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GRANT'S
LAW OF BANKING
AND BANKERS.
J'flMttl ®biti0n.
1^
GRANT'S
LAW RELATING TO BANKERS
A^'D
BANKING COMPANIES,
WITH AN
APPENDIX CONTAmNCI THE MOST BIPOKTANT STATUTES IN
FOUCE RELATINa THEPtETO.
|0milj (Siriticrii
WITH SUPPLEMENT CONTAINING THE BILLS OF
EXCHANGE AND BILLS OF SALE ACTS, 1882.
BY
CLAUDE C. M. PLUMPTRE,
OF THE MIDDLE TEMPLE, BARRISTEB-AT-LAW, ESg.
Middle Temple Common Laiv Scholar, Hilary Term, 1877,
Author of "A Summary of the Law of Simple Contracts,"
LONDON :
BUTTERWORTHS, 7, FLEET STREET,
■JCato ^ublisi^cvs to tl;c Queen's most excellent Jtlaj'cstt).
HODGES, FIGGIS & CO., GHAFTOX STREET, DUBLIN.
CALCUTTA : THL^CKER, SPESTK & CO. IsLELBOUENE : GEORGE ROBERTSON.
MANCHESTER : MEREDITH, RAY & LITTLER.
EDINBURGH : T. & T. CLARK ; BELL & BRADFUTE.
1882.
\BBZ
Z3A IS4
LONDON :
FEINTED BY C. F. ROWOBTH, DREAM'S BUILDINGS, CHANCERY LANE.
PREFACE
FOUETH EDITION.
The Editor has endeavoured to follow as nearly
as possible the arrangement adopted in the pre-
vious Editions. Such alterations as have been
made have been rendered necessary by the many
changes that have taken place in the Law during
the past six years. Many cases that have hitherto
been cited in extenso the Editor has been obliged
to curtail, or merely refer to as authorities, so as
to afford space for fresh matter. The Chapter on
Bankruptcy has been entirely rewritten, and a
new Chapter on Bills of Sale added. The Editor
wishes in conclusion to acknowledge the assistance
rendered him by his friend Mr. Lacey Smith, of
the Middle Temple.
CLAUDE C. M. PLUMPTRE.
5, Haee Couet, Temple.
PKEFACE TO THE THIRD EDITION.
My former Edition of this "Work teing out of print, and
a new Edition being asked for, I have undertaken its
preparation at the particular request of the Publishers.
In fulfilling the task thus entrusted to me, I have
endeavom-ed to add to the acknowledged utility of the
original Work, by eliminating much matter that has
become obsolete or immaterial, and by presenting the
existing Law of Bankers and Banking Companies, either
affected by legislation, or developed by the decisions of
the Courts, to the time of publication. Some chapters
which were inconveniently long, or unconnected in sub-
ject, have been subdivided or re-arranged, and others
introduced.
I have made a liberal use of Mr. Morse's well-WTitten
(American) "Treatise on Banks and Banking," to illustrate
or confirm propositions advanced in Mr. Grant's Work,
which is but the reciprocation of the compliment paid by
Mr. Morse to his predecessor or pioneer in the path of
Legal Banking literature. With the view of extending
the professional value and popularity of the Work, the
existing statutory enactments of the United Kingdom
relating to Bankers, Bank Notes, and Banking Companies
have been carefully collected, and are chronologically
grouped together in the Appendix.
Vlll PREFACE TO THE THIRD EDITION.
An excellent precedent of a Memorandum of Association,
and of Articles of Association of a Limited Banking Com-
pany, is also given.
The late Chancellor of the Exchequer's Bank of England
Notes Bill of the last Session of Parliament, although with-
drawn, is inserted at the end of the Appendix as a matter
of history.
E. A. FLSHEE.
3, Essex Court, Temple,
'22nd September, 1873.
( i^ )
PREFxVCE TO THE SECOND EDITION.
In preparing this Edition, the Editor has been actuated
by a desire to render it as acceptable as po&sible to the
classes for whose use the original Work was designed, and
has spared no pains to accomplish that object. In conse-
quence of the important alterations affecting Banks and
Bankers introduced by Law, and the expansion of Banking-
operations produced by commerce, since the first appear-
ance of this Work, the Editor has found himself obliged
to re-construct and re- arrange portions of it, and to add
several chapters. The bill of the Chancellor of the Ex-
chequer for removing restrictions on the issue of Bank
Notes, as amended in Committee, together with the reasons
on which it was founded, and also the last ofiicial retiu-ns
of all the Banks in the United Kingdom, as being likely
to be of practical utility, are inserted in the Appendix.
R. A. FISHEE.
3, Essex Court, Templk,
oth April, 1865.
( X )
PREFACE TO THE FIRST EDniON.
These pages are the result of an endeavour to compile
the Law relating to the business of Banking, as gathered as
well from Statutes as from the decisions at Common Law,
in Equity, and in Bankruptcy. A work on such a plan, if
properly executed, seems to be wanting, and the Author
trusts that his attempt to supply the void will not prove
wholly unacceptable to the class of persons for whose use
it is principally designed — the professional advisers of the
great Banking interests of this country. The first duty,
it is conceived, of any one who deals with a subject of so
great importance, and of such general interest, is to aim
solely and entirely, to the exclusion of all other purposes,
at practical utility ; accordingly from his book the Author
has carefully excluded all ambitious attempts at scientific
disquisition : the endeavom- has been not to speculate how
the Law might be improved, not to lay down what it ought
to be, but what it is; so that every one, whether concerned
for a person carrying on the business of Banking solely,
or in a Common Law partnersliip, whether a shareholder,
or a director in a Banking Copartnership, under Statute
7 Geo. lY. c. 4G, or in a Joint Stock Company under
Statute 7 & 8 Vict. c. 113, miglit find here the Law, so far
as it has hitherto been prescribed by statutory enactment,
or developed, ascertained and explained by judicial de-
cisions, clearly, accurately and usefully stated. In tliis
view, tlie plan lias been followed of jjlacing before the
reader not moroly statements of tlie dry points of Law,
which wore decided in the cases collected; but, as a rule,
PREFACE TO THE FIRST EDITION. XI
a summary of the principal facts, and occasionally of the
arguments urged before the Court, together with the main
grounds on which the judgment proceeded, is also pre-
sented. By these means, and by the endeavour to lay
down no position or principle unaccompanied by examples
to illustrate its application and effect, it has been hoped to
provide facilities, in a compendious form, for the solution
of every question that can arise, provided such question,
in its nature, falls within any of the classes of questions
which have abeady passed into res Juclicatce. By these
means, at any rate, it may be hoped that a person who
consults this Work, in order to know what are his rights
or liabilities, and w^hat the proper course of conduct in
any given set of circumstances, will be enabled readily to
observe and to decide whether the principles and rules
stated under the head to which his difficulty belongs, have
been applied to, or deduced from, circumstances the same
as, or analogous to, those of his particular case, and
whether the reasons assigned by the Court meet the diffi-
culty and govern the case.
In order to render the Treatise more widely available for
every-day reference, the rules, suggestions, cautions, &c.
for the conduct of Bankers, which the Author has thought
it desirable to interpose, while they have been immediately
derived, in all cases, from the observations of the Judges
in Law and in Equity, have been — as it is hoped will be
found — as much as possible expressed in the language of
business, divested of legal technicalities, and adapted for
the probable requirements of practical men.
With respect to tlio.se comparatively new modes of
carrying on the business of Banking, the Banking Copart-
nerships, and Joint Stock Banking Companies, much
attention has been paid to place before the reader the Law
relating to them in as clear a light as possible ; the subject
of directors' powers and liabilities, civil and criminal, the
xii PREFACE TO THE FIRST EDITION.
rights and liabilities, and remedies of shareholders, as in-
volved on the Bankruptcy or Winding-up of these Bodies,
and also generally, it is hoped, will be found explained in
as satisfactory a manner as the present state of the Law
admits of.
The subject of Colonial Banks has not been omitted, and
there is subjoined a Summary Yiew of the Law relating
to Savings' Banks.
Middle Temple,
Nov. 18, 1856.
TABLE OF CONTENTS.
CHAP. I.
PAGE
The Duties of Bankers and the Eelation between
them and their customer 1
CHAP. II.
The Eules and Principles regulating Cheques or
Drafts on Bankers 12
CHAP. in.
Mode of Payment of Cheques 36
CHAP. IV.
Dishonouring Cheques 45
CHAP. V.
Time of Presentment of Cheques 49
CHAP. VI.
Crossed Cheques 63
CHAP. vn.
Cashed Cheque 72
CHAP. VIII.
Cheques as Evidence of Payment, etc 74
CHAP. IX.
Cheques considered as Money 80
CHAP. X.
Cheques analogous to Bills of Exchange 84
CHAP. XI.
Persons entitled to sue on Non-Payment of Cheques. . 87
XIV TABLE OF CONTEXTS.
CHAP. XII. PAGE
Gifts of Cheques 88
CHAP. XIII.
Payment of Lost or Destroyed Cheques 89
CHAP. XIY.
Criminal OFFE^^CES ix Eelatiox to Cheques 90
CHAP. XV.
Letters of Credit and Circular Notes 94
CHAP. XVI.
Orders to Banks and their Duties in respect of such
Orders —
(1) Orders to Pay 102
(2) Orders other than mere Orders to Pay .... 113
CHAP. XVII.
Accountable or Deposit Eeceipts and the Obligations
of Bankers in respect thereof 125
CHAP. XVIU.
The Eelation of Banker and Correspondent 133
CHAP. XIX.
Deposit of Securities for Special Purpose 138
CHAP. XX.
Deposit of Securities for Safe Custody 191
CHAP. XXI.
The Customer's Pass Book and Account 195
CHAP. XXII.
Guarantees by Customers and others to secure
Advances by Bankers 202
CHAP. XXIII.
Guarantees for Good Conduct of Clerks 222
TABLE OF CONTENTS. XV
CHAP. XXIV. PAGE
Criminal Acts of Servants, &c ., 230
CHAP. XXV.
Bankers giving Sureties as Treasurers 233
CHAP. XXVI.
Appropriation of Payments 236
CHAP. XXVII.
Lien of Banicers 244
CHAP. XXVIII.
Partnerships at Common Law, and the Eights, Reme-
dies AND Liability of Bankers on Change of
Firms and in de.vling with Firms 251
CHAP. XXIX.
Savings Banks 262
CHAP. XXX.
The Relations of Public Bodies, Companies, and of
Persons filling Representative Characters to
Bankers 273
CHAP. XXXI.
Libel on Bankers 283
CHAP. XXXII.
Criminal Liability of Bankers 284
CHAP. XXXIII.
