ascertained from persons well acquainted with him. The House of Lords held that this report was inadmissible on the ground that it was hearsay evidence, and not within any of the recognized exceptions. In this case there was strong suspicion that the report had been tampered with, and it is very likely that a judge or a jury would not have been satisfied to accept its statements; but to decide that this document was not to be considered by the tribunal at all, never mind how unimpeachable it might have been, was a decision as entirely contrary to one's ideas of the common-sense way of conducting an inquiry into the birthplace and identity of Mangini, as it might have conduced to a wrong decision on the facts if the document had been irreproachable. We think that a perusal of Stobart v. Dryden will also lead to the conclusion that the evidence rejected as hearsay ought to have been submitted to the jury.

It is frequently contended that a legal inquiry must, in its nature, be of a different character to an inquiry in common life, but we fail to see any essential difference as regards the kind of testimony which should bę admitted, or only hearsay should be suppressed before a court of justice when it is often valuable testimony in the affairs of every-day life and a large part of the business of the world is carried on upon hearsay statements. In a court of justice there are greater powers for the discovery of the whole facts by the compulsory examination and cross-examination of witnesses, and the production of documents, hence the greater facility to detect fraud. If, therefore, hearsay is accepted outside a court of law as valuable testimony, it certainly ought to be accepted inside.

As no one would now propose a return to the old system of excluding witnesses as incompetent, on the ground of interest, so we contend that if hearsay were once admitted no one would suggest a return to the present cumbrous rules by which it is rejected as incompetent. The exclusion of witnesses and the exclusion of hearsay have both arisen from the same mistrust of the discernment of juries. The exclusion of witnesses has been shown to be a mistake by experience, though long strenuously opposed by great authorities; we believe that the admission of hearsay would also be justified by experience.

The rejection of hearsay proceeds upon principles and exceptions which are extremely difficult of apprehension and which have no counterpart in common life. The rejection of hearsay often leads to the suppression of most important and valuable testimony. The very cases which are the authorities for the rejection are examples of the injustice of this practice.

The attention of jurymen is strained and often defeated by the discontinuity in the proof of a witness; the witness himself is flurried by constant interruptions in the thread of his evidence; full reports of conversations often become impossible; a fraudulent witness is less easily detected in his evasions or perjury because his narrative is so artifically told, and thereby the rejection of hearsay often becomes the cover of fraud. Lewis EdmunDS, in Law Quarterly Review.

Digest of Insurance Cases, for the year ending Oct. 31, 1889, by John A. Finch, of the Indianapolis Bar. Indianapolis, Ind. The Rough Notes Co. 1889.

This is the second annual volume of a publication, which we took occasion to commend a year ago, when the initial volume was published. The business of insurance in all its branches has grown to such immense proportions, that insurance law is coming to be recognized as a field sufficiently large for the specialist. The extent of this field is shown by the fact that Mr. Finch's Digest for 1889, refers to nearly four hundred reported cases, decided during the period of one year.

To the lawyer who desires to keep up with the current of legal thought and decision in this department of his profession, as well as to the practical insurance man, a publication such as the one before us, is invaluable. The cases digested cover points in fire, life, marine, accident and assessment insurance, and affecting fraternal benefit orders. Especially noticeable is the increase in the number of cases arising from accident insurance policies, the natural result of the rapid growth during the last few years of that branch of the insurance business. The cases of this class digested by Mr. Finch are just double the number contained in his last year's volume.

Mr. Finch's work appears in the main to be thoroughly and completely done. We think, however, that an arrangement by subjects would facilitate the use of the Digest as a book of reference. The index only partially answers this purpose. One criticism must be made: The book purports to contain "reference to annotated insurance cases," and does to a certain extent. But in this one respect it is far from complete. For instance, we can find no reference to the report and comprehensive annotation of Central Nat. Bank v. Hume in 28 American Law Register 417 (July, 1889), nor to Hutchcraft v. Travelers' Ins. Co., in the January number of the same publication (28 A. L. R. 42). The report of Gillett v. Liverpool & L. & G. Ins. Co., also in the same volume, p. 216 (April number), is referred to in the table of cases, but not in the body of the Digest, and the annotation is entirely overlooked. J. C. S.

