beginning of November, and to conclude the session's business on July 31st. It unanimously favoured the proposal to "meet as now after the turn of the year and sit until near the end of July," with an adjournment to an autumn sitting if the business. of the session could not be concluded by August. This decision offered a measure of co-ordination between the Parliamentary and the secular year, but it is not proof against dissolutions and general elections, and it has already been upset by political vicissitudes. So we must just hope that Parliament may some day consent to number its Acts as of the calendar year, and not of the session. The first Act passed after New Year's Day would then be Chapter One instead of being as it is in this present year of 1925-Chapter Six. The change would hardly require a formal Act of Parliament; a resolution of both Houses should suffice; there seem to be no written instructions governing the practice whereby chapter numbers are allotted by the Clerk of Public Bills.

And now, after all this amateur suggestion-mongering, is anything of the kind ever likely to happen? Why, possibly not, for it would mean upsetting the established tradition of centuries. The twenty volumes of the current edition of Statutes Revised would shudder in their shelves at the idea, though they must some day give place to a new edition when a new system could be adopted. Meanwhile there. are certain omens and precedents. Successive editions of a well-known text-book on Statute Law (edited by the late Mr. Craies) have described the Mansfield Park method as "ancient and cumbrous," and have prophesied that "it will no doubt in time give way to the preferable method of citation by the secular year, already adopted in some of the colonies and in India." Successive editions of another text-book

1 The prophecy seems to be omitted in Mr. Pease's recent edition of Craies on Statute Law.

(Wright and Hobhouse on Local Government and Local Taxation) have been citing statutes by the secular year only and not by the regnal year, though this involves the addition of an appendix tabulating the Parliamentary sessions which correspond to each secular year. So much for the omens; now for the precedents. Here is one of respectable antiquity, yet of a republican sort hardly proper to be quoted in the courts and cloisters of royal and ancient foundations. Scobell's publication of the Acts and Ordinances of the Interregnum numbered the Ordinances from 1649 to 1653 in yearly series, though his numbering possessed no official authority. Better and more modern precedents can be found in the British Dominions overseas, nor need the Mother of Parliaments blush to learn from her daughters. New Zealand (as from 1880), New South Wales (as from 1897), and Western Australia (as from 1903) have given up the system of regnal year citation, and have adopted the numbering by secular year, though both New Zealand and Western Australia continue to quote upon their Acts the regnal year as well as the secular year and number. And while Canada, Newfoundland, Queensland, South Australia, Tasmania and Victoria still adhere to the regnal year citation, the newer Commonwealth of Australia and the Union of South Africa (the latter carrying on the pre-union practice of the four constituent provinces) have always used the secular year numbering. South Australia and Victoria, it may be mentioned, maintain a continuous system of numbering of Acts, irrespective of year or session, in addition to the regnal year system. Victoria began its sequence in the year 1857, and has now somewhere about 3400 Acts on its list; South Australia began in the year 1875, and is still a few hundred short of the 2000 mark. In the colonies and protectorates the almost universal plan is to employ the secular year.

The Bahamas seem to be exceptional in clinging to the regnal year arrangement. Jamaica used the regnal year citation until some sixty years ago when she changed over to the secular year method.1 Nearer home the Belfast Parliament has been loyal to the method of Westminster, while the Irish Free State has chosen the secular year. Thus, amid a natural diversity, there is (especially if we add the example of India, which has long enjoyed a tradition of orderliness in draftsmanship) ample precedent within the Empire for numbering and citing our Acts as of the calendar year. If we did so, we could still imprint upon them, in addition, the regnal year for the sake of continuity.

One last question. If the change is ever to be made by the Parliament of the United Kingdom, when may it be expected? Not, we may assume, until the grumbles at the Mansfield Park method have become more articulate than hitherto. The beginning of a new century would be a seasonable. moment, for we are sensible of a certain magic in round numbers. A great chance was lost in 1900. We did not realise our opportunity at the time, and, as it happened, the fortunate correspondence of regnal, secular and sessional years during the reign of King Edward VII. minimised the sense of inconvenience. Now, perhaps, we must wait till the year 2000. If we are excited by centuries, what may we not do under the influence of a new millennium?

1 For details of these oversea precedents I have to thank Mr. W. R. Shipway, M.B.E., Registrar of Colonial Laws at the Colonial Office.

The Charitable Foundations of

Byzantium

By P. W. DUFF, B.A.

FELLOW OF TRINITY COLLEGE, Cambridge.

A CITIZEN of the Roman Republic or the pagan Empire who wished to found or endow a hospital, an almshouse, or a school, could only do so by indirect means. The machinery of charitable trusts was of course unknown; and the earlier Roman lawyers took no step towards recognising as separate legal entities such institutions as are familiar in Germany under the names of Anstalten and Stiftungen. Hence the only course open was to transfer the property destined for the charitable object to an individual or a corporate body, and place the recipient under as strict as possible an obligation to expend the revenue in the way desired. To secure greater permanence, such a charge was more often laid on a corporation than an individual, and usually on a town. Gifts and bequests of this kind were common, and many instances are to be found in the Digest, lay literature, and inscriptions.1 Among the most famous are the charitable endowments of the younger Pliny, who bequeathed to the town of Comum more than two million sesterces for the erection, outfit and maintenance of public baths, for the support of a hundred of his own freedmen, and for public entertainment; and in his life-time founded and endowed a library,

1 For a large collection of Inscriptions, with some other non-juristic texts, see B. Laum, Stiftungen in der Griechischen und Römischen Antike, Vol. 2.; and for references to the Corpus Juris, Pernice, Labeo, 3. 1, especially pp. 56 ff., 150 ff.