Discounts 291
CHAP. XXXIV.
Bank of England 305
CHAP. XXXV.
Bank of Ireland and Bank of Scotland 326
XVI ■ TABLE OF CONTENTS.
CHAP. XXXYI. PAGE
CuiMmAL Liability of Officees and Servants of the
Bank of England and the Bank of Ireland 327
CHAP. XXXYII.
Banks of Issue • 328
CHAP. xxx^t:ii.
Banknotes — Issue, Negotiation, Loss and Forgery, &c. 340
CHAP. XXXIX.
Bank Post Bills 366
CHAP. XL.
Exchequer Bills and Bonds 367
CHAP. XLI.
Coupons 370
CHAP. XLH.
Remittances 372
CHAP. XLIII.
Joint Stock Banks established under 7 GrEO. 4, c. 4 ;
3 & 4 Will. 4, c. 98 ; 7 & 8 Vict. c. 113 ; and the
Companies Act, 1802 375
CHAP. XLIV.
Limited Banking Companies — Formation, Incorporation
AND Registration 397
CHAP. XLV.
Chartered Banks 421
CHAP. XLVI.
Irish and Scotch Banks 422
CHAP. XLVIL
COLONLSX, InDLVN AND FOREIGN BaNKS 425
CHAP. XLVIII.
Branch Brinks 428
TABLE OF CONTENTS. XVU
CHAP. XLIX. PAGE
Shakes, Calls and Shareholders 431
CHAP. L.
Directors — their Qualifications, Powers, Duties and
Liabilities 444
CHAP. LI.
Manager— HIS Power, Duty and Liability 464
CHAP. LII.
Public Oeeicer — nis Functions 474
CHAP. LIII.
Criminal Liability of Members and Officers of Bank-
ing Companies 481
CHAP. LIV.
Attaching Funds in Bankers' Hands 487
CHAP. LV.
Winding-up and Dissolution of Banking Comp.^y .... 490
CHAP. LYI.
Bankruptcy 514
CHAP. LVII.
Bills of Sale 544
ADDENDA xxxviii
— ♦ —
APPENDIX.
Statutes in Force relating to England, Scotlant) akd
Ireland —
(1) Relating to England, Scotland and Ireland .... 574
(2) Relating to Scotland exclusively 674
(3) Relating to Ireland exclusively 696
INDEX 743
G. b
TABLE OF CASES.
A.
PAGE
AcHESON r. Fountain , 299
Ackland, In re 323
Adair, Ex parte 190
Adam, Ex parte 244, 537
Adams Ex parte 244
v. Bankhart 252
r. Claxton 183
• V. Ferich 441
V. Graham 555
Adams' case 503
Adamson, Ex parte 539
Addie t'. Westei-nBank of Scot-
land 469
Agra Bank v. Barry 175
and Masterman's Bank,
In re 414, 427, 451
and Masterman's Bank,
Ex parte Asiatic Co. . . 97, 99
and Masterman's Bank,
Ex parte Toudeur 100
and Masterman's Bank,
In re Barber 100
and Masterman's Bank r.
Hoffman 45, 489
Aldous r. Cornwall 22
Alexander v. Barker 197
V. Burchfield . .49, 51, 85
■ V. Mackenzie ..301, 466,
468
V. Sizer 27
Allen, Ex parte, Middleton,
In re 557
■ V. Dundas 26
V. Thompson .... 554, 555
Alletson r. Chichester 162, 164
Alliance Bank v. Kearsley 252, 260
Allsopp r. Day 545
Alsage V. Currie 294, 537, 540
Alston, Ex parte 181
Amory v. Mereweather 59
Ancona v. Marks 87
V. Rogers 563
Anderson's case 406, 408, 506
Anderson v. Thornton 224
Angas'.s case 505
PAGE
Ai-cher r. Bank of England . . 304
Arkwright v. Newbold 433
Armistead, Ex parte .... 141, 146,
148, 149
Armstrong r. BiimelL 440
Ex parte 161
Armytage, In re 549, 550
Ai-nold, Ex parte 525
V. Cheque Bank. . 18, 23, 24
Ai'tistic Color Printing Co., In
re 494
Ashbnry v. Riche 406, 407
Ashby V. James 242
Ashmead, In re 323
Ashton V. Blackshaw 546, 547, 562
r. Dilton 245
— r. Lord Langdale . , . , 431
Ashworth r. Miller 303
V. Outram 29
Astbiiry, Ex parte 550
r. Beasley 277
Astley V. G-urney 294
V. Johnson 255
Atkins V. Barwick 10
Ex parte .... 139, 153, 146
Attenborough v. Commissioners
of Inland Revenue 185
V. Mackenzie . . 297
V.St. Katherine's
Dock Co 184
V. Thompson . . 554
Attorney- General y. Brown and
others 483
r. Gilpin . . 21
Atwood V. Banks 260
Aubert r. Walsh 74
Austin V. Mead 88
Ayer r. South Australian Bank-
in^ Co 427
B.
Bacldiouse r. Carlton 171
Bags, In re 292
Bagshawc, Ex parte 418
b2
XX
TABLE OF CASES.
PAGE
Bagholt V. Norman 548
Bailey v. Bodenliam 56, 57
V. Finch 299
('. Johnston 540
r. Porter 103, 104
Bainbridge, Re 550
Baird's case 437, 440
Baker v. Charlton 257
V. Tynte 442
• Ex parte 536
Ball, Ex parte 232
Bainfield, In re 545
Banbury v. Lissett 106
V. White 554
Banco de Lima v. Anglo-Peru-
vian Bank 373
de Portugal, Ex parte.. 539
Bank, Agra and Mastennan's,
In re. Ex parte Wai-ing .... 5
Bank of Australasia r. Breillat 1 1 ,
445, 446
V. Harding 425
■ V. Nias . . 425
'Z'.Willan . . 445
Bank of Bengal v. Macleod 178, 360
■ V. Fagan ..178, 356
Bank of England, Ex parte 255, 307
r. Anderson 6,
330
V. Davis . . 321
V. Johnson.. 381
• r. Newman. 292
V. Parsons . . 317
v. Tomkins. 367
Bank of Hindustan v. Alison . . 448
, China and
Japan, Limited, In re .... 448
Bank of Ireland v. Trustees of
Evans' Charities 18
Bank of New South Wales v.
Owston 472
Bank of Scotland r. Christie. . 257
V. Watson . . 127
Bank of Switzerland v. Bank
of Turkey 512, 513
Bank of Upper Canada v. Brad-
shaw 473
Bank of Van Diemen's Land r.
Bank of Victoria 137
Banks, Ex parte 522
Banner, Ex jiarte 149
r. Johnstone 97, 522
Barber, Ex parte 250, 521
In re 210
Barclay v. Lucas 223
, Ex parte 549
Barfoot r. Go(Klall 75
Bargatc v. Shortridgc 458
PAGE
Baring's case 121
Barker and Aston 557
V. Buttress 381, 382
V. Parker 223
Barkworth, Ex parte 139, 142, 146
■ — — i'. EUerman 135
Bamed's Banking Co., In re. . 100,
136, 149, 242, 243, 395, 508, 509
(Helbert v. Banner) . 492
Massey, Ex parte . . Ill
Bamett, Ex parte, re Deveze 178,
522, 540
r. Brandao 250
Barnewall v. Sutherland 477
Barratt's case 500
Barraud, In re. Ex parte Coch-
rane 558
Barrick v. M'CuUock 342
Barron, Ex parte 518
Barry, Ex parte 164
Barwick v. London Joint Stock
Bank 469
Bateman's case. In re 238
Bateson v. Gosling 216
Bath's case 416
Batstone v. Salter 312
Bawden v. HoweU 31
Baynes v. Fry 303
Bays, In re 292
Beak v. Beak 88
Beale v. Caddick. . 197, 242, 251, 260
V. Tennant 555
Beattie v. Lord Ebuiy . . 35, 451,
274, 275
Beckham v. Drake 522
Beederman v. Stone 434
Beer v. London and Paris Hotel
Co 449
Bcgbie r. Levy 14
Begnold, Ex parte 14, 02
Belcher v. Campbell 138, 145
BeU V. Banks 210
V. Buckley 296
11. Carey 107
V. risk 476
Bellamy v. Majoribanks . . 18, 39,
53, 04
Benjamin v. Bank of England . 355
Benson, Ex pai-te 149
Bentley, Ex parte 109
Beresford r. Browning 255
Beny v. Gibbons 246
V. Jackson 252
Bevan v. Hill 80, 89
V. Waterhcad 441
Bcvoridge v. Bevcridge 27
Bickerdikc v. Bolman 537
Biddulpli, Ex parte 120
TABLE OF CASES.
XXI
PAGE
Bigg, In re 323
Bilborough v. Holmes . . 127, 257,
258
Billing V. Deraux 85
Bingold, Ex parte 536
Bird, Ex parte , 302, 505
Bird's case 503
Bishop v. Church 255, 540
V. Coimtess of Jersey .... 6,
121, 253
Bishop's case 410
Bishton, In re 323
Black V. Ottoman Bank 209
Blackburn, Ex parte 41
, Ex parte, re Cheese-
borough 527
Blackhouse v. Charlton 31
Blackwell r. England 555
Blain, Ex parte. Sawyer, In re 514
Blair v. Bromley 254
Blake, Ex parte 522
. V.Beaumont 103
V. Izard 547
Bleasby v. Crossley 77
Blew V. Wyatt 257
Block V. Bell 366
Blount V. Harris 554
Bloxam, Ex parte 503
Boardman v. Jackson 197
Bobbet V. Tinkett 23, 67
Bock V. Gorrissen 244
Boddington v. Schlencker 50, 51, 53
Bodenham v. Hoskin 122
V. Purchase 237
Boehm v. Sterling 85
Bolderot'.LondonDiscountCo. 516
BoUand, Ex parte ..528, 540, 564,
565
Ex parte, re Clint. . 526, 527
v. Bygrave 250
Bolton V. Lancashireand York-
shire Rail. Co 179
V. Puller 139, 147, 151, 256
V. Richards 41
Bonar v. Macdonald 229
v. Mitchell 378, 423
Bond, Ex parte 194
i\ Warden 51,52
Bone «'. Pollard 313
Bonser v. Cox 215
Booth V. Bank of England 330
V. Briscoe 283
r. Hutchinson 540
Borough of Hackney News-
paper Co 415
Bosanquet i\ Dudman 250
V. Shortridge 378, 379,
434, 436, 437,458
PAGE
Bosanquet v. Woodford .... 377
Boswell V. Smith 75
Boulor V. Mayor 209
Boyd r. Emmerson 54
BoydeU r. Harkness 104
Bowes V. Foreign and Colonial
Gas Co 249
Bradberry v. Morgan 207
Bradbury v. Dickens 256
Bradley v. Riches 175
Bramble, Ex parte, re Tolman 530
Brandao v. Baniett. .367, 244, 151,
246, 248
Brander v. Brander 324
Brandon r. Brandon 536
V. Scott 255
Beaujolais Wine Co., In re . . 497
Brantoni?. Grifaths. .545, 549, 550,
551
Branwhite, Ex parte 509
Brazier v. Hudson 190
Breslaur v. Brown 216
Brett's case 507
Brice v. Bannister 115
V. Stokes 280
Bridges r. Hawkesworth .... 359
Bridgman v. Gill 4
Briggs V. Boss 553, 555
V. Jones 175
Bright, Ex parte 521, 524
Brine v. Eerrier 88
British & American Telegraph
Co. V. Albion Bank. . 451
Foreign Gas Co 409
Linen Co. v. Caledonian
Insurance Co 94
Brittain v. Bank of London . . 73
Broadwood, Ex parte 169
Brocklebank, In re 518, 519
Brocklehurst v. Jessop 171
Broderick r. Scale 554, 555
Bromley v. Brunton . . . .60, 85, 88
V. Norton 28
Brook r. Enderby 241
Brooke, Ex parte 517
Brotherwood's case 460
Broughton v. Broughton .... 256
V. Davies 174
Brown's case 445
Brown, Ex parte 4
, Inre 194
i\ Adams 237, 279
V. Anderson 238
V. Bateman 547
V. Brown 308
V. Davies 53
V. London and North
Western Rail. Co. . . 306, 429
xxu
TABLE OF CASES.