THE MEDICO-LEGAL JOURNAL, of New York City, has discovered some good in the City of Brotherly Love, for it says that THE CURRent ComMENT has been started, making it "an interesting comment upon current legal decisions, and its department of legal miscellaneous topics is admirably edited and conducted."

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PUBLISHED WHEN READY, is the explanation of the Green Bag, over its "useless" appearance. When the contributors, and the editor, and the Photogravure Company, and the printer, get things all amicably' arranged, each successive number appears, and is mailed-usually somewhere between the tenth and fifteenth of the month."

THE STORY OF PHOENICIA. By George Rawlinson, M.A., Camden Professor of Ancient History in the University of Oxford, etc. (The Story of the Nations Series.) New York: Putnam's Sons. 12mo, pp. xvii., 356. Cloth. Illustrated. Map. $1.50.

Like the other volumes of the series, this one is printed in good readable type and on excellent paper. The binding is artistic and appropriate. In outward appearance it is of such a character as to make it a pretty book. Only one matter in the mechanical make-up of the volume could be improved-namely, the restoration of some few letters that have fallen out of place and the replacing of some imperfect letters by others whose corners have not suffered violence.

The author has not prefaced his book by any remarks to tell us what the limits of his task are. We are left to infer from the title that it was not his intention to go beyond the point at which Phoenicia ceased to have an independent existence, and consequently we do not find any account of the fortunes of the land since the final conquest by the Romans. But even within these limits, this work, like all other of a similar sort, has the character of a tentative effort. It is not possible to say the last word yet in regard to any of the peoples of Western Asia, where we are expecting new discoveries every day. The merit of a work on any one of them lies in the extent to which the facts of most recent discoveries are made accessible. The completest book is the one that not only gives us all that which, having been heretofore known and stated, has stood the test of criticism, but also at the same time brings down the tale to the very date of publication. The years are strewn with books which have served their purpose which are now only as mile-stones to mark the progress of knowledge. The same may be said of the present volume, for it will by no means be considered as the last word on the subject.

The materials for the history of Phoenicia are very much scattered. The remark of Pietschmann ("Geschichte der Phoœnizier," p. 3), will long remain true, to the effect: "To-day and for a long time to come it will be impossible to avoid the impression that the representation of Phoe .ician history is made up of a mosaic of disjointed notes even when one does not merely heap up the details of a dry learning." To go thoroughly into the subject requires an amount of research that is simply amazing to the uninitiated. References must be gathered from the cuneiform records and from the hieroglyphic and "hieratic" writings of Egypt. The Greek and Latin historians must be searched through and their story learned. The scattered notices of the land and people contained in the Old Testament must be sifted and studied. Of modern books on the subject there are not many, but the notes and scraps of information are scattered through periodicals and the proceedings and transactions of the learned societies. The classics on Phoenicia have been Movers and Kendrick, but the book that will replace them will undoubtedly be that of Richard Pietschmann in Oncken's series.

The present book does not pretend to be a complete and exhaustive study of the subject, or if it does it falls short of its aim. It deals in the first place with the land and people, the geography of the former and the characteristics of the latter. Then the colonies and the early history of the efforts of the people in navigation, the connection that they had with the Hebrews, the Assyrians, the Babylonians, the Egyptians, the Persians, the Greeks, and the Romans are treated in order. Here the history comes to a close. The final chapters are taken up with an account of their architecture, manufactures, and works of art, their language, writing, and literature. The story is told in a pleasing way, though there is too much that is technical for a popular book and not enough of detail for a book of reference. But evidently the former is the class in which it is to be placed, and further criticism is, perhaps, uncalled for. For scholarly purrposes it lacks the references to the literature which are so marked a feature in the work of Pietschmann.

