especial interest, from the sociological stand point; e. g., New Zealand legislation on the subject of the housing of the working classes in urban districts; of fixing a minimum weekly wage for boys and for girls employed in factories; of forbidding any employer, who takes out acci dent insurance policies to insure his workmen against accident, and against liability, from tak ing, directly or indirectly, any money from any workman in his employ, whether by deduction from wages or otherwise, howsoever, in respect of any such policy of insurance; of allowing the government to undertake accident insurance business — it already carries on the business of life insurance; and of restricting immigration. Of more general interest than the review itself, are the fourteen admirable contributed articles, in the first half of the volume, covering a wide range of subjects. Sir Frederick Pol lock's scholarly " History of the Law of Nature" has been seen on this side of the water in the initial number of the Columbia Law Revinu. Dr. Speyer's " Legal Aspects of the Sipido Case" deals with a matter in which there has been a "deplorable misunderstanding " in England,— and here, as well. The facts were these : three lads, between sixteen and twenty years of age, had incited Sipido, by procuring a revolver and by betting in his presence that he would not have the courage to carry out his criminal de sign of attempting to assassinate the Prince of Wales. On the trial, the jury, influenced by the penalty of ten to fifteen years of penal servitude in case of conviction, found that the state had not proved its case against the three accom plices. As to Sipido, the jury found that he was guilty of attempting a voluntary and premedi tated homicide; but to the third question sub mitted to it by the court — " Did Sipido act with discernment?" — a question which the court was bound to submit in the case of a prisoner, like Sipido, under sixteen years of age — the jury answered in the negative; i. e., that he was not doli cafax. When, as here, the jury finds " that the prisoner had acted without criminal dis cernment, the court must acquit him, but may direct that he shall be detained in a reformatory until he comes of age." Both of these things the court did. Immediately the question arose : " Had the court authority to enjoin that its order shall be
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executed immediately, or was it not bound to suspend execution and leave Sipido in liberty until that order had been made absolute, either by a decree of the Court of Cassation, or by ex piration of the legally appointed time [three days] within which Sipido had the right to ap peal to that court. . . . All authorities tend to show that detention in a reformatory is not a penal punishment, but simply an administrative measure taken in the interest of the child." Such being the case the court was " bound to order the immediate discharge of Sipido, and the Belgian government could no more have pre vented this order being immediately obeyed by the police than the British government could disregard a writ of habeas tarpus at the demand of a foreign potentate." Sipido immediately crossed the frontier and disappeared. Then diplomatic correspondence and violent denun ciation of the Belgian jury, judiciary and govern ment by the English press followed. It is to be noted, however, that the bonafides of the Belgian government was vindicated later. Sipido was found in Paris and arrested; his case not being covered by extradition treaties, " the Belgian government claimed him in loco parentis, the custody of a child ordered to the reformatory being temporarily withdrawn from the father, and vested for the time being in the state." He was surrendered, taken back to Belgium and sent to a reformatory. An article sure to attract the attention of American readers is that on " The Immunity of Private Property from Capture at Sea," in which are brought together extracts from several valuable papers read at the recent conference of the International Law Association at Rouen. The United States was the first state to advocate such immunity; and the American members of the committee urged the calling of a conference of the various maritime governments to consider that question. Such diversity of opinion was manifested, and such strenuous opposition to such immunity was voiced, that the success of this movement seems more than doubtful. Mr. Justice Phillimore opposed it on the ground that the fear of loss and the fact of loss are both powerful to prevent war, and to bring about a speedy return of peace; that the present lia bility to capture made nations — especially Eng land — more vulnerable, which he considered a