PAGE
Brown V. Tanner 18G
Browning v. Baldwin 208
Brymer, In re 29
Bryson v. "Wylie 144
Buchanan, Ex parte 154
V. Findlay 295
Buck, Ex parte 521
V. Eobson 115, 439
Buckley, Ex parte 538
• V. Jackson 300
BuU, Ex parte 435
Bunney, Ex parte 517
Burchiield v. Moore 105, 112
Burgess v. Eave . . . .205, 207, 208,
228, 410
Burmester r. Norris 273
Burn V. Biu-n 255
V. Carvalho 114
V. Pennell 459, 4G2
Burton Bank, Ex parte . . 149, 154
Burton, Ex parte . . . .523, 564, 565
• V. Tajaie 72
Bush's case 453
Butchai-t V. Dresser 479
Butcher, Ex parte 538
r. Stead 527
Button r. O'Niell 554
Bycrly v. Prevost 545
Byron v. Metropolitan Saloon
Omnibus Co 408
C.
Gainer. Coulton ....43, 341, 366
Calisher v. Forbes 49
Calland v. Lloyd 26
CaUey r. Short 119
Calvert v. Gordon 207
Camidge v. Alleuby . . 38, 61, 343,
348
Campbell v. Rothwell 213
Cannington, Ex parte 514
Cape, Ex parte 510
Carcw,'Inre 198, 292, 451
V. Duckworth . .61, 62, 86
Cargill V. Bower 451, 506
Carr v. Carr 3
. V. Ecad 26
Carrard v. Meek 563
Carstau-s v. Bate 291
V. Stein 203
Carter, Ex parte 517, 553
Gary v. Gerrish 77
Gasbard v. Attorney-General . 174
Castle ('. Downton 551, 555
Cathcart, The 187
PAGE
Catholic Publishing Co., Re. . 493
Caton v. Caton 202
Gavander v. Bulteel 256
Cavendish v. Greaves 197
Gefn Cilcen Mining Co 274
Challen v. Shippam 276, 278
Challinor, Ex parte 559
Challis's case 410
Chambers v. MUler 43
V. Minchin 281
Chapman v. Beckington . .203, 223
V.Hart 342
V. Knight 548
V. Milvain 475, 476
Charing Cross Bank, Ex parte 559
Charles v. Black well 25
Charlton, Ex parte 209
Chashill V. Wright 191
Cherry r. Colonial Bank of
Australasia 275
Chinnery v. Evans 171
Chippendale, Ex parte . .273, 473
Chissum r. Dewes 172
Cholmely V. Darley 218
Chowne v. Baylis 232
Christie v. Peart 475
Church V. Bishop 109
Citizens' Bank of Louisiana
V. Bank of New Orleans . . 136
City Bank r. Luckie 149
Discount Co. v. M'Lean . 237
Claridge v. Hoare 231
Clark, Ex parte 354
V. Hart 461, 462
r. Laurie 313
Clayton's case 120, 237, 253
Clayton v. Gresham 324
Clerk r. Laiu-ie 117
Cleve V. Harwar 386
Climie r. Wood 550
Glode V. Bayley 429
Clough r. Bond 26, 324
Glutton, Ex parte 100
Goate's case 442
Cochrane v. O'Brien 130
Coe, Ex parte 262
Goggs V. Barnard 191
• r. Bernard 184
Cohen, Ex parte 564
Coke Co. V. Dickinson and
Pollard 210
Cole t'. N. W. Bank 182
Coles V. Bank of England . . 18, 314
r. Bristowe 434
Collen V. Wright 27, 302
Collin, Ex parte. In re Leea. . 557
Collins V. Martin 146, 147
CoUinson v. Lister 466
TABLE OF CASES.
xxm
PAGE
Collyer v. Isaacs 548
Colne Valley Act, In re 309
Commercial Bank, Corporation
of India and the
East 498
Bank of Scotland
V. Rhind 197
Cook v. Addison 278
V. Lister 109
i\ Seeley 32
Cooke, Ex parte 521,528
i: Seeley 261
Cockney's case 503
Cooper, Ex parte 545
■ V. Ibberson 555
Conflans Stone Quarry Co. r.
Parker 96, 101
Connelly v. Steer 557
Conning, Ex parte 546
Cope r.Glyn 478
Copland's case 258
Copland r. Davies 422
Cork and Brandon Rail. Co. v.
Goode 510
and YoughaU Rail. Co. . . 273
Cory V. Davis 125
Coulthart v. Clementson .... 207
County Life Assiu-ance Co. . . 445
Courtould V. Sanders 414
Courtoy v. Vincent 81
Coventry v. Gladstone 181
Coward r. Hughes 221
Cowell, Ex parte 169
r. Simpson 250
Cox, Ex parte. Re Read .... 526
V. Bishop 171
v. Masterman . .• 108
Cragg V. Taylor 442
Cragoe v. Jones 216
Crane v. Loftus 479
Craucour, Ex parte 544, 547
I'. Salter . .521, 523, 547,
564
Crauford r. Cocks 128, 257
Craven, Ex parte 527
Credit Co. r. Pott 563
Credit Foncier, Ex parte .... 456
CrelUn r. Calvert 428
Crisp V. Bunbury 266
Crispin, Ex parte. . . .515, 516, 517
Crosheld v. Such 312
Croskey v. Bank of Wales 406, 439
Croskill V. Bower . .4, 6, 199, 200
Crossfield's case 505
Crossley v. City of Glasgow
Life Assurance Co 163
Crouch V. Credit Foncier of
England 370
PAGE
Croydon Commercial Gas, Coal
and
Cruise v. Paine 500
Cullen V. Thompson 640
Cullwick V. SwindeU 550
Cumming r. Bailey 517
r. Shand 48
Curry v. Misa 33
Curtis V. Livesay 302
D.
Da Silva v. Fuller 14, 59
DagUsh, Ex parte 549
Daniel v. Cross 127, 257
Daniell r. Royal British Bank . 386
Dann, Ex parte 516
Dai-rach r. Savage 42
Dartford Savings Bank, The. . 269
Davey v. Pendergrass 209, 211
Davidson, Ex parte 381
i\ Cooper 112, 476
V. Robinson 528
V. Stanley 27
Davies v. Games 256
V. Jenkins 28
V. Stambank 220
Davis V. Bank of England . .314,316
V. Bowsher 248
V. Goodman 557, 560
r. Spui-ling 281
Day V. Day 441
De Bemales v. Fuller 108, 110
De Cosse Biissac v. Rathbone . 425
De Mattos v. Gibson 186
De Roebuck y. Lord Cloncurry 2
De Tastet v. Baring 374
Deacon v. Stodhart 109
Dear, Ex parte 538
Dearie v. Hall 4
DefPel V. AVhite 556
Dehors r. Harriott 58
Delawar, Ex parte 354
Demainbray v. Metcalfe 183
Devaynes v. Noble 196, 237
Clayton's case 120
Devonport and South Devon
Steam Flour Mills Co 238
Dewhurst, Ex parte 136, 149
Dickinson v. Bowes 347
Dickson's case 540
Dickson, Ex parte 41
r. Cass 355
V. Evans 540
Diggle r. Higgs 117
Dilworth, In re 149
Dilworth ifc Co., In re 141
XXIV
TABLE OF CASES.
PAGE
Diplock V. Hammond 114
Dixon V. Muckelstone 175
• V. Nuttall 60
Dodgson V. Bell 436
V. Scott 381
Donald v. SuckUng 250
Dorman, Ex parte 523
, Ee Lake . . 525
Dorsett v. Harding, 386
Douglas, In re 252
V. Congreve 308
D'Ouseley's case 505
Down V. Hailing 58
Downes v. Ship 448
Drake v. Martin 325
Dressier, Ex parte 522
Drever v. Maudsley 283
Droniield Silkstone Coal Co.,
In re 408, 456, 460
Dry V. Davey 223
Dryden v. Erost 172
Dumas, Ex parte 146
Duncan v. Cashin 29
, Fox & Co. V. New S.
Wales Bank . . 215, 536
V. Lowndes 252
Duncuft V. Albrecht 434
Dunn's case 92
Dutton V. Marsh .... 27, 414, 450
E.
Earl of Bristol v. Welsmore . . 82
East of England Banking Co.,
In re 61, 348,498
Easton v. Tratohott 88
Eaton V. Bell 273
Ebbs V. Boulnois 543
Edie V. East India Co 299
Edmunds v. Bushell 27
Edwards, Ex parte 157, 296
V.Buchanan 377
V. 475
■ V. English 558
V. Edwards 546
r. Ulynn 158
■ V. Martin 161
V. Newman 351
V. Vcro 125
Elliot, Ex parte 534
V. Turquand 540
Ellis, Ex parte . .184, 494, 518, 521
V. Enunauuel 206
V. Griffiths 479
r. Wilmot 216
Elmbley v. (Jorrie 64 1
Emanuel v, Bridger 562
PAGE
Emblin v. Dartnell 113
Emly V. Lye 30, 292
Emdon v. Carte 522
Emma Silver Mining Co. v.