We note that in speaking of the navigation of the Phoenicians no notice is taken of the late work of Lieblein on their traffic in the Red Sea. The plan of the work excluded mention of the Punic and Carthaginian settlements, except that a long account of the settlement of Carthage is given in quotation from an unnamed "German critic." It may be apprehended that all will not readily agree with the account of Asherah as the name of the symbol or figure under which Astarte was worshipped (p. 110). The account of the writing of the Phœnicians is also very partial, and the arguments of those who suppose that it was derived from the Egyptian are put aside too readily and with too little reason. It is certainly an extreme statement that there are resemblances between the Phoenician and Egyptian letters only in three or four cases and exact likeness only in one. It must be borne in mind that long interval existed between the time when the Phoenicians became acquainted with the Egyptians and their culture and the time whence we have any remains of the literature—if it is worthy of the name. And it is further to be remarked that the system of comparison between the letters of the Phenicians and the complete and perfect hierogly phics of ancient Egypt is very unfair. The ordinary signs used in business transactions cannot have been these, but rather the more easily-made and the currently-used "hieratic" or even "demotic" writing. It is not possible thus easily to brush aside the work of De Rouge on this interesting topic, to say nothing of the work of Taylor ("The Alphabet ").

To the general reader the work will afford a means of gaining a rapid glance at the interesting story of these early and adventurous voyagers, but to the student it will afford comparatively little aid. It will not serve as a guide because the literary sign-boards have been omitted. Incidentally it appears (p. 294) that the book was written in 1887, and hence some allowance is to be made, but on the whole we lay the book down with some degree of disappointment.-C. R. Gillett, in Magazine of Christian Literature.

THE FORUM. February, 1890. N. Y. Fifty cents a copy. The Immigrants' Answer, by one of them, makes a good showing against the expediency of restraining unassisted immigration. A fair idea of this contribution can be obtained from the extract on another page. The writer is of German birth, and fought through the war and then through the courts, to the judgeship of the Chicago Superior Court. He is an anti-slavery democrat, and favors universal suffrage.

The publishers have opened a new department, at the head of the advers., in the back of the magazine, and have called it "The Commercial Forum." Therein, for a consideration, any respectable tradesman, patentee, or other would-be seller, can have his wares elegantly puffed; provided always, nevertheless, that the editorial force can make or receive "these statements and descriptions to such enterprises and establishments as admit of dignified and instructive description." Which proviso should be amended by striking out the words "and descriptions," for euphony's sake. The department begins with a prospectus of a car-heating device and a circular about American India Ink, which latter is so superior as to secure a free reading notice from a great English pen artist and illustrator.

The author of Drone on Copyright furnishes a very light article on The Power of the Supreme Court of the U. S. In some respects, and to a foreign reader, the statements are incorrect in too many places. For it is not true that a majority of the Court have more power than the President and a majority of the two houses of Congress. In fact, as the Court cannot execute its own judgments, the Executive is the most powerful department; as, witness the defiance by the State of Georgia of the judgments of the Court, in the early part of this century. The President did not and the Court could not enforce its decrees, and Congress alone, by impeachment, might prod the Executive. This calls to mind how effectually the denunciations of a member of the Peace Society were silenced by a lawyer whose caustic examination had tried the principles of the Peace man. The Peace man had failed and gotten a discharge in bankruptcy. "Sir! don't speak of peace to me; if it were not for Uncle Sam's blue coats, I'd collect every dollar of the old debt!" The other articles are The Ethics of Property, by Lilly; America's Fourth Centenary, by Gen. Walker; Key Notes from Rome, by Lea; Problems of American Archaeology, by Major Powell; Moral Aspects of College Life, by Pres. Adams; A Political Paradox, by Leonard Woolsey Bacon; Mrs. Grundy's Kingdom, by Mrs. Linton; and Writing for the Stage, by Prof. Hennequin.

THE REACTION against "boy choirs" has reached its legitimate fruits. A correspondent of an English paper, writing from Melbourne, Australia (where St. James' Church claimed to be a cathedral), communicates the natural result that the choir of surpliced ladies was not a musical success and practically broke up when the Rev. Dr Bromby (who started the idea) married the youngest and prettiest member of his "Angelic Choir." "Thou shalt love the Lord thy God, and Him only shalt thou worship."