more particularly to decide questions requiring the cooperation of two or more Departments. Sufficient power will be delegated to the Committee to enable it to give binding decisions on questions which come before it without reference to the War Cabinet, but exceptional cases of doubt and difficulty and larger questions of policy will be referred at the discretion of the chairman to the War Cabinet. The supreme power over domestic affairs will, therefore, still rest with the War Cabinet, which, while giving very wide discretion to the new Committee, will be ready to act as a final court of appeal. The scheme is designed to relieve the War Cabinet of matters of detail having no immediate bearing on the conduct of the war, and to enable the Prime Minister and his colleagues to give their undivided attention to the great national task.

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The House of Lords has unanimously adopted a motion approving the principle of a League of Nations. This significant step was taken on June 26th after Lord Curzon, with the authority attaching to his position as a member of the War Cabinet, had pointed out the difficulties no less than the advantages of the proposal. After calling attention to the failure of the various Leagues of Nations proposed in the past, Lord Curzon observed that in spite of this the principle was one to which the great majority of thinking men in all countries are converts: In the various schemes put forward he found a general concurrence in certain features, such as the institution of a tribunal to which all signatory parties would pledge themselves to refer their disputes before going to war, and a sanction for enforcing the decrees of the supreme body. Lord Curzon asked the assent of the peers to two propositions: First, it was desirable to do something to prevent wars, or, if that was too Utopian an aspiration, to limit their scope and to diminish their horrors. in future. For this purpose, he argued, the general concurrence of nations was necessary, and if it was to be effective, it ought ultimately to include all the important States of the world. Secondly, Lord Curzon

believed it to be true that opinion in this country was rather in advance of that of any of our Allies, except possibly that of the United States. He, therefore, warned the House that it would be well not to go ahead too quickly, or a rebuff might be incurred. Lord Curzon urged that we must try to get some alliance or confederation of States none of which should be at liberty to go to war without reference to arbitration or to a conference of the league. Then if a State broke the contract, it would become ipso facto at war with the other States in the League, who would support each other, without any need for an international police, in punishing or repairing the breach of contract. Some States he suggested might do it by economic pressure: that might apply perhaps to the smaller States. The larger and more powerful States might do it by the direct use of naval and military force. His conclusion was that in this way war might not indeed be abolished, but rendered a good deal more difficult in the future.

Two recent decisions of the House of Lords on the rights and liabilities attaching to the relationship of banker and customer deserve more than mere passing notice. In the one case (London Joint Stock Bank v. Macmillan, June 21st), a trusted clerk of a business firm drew a cheque for petty cash, and in accordance with the custom of the firm took it to one of the partners for signature. The latter signed it in a hurry and apparently failed to notice that the place left for the amount to be stated in words was blank, and that where the amount should have been given in figures there was only a "2" with a blank space on either

side. The clerk afterwards filled in the words

one

hundred and twenty pounds " and added the figures to correspond. The bankers cashed the cheque and the clerk absconded. Thereupon the firm sued the bankers for the money lost. Mr. Justice Sankey had held

that when the only negligence suggested against customer of a banker was that he had given to a

the

clerk

the opportunity to commit a forgery, such negligence was not enough to make the customer liable. That view was upheld by the Court of Appeal (Swinfen Eady and Scrutton, L.JJ., and Mr. Justice Bray), a strong Court in which the President said that the customer's duty not to mislead the bank was not violated by his negligently drawing a cheque in such a way as to afford another person the opportunity to mislead. No decision could have been more disconcerting to bankers, and it must be greatly to their satisfaction that the law as it was declared nearly 100 years ago in Young v. Grote has now been affirmed in the House of Lords by the reversal of the judgment of the Court of Appeal. The Lord Chancellor held that for all practical purposes the cheque was in blank and that the loss was the natural and direct consequences of the customer's negligence. Lord Finlay laid down the rule that it is the duty of a customer to draw his cheques with reasonable care to prevent forgery, and that he must be liable for the result of any neglect of that duty. It will be recalled that Young v. Grote, which was supposed to have recognized some special relation between banker and customer involving the duty of care in the drawing of cheques not extending to other negotiable instruments, was believed in many quarters to have been displaced by the more modern authority of Schofield v. Earl of Londesborough. The decision in the latter case was that the maker of a bill or note owes no duty to a subsequent holder for value to see that the document is filled up in such a way as to prevent subsequent alterations, and Lord Halsbury repudiated the idea of there being any different duty as between drawers of cheques and their bankers. In the present case the House of Lords have taken a different view and have accepted the doctrine that if it be the fault of a customer that the banker pays more than he ought the customer must make good the difference.