Grant 541
Emmerson, Ex parte 523
Emperor of Austria v. Cossuth. 338
English and American Bank,
Ex parte 516
V. Darby 536
Epinuel, In re 560
Esdaile v. Maclean 475
European Bank, In re. . . .245, 537
Eustace v. Dublin Trunk Rail. 167
Evans v. Bembredge 210
V. Coventry 504
V. Drummond 258
Eykin, In re 312
Eylesr.EUis 119
Eyre, Ex parte 121, 246
t'. McDowell 468
V. WaUer 84
Fanshawe f . Peet 107
Farhall r. FarhaU 246, 282
Farley, Ex parte 173
v. Turner .. 107, 110, 111,
135, 242, 295
Farquhar v. City of Toronto. . 114
Fawcett v. Laurie 463
Fayle V. Bird 103
Felgate's case 410,433
Fell V. Burchett 389
Fellows V. Mitchell 280
Fenwick r. Clark 276
Fernandez v. Glynn 61
Field V. Lonsdale 264
Finch V. Marcon 277
Findlay, Ex parte 539
Finlay, Ex parte 506
Fisher, Ex parte 185, 565
— • V. Calvert 115
Fleet, Ex parte 269
Fletcher, Ex parte 523, 540
V. Manning 78
V. Walker 282
Flower r. Shaw 91
Foley V. IIUl 2, 4, 5
Forbes' case 4
Forbes v. Marshall 252, 366
Fordliam r. WaUis 171
Forster v. Clements 23, 108
V. Green 472
V. Lawson 283
TABLE OF CASES.
XXV
PAGE
Forster i>. Mackreth 30
V. Surtees 353
V. Wilson 342
Fortescue v. Barnett 162
Fortune Mining Co 409
Forwood's Claim 100
Foster v. Bank of England . . 311,
316
V. Bank of London . , 7
• Ex parte 517
V. Parker 536
Fountain's case 401, 501
Fountaine v. Carmarthen Rail.
Co 33
Fowler v. Foster 547
Fowler's case 444, 503
France v. Woods 276
Frank v. Edwards 228
Franklin v. Bank of England .312
Franks, Ex parte 514
Eraser v. Jordan 211
Frith, Ex parte, Cowburn, In re 559
Frowd, Ex parte 482
Fruhling v. Schroeder 8, 116
Fry V. Russell 386
Fryer v. Ranken 2
Fuentes 1^. Montis 183
Furber, Ex parte 564
Fydell r. Clark 292
G.
Gallini v. Noble 308
Gammon r. Schmoll 102
Garden v. Bruce 77
Gardner v. Lachlan 177
Garland v. Jacomb 252
Garnett Gold Mining- Co. of
America v. Sutton. . 501
Mining Co. V. Sutton . 401
V. McKewan..48, 199, 246,
300, 430
V. Woodcock 103
Garrick v. Taylor 432
Gatty V. Fry 20
Gaunt V. Taylor 281
GeneralFurnishing and Uphol-
stering Co. r. Venn 547
General Provident Ass. Co., In
re National Bank 176
General S. American Co., In
re 374, 416
General S. American Co., Ex
parte 149
General S. American Co., In
re. Ex parte Banco de Lima 100
Gibb V. Mather 103
PAGE
Gibbs r. West 509
Giblin v. McMidlen 192
Gibson v. Minet.8, 10, 21, 114, 116
Gilbert's case 409
Gilbey, Ex parte 520, 525
Giles r. Perkins. . 141, 144, 145, 146
Gill V. Continental Gas Co. . . 442
V. GiUingham 341
Gill's case 509
Gillard v. Wise 341
Gladstone and Ottoman Bank 339
Glegg, Ex parte 522
V. Gilbey 218
Goggerly v. Guthbert 177
Gomex, Ex parte 149
Goodbody v. Foster 83
Goodwin v. Robarts 2
V. Roberts 370
Gordon, Ex parte 355
V. East India Co 161
Gordon's case 436
Gorgier v. MelviUe 370
Gosden ;-. Dotterill 308
Gough r. Da-\-ies 127, 257
V. Everard 561
Grady's case 460
Graham v. Connell . . 441, 442, 481
V. Wilcoxon 545
Grainger v. Slingsby 325
Grant v. Shaw 554, 555
— V. Vaughan 21
Gray v. Johnston 47
Green v. Bank of England .... 315
■ v. Carhill 29
r. Wynn 216
Gregoiy v. Patchett 456
Grepe, Ex parte 520
Grey r. Kentish 522
Grigby v. Oakes 342
Grigg v. Cockney 243
Grindell v. Brendon 553
Gri.ssell's case 509
Gross, In re 190, 239
Gwaitkin r. Campbell 465
Gwyn, Ex parte 302
V. Godley 4
H.
Hale v. Saloon Omnibus Co . . 547
Halford v. Cameron Coalbrook
Co 33
Halifax Union v. Wheelright 18
Haley v. Hammersley 550
Hallmark's case 444
Hall, Ex parte, In re Cooper 527
XXVI
TABLE OF CASES.
PAGE
Hall f. FuUer 18, 108
f. West 257
V. Wilcox 220
Hallett's Estate, In re 123
HaUett r. HaUett 540
Halstead v. Skelton 103
Hamilton r. Chains 559
, In re 237
Windsor Ironworks,
In re 274
Hamlyn v. Betteley 560
Hammersly v. Knowlys 297
Hanunett v. Yea 303
Hampden v. Walsh 117
Hamer t'. Giles' District .... 487
Hancock v. Lablache 29
Hancon v. Allen 324
Hankins v. AVhitten 517
Hanky v. Berwick 106
Hans, Re 555
Hansard v. Robinson 357
Hanson, Ex parte 260
Harding v. \Villiams 316
Hardy v. Veasey 7
V. Woodrooffe 106
Hare r. Copland 11, 22, 101
r. Henty . .49, 51, 52, 53, 55
Harlock v. Ashberry 171
Harris, Ex parte 518, 538
V. EaAvcett 207
r. Parker 104
V. Royal British Bank 363
V. Truman 521
V. Venables 202
Harrison v. Beving-ton 283
V. Brown 476
V. Cohen 185
■ -, Ex parte 164
, In re 139, 142, 146
Hart V. Alexander 127, 258
Hartga v. Bank of England . . 317
Hartland v. Jukes 188
Hartop r. Hoarc 183
Harvey v. Cricket 352
V. Scott 377
Harward's case 444
Harwood r. Law 382, 479
Hattersley, Ex parte 524
Hatton V. English 554
Haseltinc r. Siggers 370
Hawken v. Bourne 473
Hawker, Ex parte 564
Hawkins v. Allen 88
V. Wakond 551
V. Whitten 355
Hawse v. Crowe 82
Hawtaync r. Bourne 473
Hayman, Ex parte 523, 521
PAGE
Haythorn v. Lawson 283
Haywood r. Pickering .... 52, 57
Heane r. Roberts 197
Heath v. Percival 258
Heather r. Webb 541, 542
Heaton, Ex parte 281
Hebbell, Ex parte 515
Heffield r. Meadows 206
Heming v. Clutterbuck 88
Hemming, Ex parte 541
Henderson v. Appleton 346
V. Gilchrist 349
I'. Henderson 425, 510
V. Royal British
Bank 435
Hendricks v. Montague 406
Hennessy, Ex parte ,' 162
Henniker v. Wigg 221
Herefordshire Banking Co., In
re 347
Herschfield v. Brown 302
Herbert v. Sayer 522
Hertford (Marquis of). In re. . 318
Heseltine v. Siggers 309
Heslop V. Bank of England . . 316
Howard v. Wheatly 440
Hewer r. Cox 553, 554
Heweson r. Guthrie 250
Hewett V. Raye 50, 88
Hewitt V. Raye 130
Higgins r. LiAangstone 273
■ -W.Nichols 103
Higg's case 448
Hill's case 432
Hill i\ Kirkwood 552
i: Royds 110, HI
V. Smith ..107, 110,242, 295
HlUs r. Parker 178
r. Shepherd 557
Hinsdale v. Bank of Orange . , 358
Hoare's case 606
Hobb's case 503
Hobson V. Bass 536
Hockley r. Bantock 168
Hodgkins, Ex parte 187
Hodgson r. Anderson ..8, 87, 114
Hogarth v. Latham 31
r. Whaley 27
Holl r. The Mercantile and
Exchange Bank Limited .. 198
Holland, Ex parte 514
■ — • r. Hodgson 550
HolUer r. Eyre 220
Holme r. Binney 477
V. Brinskill 209
Holroyd c. Whitehead 51(5, 517
Homan, Ex parte 565
Hoonian, Ex parte . 562
TABLE OF CASES.
XXVU
PAGE
Hone V. O'Flahertie 383
Honey, Ex parte 539
Hooper, Ex parte 168
V. Keay 237, 240
Hopecraft, Ex parte 546
Hope V. Cust 30
V. lutemationalFinancial
Society 406, 451, 461
Hopkin's Trust, Re 324
Hopkins v. Abbot 3
i-. Warr 49, 51
Hopkinson v. Poster 4, 115
r. Eolt 173
Hordem r. Dalton 356
Hornblower r. Proud 158
Horn V. Baker 523
Home r. Hughes 558
Homsby r. Millar 523
Hosegood V. Bull and Eing-
dom : .- 469
Hotham r. Sutton 308
Hough v. May 76
Houldsw'orth r. City of Glas-
gow Bank. . . . 469
V. Evans . .437, 440,
460
Howard r. Baillie 27
Howe V. Bowes 347
HoweU I', Jones 210
V. Metropolitan Rail-
way 487, 488
Hudson's case 508
Hughes, In re 313
V. Spooncr 144
Hiimberstone v. Chase 318
Hiunble r. Mitchell 433
Hume V. BoUand 197, 314
Hunt, Ex parte 172
V. Peacock 323
Hunter, Ex parte 30
Husband v. Davies 30
Hutton r. Cruttwell 565
V. Scarborough Hotel
Co 406
Huxtable, Ex parte 526
I.
Ibbetson, Ex parte 161, 523
Imperial Anglo-German Bank,
In re 513
Bank of Chma 497
Guardian, &c. So-
ciety, In re 493
Land Co. of Mar-
seilles, In re 485
Mercantile Credit
Co., In re 511
PAGE
Ingham v. Primrose . .59, 100, 112
Innes i\ Stephenson 30
International Pulp Co 415
Ii'vine V. Union Bank of Aus-
tralia 274, 406, 445, 456
Irving, In re 161, 164
V. Yeitch 76
J.
