Trial.-Colonial Governor.The plaintiff had in his possession despatches on matters connected with the public service, which had passed between himself as Governor of the Colony of Mauritius and the Secretary of State for the Colonies. He made an affidavit in which he stated that he had these documents in his custody; that they were acquired and held by him in his capacity of Governor, and subject to the direction of the Secretary of State, and that the attention of the Secretary of State had been directed to the nature and dates of the documents, and he had directed the plaintiff not to produce them, and to object to their production on the ground of the interest of the State and of the public service. On an interlocutory appli.

cation by defendant, that plaintiff be ordered to produce them for inspection, Held (Field and Wills, JJ.): That the order could not be made. Per Field, J., on the ground that the application being for production before trial, the statement in the affidavit as to the character of the documents was sufficient. Per Wills, J., that it did not appear that the Secretary of State had seen and considered the documents, or formed any judgment as to whether the result of their production would be injurious or not, and had not informed the Court either by affidavit or through the Attorney-General (Beatson v. Skene, 5 H. and N., 838), that he objected, and that the statements in the plaintiff's affidavit were too vague to be treated as an objection raised by the responsible minister; yet, that it was the duty of the judge to prevent the disclosure of the contents of the documents in question. If it is appa rent to the judge that a rule of public policy would be contravened by disclosure of the documents (though no objection be made by a minister or the head of a department, or by the party called on to produce) it is his duty to prevent the admission of the evidence.

GUARDIANS OF POOR OF Southampton v. Bell and Taylor. Solicitor to Guardians of Poor.-Costs.-Taxation by Clerk of Peace. Conclusiveness of 7 and 8 Vict., c. 101, s. 39.-Right of Solicitor to taxation under Solicitors Act (6 and 7 Vict., c. 73, s. 37). The plaintiffs had paid £600 to defendants (their solicitors) for the purpose of an action. Defendant's costs as taxed by the Clerk of the Peace for Hampshire, left a balance due to plaintiffs; defendants however contended that they were, notwithstanding this taxation, entitled to have the costs taxed as between solicitor and client, in the High Court, under sec. 37 of 6 and 7 Vict., c. 73, and this course they proposed to take on the ground that the allowances made them were unreasonably low. The present action was for the balance of the £600 (after deducting the amount of costs allowed by Clerk of Peace) as money had and received to plaintiffs' use. Held (by Manisty and Stephen, JJ.): That defendants were right, notwithstanding sect. 39 of 7 and 8 Vict., 101, and the taxation thereunder. Order for taxation under 6 and 7 Vict., c. 73, s. 37.

CHARMAN V. SOUTH EASTERN RAILWAY COMPANY.-Railway Company.-Level Crossing.-Act for Regulation of Railways (5 and 6 Vict., c. 55, s. 9).-Evidence of Negligence.-Maintenance of good and sufficient Gates.-Straying Cattle.-Two horses belonging to plaintiff strayed on defendant company's line at a point where the railway crosses a highway on a level; there were two large carriage-gates, and by the side a small wicket-gate for foot passengers. The wicket-gate was fenced round to prevent cattle straying on the line. The horses pushed the wicket-gate open, broke through the fence, got on the line, and were killed. In an action for damages for their loss, Huddleston, B., gave judgment for defendants, on the ground that there was no evidence of negligence on the defendants' part. Held (by Manisty and Stephen, JJ.), on motion for new trial: That it must be left to the jury to say whether the gates were good and sufficient, as required to be maintained by sect. 9 of 5 and 6 Vict., c. 55 (An Act for the better Regulation of Railways). New trial ordered.

COLE V. MILES.-Trespass on Railway.-Public Footpath.Extinguishment by Acts for Constructing Railway.-Bond fide Claim of Right.-Ouster of Magistrates' Jurisdiction.-Appellant had been convicted for wilfully trespassing: the trespass con sisted in crossing over a railway embankment. Over the land on which the embankment had been raised a public footpath had existed, and the applicant contended still existed --the trespass had been committed in the exercise of the right contended for and for the purpose of asserting it. The Jus tices were of opinion that the Acts authorising the making of the railway extinguished any such right. On a case stated by the Justices under 42 and 43 Vict., c. 49., s. 33, Held (by Cave and Wills, JJ.): That the conviction must be quashed; that the right of way had not been extinguished by the statutes in question; and that whether that were so or not the claim of right was a bona fide one and sufficient to oust the jurisdic tion of the Justices.