In the other case (Banbury v. Bank of Montreal, June 25th), the House of Lords were not unanimous in dismissing an appeal which had been decided in favour of the bank in an action brought by a customer for alleged negligence and breach of duty by its branch manager. The plaintiff contended that the manager had given him unskilful advice about an investment, which involved him in a heavy loss. The Court of Appeal (consisting of Lord Cozens-Hardy, and Warrington and Scrutton, L.JJ.), had held that the local manager of the bank had no general authority to advise the plaintiff as to investments so as to bind the bank, nor any special authority to do so with regard to the investments in question. The Court of Appeal also held that sec. 6 of the Statute of Frauds Amendment Act, 1828 (Lord Tenterden's Act) was also an answer to the plaintiff's claim. On the first point the House of Lords by a majority of 4 to 2 have upheld the decision of the Court of Appeal, but as to the effect of Lord Tenderden's Act all the learned Lords agreed that the action being for breach of duty, it did not fall within the section at all, Lord Atkinson stating that it applied merely to actions of deceit and false and fraudulent representations.

The King has been graciously pleased to approve that the dignity of a peerage of the United Kingdom should be conferred upon the Right Hon. Sir Walter George Frank Phillimore. Sir Walter Phillimore, himself the son of a judge, retired from the Court of Ap years ago. He had previously been for nearly 16 years a judge of the King's Bench Divi sion, but had sat in the Appeal Court for only three years. Few English lawyers have possessed a richer or more varied store of learning. At the Bar he spe cialized in Admiralty and Ecclesiastical cases. As a King's Bench judge, in addition to taking a successful

part in the ordinary work of the Division, he was judge in bankruptcy. In the Court of Appeal proved himself to be familiar with the principles

the

he

of

Equity as well as with the Common Law. On the Judicial Committee, where he has sat frequently since his retirement from the Court of Appeal, he has already rendered valuable and distinguished services, and now his wealth of legal knowledge will be at the disposal of the Supreme Appellate Tribunal for the United Kingdom. The new peer, who is 73 years old, has written on ecclesiastical and international law, and, since his retirement, a book dealing with the great European wars of the last three centuries and their influence on history. In being raised to the peerage Sir Walter Phillimore has received an honour which few ex-judges have had bestowed upon them, the only judges within recent years who have been created peers on their retirement from the Bench being Lord Field, Lord Brampton, Lord Ludlow, Lord Gorell, and Lord Mersey.

A House of Commons Committee is sitting to discuss the meaning of the phrases "continuance of the "'"duration of the war," "end of the war,' war,' which have found their way into a large number of emergency statutes and have been adopted in innumerable contracts. Some discussion of the point recently took place in a case before Mr. Justice Neville, and that learned judge appeared rather to deprecate the necessity of an Act of parliament to define the "duration of the war," preferring rather a legal decision on the question of interpretation involved. That the problem is not an easy one will be readily admitted. Is the end of the war the cessation of hostilities or is it the signature of the treaty of peace? If the latter, peace with all the belligerents or only some? Unless the difficulty is solved either by legislation or by authoritative legal decision, much confusion and almost endless disputes are likely to arise.

Mr. Bonar Law has stated in the House of Commons that the Government are inquiring into the legal aspect of the claims by women to seats in the House. The law, however, appears to be reasonably clear. There can be little doubt that at common law a woman