Jackson, In re. Ex parte Hall 565
V. Turquand 463
Jacobs, Ex parte 216
, In re 216
Jakeman v. Cook 542
James, Ex parte 517
r. Holditch 347
r. James 171
Jameson v. Bi-ick and Stone Co. 522
v. Swinton 49
Jay, Ex parte 502
Jeffryes v. Agra, and Master-
man's Bank 248
Jenkins v. XJsbome 182
Johns V. Mason 89
Johnson, Ex parte, Inre United
Service Co 193
V. Gallagher 28
r.Lithes Iron Agency 462
V. Lyonnais Co. 181, 182
!•. Newton 276
V. Robarts 136, 242
Johnston v. Renton 434
Jombert r. WooUet 146, 152
Jones, V. Arthur 43
Ex parte 515
, Ex parte, In re Grissel. . 514
V. Gibbons 162
V. Harber 185
V. Harris 553, 554
V. Peppercorn. . 244, 248, 370
p. Ryde 302
Joy v. Campbell 200
K.
Karet r. Kosher Meat Supply 558
Keane v. Robarts 281
Kearney v. King 16
Kearsley r. Cole 216
Keene's Executors' case . .453, 505
Keene r. Beard 22, 84, 85, 87
Keith V. Biu-rows 186
Kellock's case 100
Kellsall r. Marshall 420
Kelly, Ex parte 528
XXVIH
TABLE OF CASES.
PAGE
Kelner r. Baxter 27
Kelsby v. Williams 54
Kendall v. Hamilton 250
■ v. Kendall 308
Kensington, Ex parte 189
Kerwan r. Kerwan 257
Kevan, Ex parte 528
Keys, Ex parte 355, 517
r. Williams 168
Kibble, Ex parte 519
IviddUl r. Farnell 313
Kilner, Ex parte 564, 565
Kincard's case 444
King V. Bradley 4
V. Zimmerman 89
King's Cross Industrial Dwel-
lings Co., In re 493
Kingston, Ex parte. .239, 279, 621
, Ex parte, In re
Gross 122
Kinirerly v. Hosack 540
Kinnaird r. Webster 208, 237, 244
Kirk r. Bell 449
r. Blurton 30,31,252
Kish r. Central KaU. Co. of
Venezuela 506
Knott, In re 560
Knowles' Mortgage 415
Kymer v. Laurie 45, 107
La Banca Nazionale Scde di
Torino r. Hamburger .... 427
Lacey r. Hill 254, 538
Lacou v. Allen 168
V. Liffen 187
Ladbuiy, Ex parte 522
Laing i\ Campbell 237
Lake r. Gibson 312
Lamb v. Attenborough 182
r. Bruce 555
Lambton, Ex parte 149
Lancaster Banking Corpora-
tion, Ex parte 543
Land Credit of Ireland v. Fer-
moy 456
Lanesborough v. Jones 540
Langdalc r. ■S\niitfield 3
Langford, In re 309
Langton r. Ilorton 171, 187
r. Waite 316
Lanj-on v. Smith 401
La Touche r. La Toucho .... 221
Latta, y.x parte 513
La Vie v. I'hillips 514
Law, Ex parte 540
PAGE
Law V. Pamell 467
V. Thompson 466
Laws V. Rand 49
Lawson v. Bank of London . . 408
Layton v. Horton 187
Lazarus v. Andrade 548
Leadbitter v. Farrow 27
Leask r. Scott 179
Leathley v. Spyer 216
Lee V. Glutton , 175
V. Sankoy 279
V. Stewart 30
Leeds Bank, Ex parte 147
Banking Co., In re ... . 437
, Ex
parte Prange 113
Leese v. Martin 244, 246
Le Fanu v. Malcolmson 283
Leftley r. MUls 60
Leifchild's case 506
Leslie, Ex parte 534
Letts V. Morris 114
Levy V. Walker 172
Lewis, Ex parte 562
V. Leonard 542
Lichfield Union v. Greene . . 39,
234, 348
Lickbarrow v. Mason 179
Lilly V. Hays 8, 116
Lindsay v. Cundy 522
Lindus v. Melrose 414
Lingham v. Biggs 523
Liquidators of Overend, Gur-
ney & Co. v. Liquidators of
Oriental Financial Corpora-
tion 213
Lister v. Payne 185
Little r. Slackford 13
Liverpool Borough Bank v.
Mellor 394
Lloyd, Ex parte 169
V. Pugh 28, 29
V. Sandilands 74
Lloyds V. Harper 207, 227
Locke V. Prescott 247
Lodge r. Dicas 257
Lomax r. Buxton 185, 565
V. Hyde 172
London, Bombay, &c. Bank,
In re 297
and Medi-
teiTanean Bank, In re. .438, 505
r. NaiTaway . 294
London Cliartered Bank of
Australia I'. Lempriore 29
V. Wliite 244
London and County Bank, Ex
parte.. 527
TABLE OF CASES.
XXIX
PAGE
London and County Banking
Co. v. Groorae . . 59
r. Ratcliffe 173
London and Eastern Banking
Corporation, In re . . 286
, Hamburg and Conti-
nental Exchange Bank . .455, 508
London and Mediterranean
Bank, In re 460, 461
Mercantile Discount
Co., In re 497
and North Western
Rail. Co. V. Whinray 228
and Provincial Coal Co. 460
— — Telegraph Co. 409, 437
London and Westminster Loan,
&c. Co. V. Chase 554
Longbottom v. Berry .... 170, 550
Longman v. Pole 254
Longworth, Ex parte 386
Loughnan v. Barry 82
Lovell V. Newton 29
Levering, Ex parte 524
Lowrey v. Barker 522
Loyd V. Freshfield 4
Luard's case 438, 505
Lucas V. Dicker 525
■ V. Dorrein 249
I'. Wilkinson 179
Lumley v. Timms 29
Lynch, Ex parte 615
V. Fitzgerald 266
Lyons r. Tucker 557
Lysaght v. Walker 235, 238
Lyth V. Ault 128, 257
M.
McArdly v. Irish Iodine Co. . . 449
M'Cue v. James ; . 555
McClean v. Kennard 256
McDonnell r. Murray .... 19, 357
McDowell V. Dogle 477
McGowan v. Dyer 469
t;. Smith 114
McGrath v. Gray 216
McHaltie, Ex parte 555
Mclntyre v. Connell 443, 481
■ V. Miller 475
McKenna, Ex parte 249
V. Eolt 477
McKewan's case 406
Mackay, Ex parte 546
V. Commercial Bank
of New Brunswick 469
Mackenzie, Ex parte 554
Mackersay v. Ramsay 134
PAGE
Mackintosh v. Haydon . . 105, 106
Madrid Bank v. Bailey 463
Maguire's case 436
Mahoney v. Donovan 342
V. East Holyford
Mining Co 33, 34, 448, 449
Maingay r. Lewis 209
Maitland r. The Chartered
Mercantile Bank of India,
London and China 96, 98, 99
Malcolm r. Scott 4
Manchester and Liverpool
Bank, Ex parte 518
Manchester Bank, Ex parte . . 533
Manchester and County Bank,
Ex parte 538
Manchester and County Bank,
In re 244,249
Manley v. Boycott 220
Manning t\ Purchell 3
v. Westeme 238
Manningford v. Toleman .... 246
Mansfield, Ex parte 503
Mapleback, Re 534
Mare r. Charles 27
Marquis of Abercom's case . . 445
Marsden v. Meadows 545
Marsh v. Houlditch 297
r. Keating 253
Marshall v. Crutwell 28
Marstead v. Paine 434
Martin, Ex parte 521
«'. Read 184
Marzelli i\ Williams 45
Massey, Ex parte 136, 242, 243
Master r. MiUer 105
Mastei-man r. Cowrie ........ 303
Masters v. Baretto 113
Mather v. Eraser 550
Mathew v. Sherwell 62
Mathewman's case 437, 504
Mathews v. Brise 276
Mathewson's case 28
Mathieson v. London and
County Bank 71
Matthews, Ex parte 528
Maude, Ex parte 638
Maxfield v. Burton 175, 246
Maxwell's case 406
Mayhew's case 436
Mayo's (Lady) case 317
Mayor r. Johnson 358
Maj'or of London v. London
Joint Stock Bank 487, 488
Mead, In re 130
Mcaux r. Jacobs 548
Meek v. Baylis 168
V. Wallis 207
XXX
TABLE OF CASES.
PAGE
Mellershr. Kean 256
Mellish r. Simeon 374
Melville i: Doidge 225
Meuzics v. Lightfoot 173
Merchiint Banking Co. v.
Phcfinix Bessemer Steel Co. 179
Merchant Banking Co. of
London r. Merchant Joint
Stock Bank 408
Merchants Bank of London v.
Maude 213
Metcalfe r. Bruin 223, 224
Metropolitan Counties Co. r.
Brown 550
Meux's case 454
Meux V. Jacobs 169, 170
Meyer, Ex parte 517
Middleton v. Barned 293
Midland Banking Co. , Ex parte 206
Midland Ins. Co. r. Smith. . . . 232
Midland Rail. Co. v. Chalmers 536
• V. Taylor . , 314
Miles V. Williams 522
Miller's case 444
Miller v. Austen 130
r. Race 356
r. Thompson 467
MOls V. Alderbury L^nion .... 234
z'. Bennett 517
V. Oddy 77
Milnes r. Dawson ,*. . 88
Misa r. Cun-ie 244, 249
Mitchell's case 13
Mitford V. Mitford 522
Mittam, In re 324, 32o
Moffat V. Farquluir 409, 457
Moore v. Barthrup 76
V. Bushel! Ill, 137
V. Greg 171
(Sii" John) r. Gold
Mining Co 600
r. Lister Banking Co. . 130
Moore's Co., Ex parte 171
Morewood r. S. Yorkshire Rail.
and River Dun Co 555
Morgan v. Lari%ai;i"e 116
■ — V. Morgan 352
Morier, Ex parte 540
Morley v. Bird 312
■ V. Culverwell 59
Morrcll v. Cowan 206
V. Woottcn 114
Morrisse v. The Royal British
Bank 385
Mortimer r. McCallau 316
Mortlock, E.V parte. In re
Bashara' 562
Mortou c. Woods 547, 552
PAGE
Moscow Gas Co. r. Interna-
tional Financial Co 419
Mosse r. Salt 6, 198, 200, 201
Moule V. Brown 50, 52
Mountford v. Harper 74
Mountfort, Ex parte 168
Moyser v. Whitaker 60
Muchlow V. May 517
Muir V. City of Glasgow Bank 506
V. Crawford 209
Mumford r. Stowasser 175
Murray r. Bush 436, 453
V. Ellibank 522
r. Judah 43
V. Mackenzie 554
V. Pinkett 247
Murrow v. Stuart 200
Mutrie, Ex parte 516
Mutton, Ex parte 563
Muttylol Seal v. Dent 130, 295
Myers v. Perigal 431
N.