Henderson v. PRESTON.-False Imprisonment.-Governor of Gaol.-Warrant.-Time from which Imprisonment runs.—Arrest or Receipt in Gaol by Governor.-H. claimed damages from P. for false imprisonment. P. was governor of a gaol and as such received H. into prison on August 25, discharging him on September 1. The warrant was dated August 24, and H. had been arrested on that day. The sentence was seven days' imprisonment in default of payment of a fine and costs. The defence set out the magistrate's warrant, which directed P. "to receive" H. "into his custody and keep him for the space of seven days unless" fine and costs "be sooner paid." Held (by Manisty and Stephen, JJ.): That the statement of defence disclosed an answer to the action, and that the detention of H. during August 31 was not wrongful. The term of imprisonment dates not from conviction or arrest but from the time of lodging prisoner in gaol. The authorities discussed.

"PUMP COURT" PORTRAIT GALLERY.

H. HOMEWOOD CRAWFORD, ESQ., CITY SOLICITOR.

It would be difficult indeed to designate a position in the solicitors' branch of the legal profession at once more honourable and more onerous than that of legal adviser to the Corporation of London. The vast issues involved in a conscientious and able discharge of the duties of the appointment, and the varied and often complex nature of the work, make it more than desirable-absolutely essential, that the holder of the position should be a gentleman of unimpeachable integrity, and of indisputable ability. The Corporation have long had the good fortune to be well served in both these respects. The late City Solicitor, Sir Thomas Nelson, was a man of unblemished honour and wide legal knowledge, and his successor, whose portrait we now have the pleasure of presenting to our readers, is worthy in all points to take up the record of his predecessor in the office. Never, perhaps, in the long and honourable career of the Corporation, has there been a period when zeal, knowledge, and devotion were more urgently demanded from the legal champion and warder of municipal rights, than the present. We live in hypercritical We live in hypercritical times, and upon no single one of the venerable institutions of the country has criticism been. lavished more prodigally than upon the Corporation of London. In the face of this fact it is, therefore, a matter for congratulation that the rights and privileges of the City are in the guardianship of a gentleman so well qualified, both by nature and by training, to preserve them intact and inviolate, and hand them on in all their traditional dignity and completeness.

Mr. Henry Homewood Crawford has been fortunate enough to enjoy, in the course of his professional studies and career, just the varied experiences which are best cal

culated to qualify a man of natural talent for the work of dealing with the complex and varied affairs of a great metropolitan municipality. Mr. Crawford, in addition to the active conduct of a large private practice, has served the honourable office of Under-Sheriff of London and Middlesex for the years 1875-6, 1877-8, 1879-80, and 1884-5; and the duties of this position added yet one more to the useful and valuable experiences which helped to qualify him for the important appointment which he now holds. Some of the incidents of the undershrievalty were peculiar and interesting, although the duties are sometimes not only important-such as the responsibility for the due ordering and holding of the Courts, but also disagreeable-as in the case of the necessity of attending executions. Mr. Crawford as Under-Sheriff has attended no less than fourteen of these ghastly functions, among them being that of Wainwright, whose trial lasted ten days and created an amount of excitement the memory of which is still vividly present as we write. Other notable trials in which Mr. Crawford in his capacity of UnderSheriff was engaged were the famous Mignonette case, and the great turf frauds case which lasted for six weeks and ended, as all remember, in the discharge of detective Meiklejohn from Scotland Yard. The necessity for the exercise of the greatest acumen and caution is evidenced by an incident which occurred in connection with an execution, for the due carryingout of which Mr. Crawford was responsible. On the morning fixed for the execution, of a certain criminal, a letter, containing a respite, arrived, literally at the last moment. It was duly written on the Home Secretary's official letter-paper, but was enclosed in a Local Government Board envelope-a discrepancy which put Mr. Crawford on his guard. The letter only reached the Governor of Newgate at ten minutes to eight on Monday morning, the usual course being to send reprieves on Saturday night and make the messenger wait for an official acknowledgment of their receipt. Under the circumstances, therefore, Mr. Crawford