Naoroji v. Bank of India .... 540
• V. Chartered Bank of
India 294
National Bank, Ex parte 416, 450,
536
of America v.
Bangs .... 57
of St. Charles
v. De Ber-
nales 427
of the Repub-
lic r. Millard 87
National Mercantile Bank, Ex
parte 550, 553, 555, 559, 560
National Mercantile Bank v.
Hampson 564
National Permanent Benefit
Building Society 273
Native Iron Ore Co 416
Naylor v. Mortuner 307
Ncodham v. Law 478
Ness, Ex parte 382
V. Angas 436, 438
V. Armstrong 436
v. Bertram 436
Newitt, Ex parte. In re Gar-
rard 54 7
Newton, Ex parte. In reRees . 537
New Zealand Bank, In re 149
Nichol, Ex parte 433
Niclujlsou r. Ricketts 30
Nicol's case 159
Nicoll.'j V. Rosewame 443
TABLE OF CASES.
XXXI
PAGK
Nightingale v. Devisme 308
Noble r. Adams 82
('. Bank of England 357
North British Insm-ance Co. v.
Lloyd 212
North V. Wakefield 216
Northampton Coal Co. v. Mid-
land Waggon Co 419
Northumberland and Durham
District Banking Co., Ex
parte Totty 499
Northumberland and Durham
District Banking Co., In re 394,
494, 497
North-WestemBank, Exparte 182,
548
Norton v, Ellam 360
V. Seymour 31
Novelli r. Rossi 106, 1 11
O.
Oakes, Ex parte 189
V. Turquand . .410, 433, 506
O'Connor v. Marjoribanks .... 246
Odell, Ex pai-te 545
Offord V. Davis 207
O'Flaherty v. McDowell .... 422
Ogden V. Benas 23
Ogg V. Shuter 179
Okell V. Charles 414
Orielly v. Richardson 301
Oriental Commercial Bank, In
re 507,508,539
Orr V. Union Bank of Scot-
land 18, 94
Other V. Iveson 73
OurseU, Ex parte 139
Overend, Gui-ney & Co. v. Gibb 450
. r. Oriental
Financial Corporation . .209, 211
Page V. Young 3
Pannell v. Harley 247
Paris V. Paris 324
Parker, Re 559
• r. Gordon 49, 103
V. Marchant 2
Parks V. Edge 104
Parrot v. Eyre 273
Parry v. Nicholson 112
Partridge r.'Coates 72
Pascal, Ex parte, Myer, In re . 515
Patent File Co 416
PAGE
Patent File Co., In re, Ex parte
Birmingham Banking Co. . . 176
Paterson r. Ironside . . . .477, 479
Pattison v. Bedford Union . . 235
Pauli, Ex parte 151
Payne, Ex parte 185, 550, 564
, Ex parte. In re Cross . . 549
— V. Fern 564
Paynter v. Houston 258
Pearce v. Creswick 126, 127
V. Davis 77
Pearse r. Pemberthy 113
Pease, Exparte. .145, 147, 148, 153
V. Hirst 189, 292
Peate v. Crane 324
Redder r. Preston 239, 540
V. Watts 118
Peek V. Gurney . , , 451, 460
Peele, Ex parte 259
PeUatt's case 503
Peltz V. Cooke 218
Pemberton v. Chapman 280
v. Oakes 203
Pender v. Lushington 457
PenneU ?'. Deffel ..,.123,237,279
Penney, Ex parte 434
Penny, Ex parte 457
People's Garden Co 494
Perring v. Dunston 330, 383
Perwarden r. Roberts 552
Pettit's Estate, In re 543
PhilliiJS, In re 650
V. Eastwood 308
V. Foxall 208, 228
r. Gibbons 545
Pliilpot V. Bryant 106
Philps r. Homstedt 185
Phipps V. Tanner 17
Phosphate of Lime Co. v.
Green 456, 460
Picard v. Breby 554
V. Man-iage 554, 562
Pickering v. Busk 469
Pierson v. Pounteys 16
Pigot V. Chubley 183
Pike V. Fitzgibbon 28
Pillars, Ex parte, re Curtoys . 525
Pinkett v. Wright 457
Pinto V. Santos 87, 115
Pitcher v. Rawlins 175
Pitman, In re, Edwards, Ex
parte 274
Plummer v. Gregory 254
Poeklington v Sylvester 50
Polak V. Everitt 209
Polhill V. Walter 301 , 302
PoUard v. Bank of England ..43,57,
110
XXXll
TABLE OF CASES.
PAGE
PoUard r. Ogden 105, 297
Polyglass V. Oliver 342
Pond V. Underwood 26
Poole V. Middleton 457
Pophara V. Lady Aylesbuiy . . 342
Pothoniei" r. Dawson 183
Pottr. Clegg 4, 130
Poulson, Ex parte 539
Powell, Ex parte 523
, In re 2
Powels V. Page 451
Powis V. Butler 386
Powles r. Page 380
Prelin v. Liverpool Bank. . 100, 374
Prescott, Ex parte 510
■ V. Biiffery 378
1'. Plinn 27
Price, Ex parte 169
V. Edmunds 220
V. Great Western Rail.
Co 370
Prid, Ex parte, re Lankester. . 540
Prideaiix r. Creddle 52, 57
Prince v. Oriental Bank . . 106, 199,
246, 300, 429
Pritcliard, In re 487
Prosser v. Bank of England . . 310
r. Wagner 26
Pryce, Re 164
Pugh's case 437
Puller V. Roe 255
Punnett, Ex parte 534
R.
R. V. Aspinall 459, 462, 483
— V. Ckristoi^her 359
— V. Giles 363
— V. Mildcnhall Savings Bank 2C6
— V. Moore 359
— v. Norwich Savings Bank. . 266
— V. Skeen 484
— r. Witham Savings Bank. . 266
— V. WooUey 365
Rai Sri Kishen v. Rai Huri
Kishcn 426
Rainbow v. Juggins 214
Rainev, In re 515
Ram, Ex parte 323
RanichurnMidlicki'.Luchmee-
chund Radakissen 35
Rainsdeu r. Brcarley 514
V. Luptou 5G3
Ranco's case 411
Randall v. Trimen 27
Raudleson, Ex parte 197, 242
Ranaford v. Bosanquet 381
PAGE
Ransford v. Maule 517
Paper v. Birkbeck 106, 112
Raphael v. Bank of England. . 356,
360
RasteU v. Draper 16
RatclifPe r. Barnard 175
Rawley v. Rawley 540
Redmayne v. Burton 89, 357
Reed v". Bailey 254
Reese Silver Mining Co. v.
Smith 503
Reg. V. Adams 489
V. Ashby 93
V. Atkinson 131, 481
r. Autey 91
V. Boreham 17
i: Burch 484
V. Carter 377
V. Clark 364
r. Cooke 362
V. Dixon 357
V. Esdaile 483
V. Essex 91
r. Evans 364
V. Fletcher 271
V. Foulkes 230
r. Garrett 99, 132
V. Ilarley 92
V. Harper 92
V. Ilayleton 91
i'. Inhabitants of the Pa-
rish of Lee ....171,550
V. Ion 131
V. Jessop 365
V. Johnston 131
v. Martin 92
V. Moody 198
V. Murtagh 367
V. Negus 230
V. Preston 359
V. Prince 91
t;. Pritchard 481
V. Roberts 132
V. Skeen 289
V. Smith 198
V. Taylor 92
V. Thurbom 359
r. Turpin 92
V. Walne 90
V. Ward 489
- V. Warden 92
V. Watts 72, 73
V. AVest 363
V. Williams 91
V. Wilson 91
V. Wilton ■ 95
Rohden r. AV^eslcy 276
Rcusburg, Ex parte 523
TABLE OF CASES.
XXXlll
PAGE
Rex i\ Backler 93
v. Bank of England .... 311
V. Capper 307
V. Cheadles Savings Bank 266
— I'.EUor 12
r. Flint 364
1\ Gade 310
«'. Gordon 316
V. Jackson 90
• V. James 377
• V. McKeay 362
r. Mead 357
t\ Palmer 363
v. Parker 90
V. Polman 123
V. Spencer 36-1
v. Wait 313
V.Walsh 91
i'. Wavell 90
V. WyUe 363
Reynolds v. Chettle 54
Rhode r. Proctor 536
Rhodes, Ex parte 505
Richards v. Heathers 255
. r. James 557
V. Macey 292
Richardson, Ex parte 164
Ex parte, Re Har-
ris 522
r. Bradshaw .... 514
r. Williamson.. 274, 275
Richdale, Ex parte, In re Pal-
mer 525
Richmond r. Heapy 255
Rickett V. Bennett 261
Riddle, Ex parte 270
Ridley v. Blackett 80
Rigby, Ex parte 26
Riskford r. Ridge 52
Robarts v. Tucker 53
Roberts v. Eden 178
• V. Evans 29
Robertson & She ward 467
■ V. Kensington 299
Robinson, Ex parte 453, 510
. V. Briggs 562
V. Chartered Bank of
India 434, 457
r. CoUing^vood . .556, 557
. v. Hawksford 49
V. Marchant 283
r. Pickering 28
. r. Preston 312
. V. Ward 278
V. Yarrow 27
Robson V. Bennet 52, 53
I', Great Eastern Rail.
Co 524
G.
PAGE
Robson V. Oliver 61, 348
Rodgerson r. Ladbrook 298
Roe r. Bradshaw 556
r. Fiillar 478
Roger v. Comptoir d'Escompte
de Paris 179
Rogers, Ex parte. . . . 354, 518, 537
In re 370
■ V. Kelly 226
i'. Langford 346, 348
Rolin /•. Steward 45, 46
Rolls V. Pearce 85, 88
Rolph, Ex parte. In re Spind-
ler 569, 560
Rose V. Garden Lodge Co. . . 494
Rossiter r. Miller 202
Rothschild v. Corney 58
Rouch V. Great Western Rail.
Co 524
Routh V. Roiiblct 554
Row v. Dawson 115
Rowe r. Young 102
Rowneugi". Bank of England. . 356
Rowning v. Goodchild 356
Rowton, Ex parte 154
Royal British Bank r. Tur-
quand 33, 274, 437, 445
RumbaU c. Metropohtan Bank 249,
370
Russell, Ex parte, In re But-
terworth 526
1'. Hankey 80
Ryder, Ex parte 295
S.
Sadler, Ex parte 522
r. Belcher '. 159, 160
V. Lee 120, 281
Salfery, Ex parte 563
Saffron Waldi-on Building
Society v. Raj-ner 175
St. Aubyn r. Smart 254
Samble v. Wilson 171
Sanderson v. Anderson 208
?'. Piper 16
Sands v. Clark 113, 347
Sargeant, Ex parte . . 139, 141, 144
Sargent, Ex parte . . 147, 148, 432
Saul r. Jones 103, 106
Saimderson v. Aston 209, 228
V. Bowes 347
r. Jackson 25
r. Judge 104,113
Savage v. Aldren 299
Sayer r. Wagstaff 41
C
ixxiv
TABLE OF CASES.
PAGE
Scarsbrick's case 438
Scholej' r. Kamsbottoin 59
Schroeder v. Central Bank of
London 5, 115
Schulte, Ex parte 625
Scott i'. Dixon 433
and Franklin 250
r. Porcher 116
• r. Surman 139, 151
Scottish and Universal Finance
Bank, Limited, In re 448
Seal r. Claridge 552, 562
Sebag V. Abidol 107
Selby V. Eden 103
V. Graves 295
Serle i-. Norton 49, 85
Serrell v. Derbyshire, «S:c.
Rail. Co 25, 33, 58
Se\-mour v. Brecon Corpora-
tion 487
Shackelford and Co. r. Danger-
field . . . ." 408
Sharpe r. Birch 553
Shaw V. Dartnall 197
f. Foster 168
V. Picton 197
Shears v. Jacob 554, 556
Sheen, Ex parte 538
• , , In re Win-
stanley 565
Sheffield and Hallamshire, &c.
Society 401
Shepherd, JJx parte 519
, Ex parte 518, 519
Sheppard v. Dry 31
Shillibeeri'. GljTi 10
Ship's case 448
Shipton V. Casson 341
Shortridge v. Bosauquct .... 379
Shropshire L^uiou Railway and
Canal Co. v. The Queen .. 165,
166, 167
Sibree r. Tnpp 130
Sigouniey r. Lloyd 300
Sillitoe, Ex parte 538
SimnioLs v. Taylor 60
Simpson, Ex parte 308
, In re 256
('. Chapman 256
V. Egginton 109
' >'. Sikes 354
f. Westminster Palace
Hotel Co 447
Sims V. Bond 32
r. Bnitton 121
Simson r. Ingham 237, 238
Sinclair r. Wilson 179, 528
Skelton r. Braithwaitc lOG
PAGE
Skillet c. Fletcher 224
Skyring v. Greenwood 197
Sladden r. Sargent 556
Slee r. International Bank . . 457
Sleech's case 255
Sloman v. Bank of England. .312,
314
Smale v. Burr 563
Smallcombe v. Evans 460
Smart, Ex parte 136
Smith, Ex parte 152, 173, 189,
190, 237
V. Abbot 106
V. Butler 2
V. Chase 555
r. Craven 109
v. Everett 256, 331
V. Ferrand 42
, Knight & Co., Inre. . 496
r. Leveaux 4
r. Lucas 28
V. Mercer 39, 107, 108
r. Munday 357
«'. Pilgrim 527
V. Thatcher 113
V. Union Bank of Lon-
don 67
t'. Vertue 106
r. WaU 561
Snead r. Williams 198
Sneezum, In re 522
Snell's case 456, 460
Snowball, Ex parte 252, 524
Snowdon, Ex parte 536
Soares v. Glyn 299
Solomons r. Bank of England 355
Somerset v. Cox 247
Somes V. Hallam 525
South, Ex parte 114
Durham Iron Co., In
re 416
Southam, Ex parte 556
Spackman v. Evans 445, 460
Spalding «;. Ruding 179
Sparrow v. Carruthers 514
Silencer c. Clarke .. 162, 163, 164,
175
V. Slater 516
Spiller r. Johnson 475
Spindler, In re 559, 560
f. Grellet 113
Spincer v. Spinccr 82
Spraguo, Ex parte 523
Sprout v. Matthews 105
Sprowle r. King 16
Stackhouse v. The Countess of
Jersey 246
Staddon, Ex parte 156, 354
TABLE OF CASES.
sxxv
PAGE
Stagg V. Elliot 301, 466
Stammers v. Elliot 540
Stanhope's case 460
Stapleton, Ex parte 179
■ r. Hayman 187
r. Stapletou 125
Starrey v. Bams 294
Stevens, Ex parte 564
V. HiU 53
■ V. Masterman 10
Stevenson, Ex parte 501
I'. Wood 527
Steward, Ex parte 247
■ V. Dunn 379, 478
V. Greaves 475
Stewart, Ex parte, In re Shel-
ley 165
V. Fry 8, 110
!. Gladstone 172
v. Lee 63, 64, 65
Stockton Iron Furnace Co. . . 552
Stone v. City and County Bank 433,
506
r. Compton 213
r. Marsh 30, 279
Stoveld V. Eade 238
Stracy v. Bank of England . . 314
Strange v. Lee 203, 223
Stranton Iron Co 457
Stray v. Russell 434
Stright, Ex parte 164
Stringer's case 411
Strong V. Foster 220, 536
Stuart r. Cawse 76
■ V. Earl of Bute 3
Stubbs V. Lister 462
Stubbins, Ex parte 527, 528
Stein V. Richardson 3
Sturtevant v. Forde 58
Suche, In re 100
Suffell V. Bank of England . . Add.
xxxviii
Summers r. City of London
Bank 29, 48
Suse V. Ponipe 374
Sutton !■. Bank of England . . 311
V. Bath 555
v. North British Aus-
tralasian Co 18
V. Steele 257
V. Toomer 60
Swan, Ex parte 13, 537
Swift V. Winterbotham. . 380, 449,
469, 471
Swire v. Redman 210
Syke's case 411
Symonds, Ex parte 527
Symons v. Mulkem . .Ad.L xxxviii
T.
PAGE
Talbot v. Frere 1 76, 183
Tate r. HUbert 50, 85, 88
Tatlock r. Harris 257
Tatton, Ex parte 530
Taylor v. Dobbins 25
v. Eckersley 523
r. M'Keand 564
r. riuinmer 521
r. Scrivens 89
v. Stray 434
Teasdale's case 408
Tebb r. Hodge 169, 170, 172
Tempest, Ex parte 527
Tennyson, Ex parte 161
Thacker r. Hardy 117
Tharp, In re 29
Thayer v. Lister 372
Thomas v. Atherton 252, 254
V. Desagnes 524
r. Patent Lionite Co. . . 100
Thompson, Ex parte 149
V. Barrett 545
V. Bell 469
■ V. Bennet 29
• V. Giles 139, 141, 284,
291
r. Harding 280
r. Percival 257
V. Pitman 75
r.Simpson 111,136,373
Thomson v. Freeman 527
Thornton v. McKewan 536
Thorpe v. Brown 553
Threlfalr. Giles 158
ThrelfaU, In re 534
Tidmarsh r. Grover 105
Tiley r. Courtier 43, 366
Timmis v. Gibbins 346, 349
Todd, Ex parte 537
V. Wright 475, 479
Tomkins «'. Ashby 125
Topham, Ex parte 527
Toulmin v. Copland 258
Towgood, Ex parte 147
Towne r. London and Limerick
Steamship Co 418
Townley v. Sherbounie 280
Trethowan, In re 169
Tucker v. Robarts 108
Tunbridge r. Cord 312
Turner r. Cameron 550
v. Stones 343
Tumey r. Dodwell 76
Turquand v. Fearon 115
V. Kirby 441, 498
r. Marshall 447
Tutou V. Sanoner 555
XXX VI
TABLE OF CASES.
PAGE
Tweedy, Ex parte 169
. , in re Trethowan 549
Twogood, Ex parte 540
Twyne's case 516 — 526
U.
Ulster Bank v. Synnott . . 118, 301
Union Bank of Canada v. Cole 97
of London r.
Lenanton 187, 547
of Manchester,
Ex parte 164, 432, 513, 514
University of Cambridge v.
Baldwin 234
Vaisey v. Reynolds 3
Van Wort v. WooUey . . 8, 1 18, 346
Vance v. Lowther 14
Vanderdonckt i\ Thellusson . . 113
Vanderzee v. Willis 183, 245
Vaughan r. Halliday 149
Venezuela Rail. Co. r.Kisch. . 433
Vere v. Ashby 259
Vernon v. Hankey 61, 62, 78
Vickers r. Cowell 190
V. Hertz 181
Villars, Ex parte 517
Vulliamy r. Noble 121, 540
Vyner r. Hopkins 211
W.
Wade's case 41
Wadsworth v. Pickles 542
• )'. Queen of Spain 489
Wainwright, Ex parte 543
Wakefield Bank, Ex parte . . 147,
153, 291
Walker's case 460
Walker v. Guarantee Associa-
tion ....226,270,271
V. McDowall 422
f. Rostron 10, 114, 116
r. Symonds 279
Walsh r. Glad.stone 88
Walton, Ex parte 434, 522
Walwyn v. St. Quentin 218
Ward's case 503
Ward, Ex parte 524
t'. Evans 42
c. Greenland 473
f. Peck 187
PAGE
Ward r. Smith 283
Waring, Ex parte .. 5, 136, 149,
430
Warrington r. Early 113
Warwick v. Noakes 374
■ V. Rogers 53, 85
Waterton r. Sharp 274
Watkin v. CampbeU 292
Watkins, Ex parte 523
Watson's case 513, 516
Watson, Ex parte, Re Love . . 548
, Re Roberts. . 543
r. Ealcs 436
V. Russell 83, 84
Watts V. Christie 5, 79, 249
V. Jefferies 81
r. Porter 174
V. Watts 318
Way V. Bassett 125, 129
Webb V. Whiffin 507, 508
Webster v. Power 551
Wedderburn r. Wedderburn. . 256
Wedlake r. Hmiey 8
Weeks r. Propert 275
Wegersloffe r. Keene .....-.,. 43
Weinholt v. Spetta 82
Weir c. BeU 451
Wells r. Abrahams 232
Went worth v. Outhwaite .... 179
West of England Bank v. Bat-
ch elor 115
West of England Bank, In re . 522
West Riding Union Banking
Co., Li re 518
Westboume Grove Drapery
Co., In re 100
Weston's case 409
Weston r. Barton 203
Whistler r. Eorster 84
Whitaker v. Bank of England 45,
103, 306
Whitbread, Ex parte 168
Whitehouse, In re 509
Wlaitfield v. Lord Despencer, . 356
Whitnash r. George 226
Whittaker, Ex parte 522
Whtting, In re 115
Whitworth, Ex parte 221
v. Gaugain 174
Wicks, Ex parte 522
Wigau r. Eowler 383
Wiiby r. Warren 43
Wilcoxon V. Searby 556
Wildmau, Ex parte 537
i: Wildman 308
Wildes V. Groom 278
Wilkins v. Jadis 103
Wilkinson v. Godfrey 82
ADDENDA.
Page 246. To note (Ii), add ^^ Symonsv.Mulkern, Weekly Notes, June I7th,
p. 94."
Page 365. Altering Number of Bank Xote. — Such an alteration, though
it does not vary the contract, is material in the sense of
altering the note in an essential part, and therefore vitiates
it even in the hands of an innocent holder. Siiffell v. Bank
of England, Weekly Notes, May 6th, 1882, p. 63.
TABLE OF CASES.
XXXVH
PAGE
Wilkinson v. Henderson .... 25.5
Williams, Ex parte, In re
Thorap.son 552
, In re 244
— V. Davies 28
V. Deacon 9
r. Evans 169
V. Everett 8, 114, 116
r. Griffith 237, 242
V. Rawlinson 237
r. Smith 351
;•. Waring 113
Williamson r. Williamson. . . . 201
Willis r. Bank of England . . 59,
306, 356, 366
r. Flasket 308
V. Sutherland 476
Wilmot r. Pike 162
Wilson, Ex parte 514
r. Balfour 161
r. Barthropp 301
V. Craven . . 218, 223, 224,
476
V. Herst 238
V. Lloyd 209
V. Tooker 184
V. WaUain 522
V. Wilson 186
Wiltshalge v. Da^■idge 16
Winch V. Eenn 302
Wingfield, Ex parte 524
Winter, Ex parte 527
Wintle V. Crowther 31
Wirth V. Austin 62, 86
Wisconsin Marine Co. Bank
t'. Bank of British North
America 137
Withemsea Brick Works Co.,
In re 100
Witt r. Steere 324
PAGE
Wood, In re 564
V. Priestner 206
Woodbridge v. Swann 352
Woodgate v. Godfrey 545
Woodhams r. Anglo -Austra-
lian and Universal Life As-
surance Co 130
Woodland i\ Feare . .306, 346, 430
Woods r. Thiedemann 118
Wookey v. Pole 177, 367
Wright, In re 185
r. Laing 242
I'. Pitt 171
V. Reed 342
r. RusseU 223
Wullf i'. Jay 215
Wj-down's case 617
Wylde v. Radford 245
Wynn HaU Coal Co 415
Wynne v. Hughes 202
Y.
Yglesias v. Mercantile Plate
Bank Ill
Yorkshire Banking Company
r. Beatson 31
Young V. Bank of Bengal . . 145,
294, 640
V. Grote 17
V. Kitchin 115
V. Young 175
Yrisari v. Clement 370
Z.
Zinck f . Walker 14G, 245
O.
TREATISE ON THE LAW
RELATING TO
iankrfj iniir §attImT0 C0ntj^ii:mt^.
CHAPTER I.
THE RELATION BETWEEN BANKER AND CUSTOMER.
The ordinary relation between banker and customer is
this : the customer opens an account with the banker by
paying a sum of money into the bank, the banker under-
taking to hold himself liable for the payment of a like
sum to the customer's use, either paying interest on the
money or not, as the coui'se of business of the bank or
the special arrangements between the banker and the
individual customer may be, and also agreeing to honom-
or cash any chec^ues, or orders for the payment of any
sums of money, which the customer may send to him,
diuing business hours, to the extent of the sum deposited.
A less ordinary, but still a not uncommon, relation be-
tween banker and customer is, that the banker makes
advances to the customer or allows him to overdraw his
account, charging interest on the advances, and in most
cases requiring a deposit of securities, or obtaining the
guaranty of some third person, for the repayment of such
advances, with interest ; and whilst such accommodation
continues the former relation of the parties is of course
inverted.
THE RELATION BETWEEN BANKER AND CUSTOMER.
But neitlier of these relations partakes of a fiduciary
cliaracter, nor bears analogy to the relation between prin-
cipal and factor or agent, who is a quasi trustee for the
principal with respect to the particular matter for which
he was appointed factor or agent.
Money paid into a hank ceases altogether to he the
money of the person paying it in ; it ia the money of the
banker, who is bound to return an equivalent by paying a
similar sum to that deposited with him when he is asked
for it {a) . To all intents, it is the money of the banker to
do as he may please with ; though it is true that, in a
popular sense, it is spoken of as "my money at my
banker's;" "my balance at my banker's;" and though no
one can doubt that in ordinary language the term " ready
money" includes the speaker's balance at his banker's.
Accordingly, there are many decisions construing phrases
occurring in wills, of this description, to carry sums stand-
ing in a banker's books to the credit of the testator.
This, looking at all the terms of a will, has been
held to be the extent of a bequest of " all my ready
money" {h).
So, under the words " ready money," a sum in a savings
bank was held to pass in a will (c). " To my wife all my
ready money at my bankers, in my dwelling-house or
elsewhere," pass cash balances in the hands of the tes-
tator's banker, and of his agent [d).
But money in the hands of his salesmaster in Smithfiold
does not pass under "all his ready money and securities
for money," there being no evidence that the salesmaster
acted as the testator's banker (c) .
Money at a banker's, placed to the trade account of a
(r?) Fold/ V. mil, 2 H. L. Cas. 36 ; sec Goodwin v. Roharts, L. R., 10
Exch. p. 351.
(i) Parker v. Marchant, 1 Ph. 3oG.
Ic) In re Fouell, Johns. 49 ; 5 Jur., N. S. 331.
(rf) Fn/cr V. Jiaii/ceii, 11 Sim. 55.
(r) Smith v. Biitkr, 3 J. & L. 5G5 ; Dc Bochucfc v. lord Cloiiciirri/, 5
Ir. R., Eq. r>88.
THE RELATION BETWEEN BANKER AND CUSTOMER.
trader, lias been construed to pass in Lis will under " all
my stock in trade" (/).
Or the balance in a testator's favour at his bankers may
be included under the expression " all the debts due to
me," and pass accordingly (g).
Or the balance at a banker's may pass as " money in
hand" {h).
So the balances at a testator's banker's upon a current
account, and also upon a deposit account, where deposit
notes or vouchers were given by the banker as a security
for the money, the balance carrying interest and considered
as money at the disposal of the depositor, and as readily
accessible by him as money in an ordinary account cui'rent,
were both held to pass under " all my moneys" (/). And
under a gift of a testator's " ready money," two sums of
money at his banker's, one on a drawing account, and the
other on deposit, for which no notice of withdrawal was
necessary, will pass (J).
A gift " of any small balance remaining in the bank
after payment of my funeral expenses," passed the
whole balance possessed by the testator at the time of his
death, though such balance had increased from 480/. to
over 1,301/. (/.•).
Effects consisting partly of cash and partly of money,
held by a banker on deposit notes, pass by a bequest of
all the residue of a testator's moneys (/).
But still the legal relation of banker and customer, in
their ordinary dealings in money, is purely and simply
that of debtor and creditor respectively. Money paid
into a banker's is merely a common law debt, and there is
(/) Stuart V. Earl of Bute, 3 Ves. 217.
(//) CcrvY. Carr, 1 Mer. 541, n.
(A) Vaiseij v. lieipiolds, 5 Russ. 12.
(j) Manning v. PurcheU, 2 Sm. & G. 292 ; affirmed on appeal, 7 De G-.,
Mac. & G. 55. " Secuiities for money," on the other hand, -R-ould not
■Dass money at a banker's on a deposit account. Hopkins t. Abbot, L. E.,
19 Eq. 222 ; 44 L. J., Chanc. 316 ; 23 W. R. 227.
(J) Stein V. Richardson, 37 L. J., Chanc. 3G9.
[k) Page v. Young, L. R., 19 Eq. 501 ; 23 W. E. 479.
(/) Langdale v. WMtfeld, 4 K. & J. 426 ; 27 L. J., Chanc. 795.
b2
THE RELATION BETWEEN BANKER AND CUSTOMER.
nothing of a fiduciary cliaracter in the relation between
the parties {m).
■ And it seems that th.e Statute of Limitations runs against
this debt as against any other simple contract debt ; and if
there has never been any payment of the principal, or in-
terest, or some other acknowledgment by the banker satis-
fying the provisions of the act, subsequently to the first
deposit, for six years, the right to recover the sum deposited
would be barred by the statute {/i).
If bankers were trustees of money of their customers in
tbeir hands, this must follow, that notice to them of the
drawer having assigned to the payee of a cheque an inte-
rest in so much of the drawer's money would, of if self, bind
the bankers to pay to the payee or bearer, and give the payee
or bearer, on non-payment, a right in equity against the
bankers (o).
But it has been expressly decided that money deposited
with a banker, and ordered by cheque to be paid to a third
person, is not money bad and received to the use of that
person until the bankers have bound themselves to pay it
over {])). The debt until then remains between them and
the customer; so that in case of non-payment to his order,
the payee has no remedy, either at law or in equity {q),
(»0 Folcj/ V. Hill, 2 H. L. Cas. 39, 42, 45 ; S. T., per Iviiight Bruce,
L. J., in Smith v. Leveaiix, 2 De Gr., J. & S. 5. A banker as a witness is
bound to answer what the balance of a party to a cause was on a given
day, as the knowledge does not come to liim in the natvu-e of a confi-
dential or privileged communication. Loijdy-. Frc&hfiehl, 2 C. & P. 32-3.
A banker with whom a contributory has kept an account is liable to be
siunnioncd under the Companies Act, 18G2, s. 115, and to produce his
books relating to the account, and to give all information in his power
toucliing his affairs. Forhoi's casr, 41 L. J., Chanc. 4G7.
{>/) Fott V. Chijg, IG M. & W. 321 : see Bridgman v. Gill, 24 Beav. 302.
It is no breach of a contract to pay intei'est on money dei^osited, that the
banker had not regularly entered the interest in liis books, the money
having been suffered to lie in his hands for eight j'ears. Foley v. IFtll, 2
II. L. Cas. 40. The usage of bankers by which they charge interest on
advances to customers has been expressly sanctioned by the Courts.
Gwyn V. Godlcij, 4 Taunt. 34G ; King v. Ihadlcg, 5 Price, 53G ; Crosshill v.
Jfowcr, 32 Beav. 8G. But before compoiuid interest can be charged an
agreement must be .shown to that effect. Fx parte Brown, 9 Ves. 223.
(o) Dearie v. Uall, 3 Iluss. 1.
\p) Malcolm v. Scott, 5 Excli. 610.
(//) Ilopkinson v. Foster, L. R., 19 Eq. 74 ; 23 W. R. 301. This rule in
THE RELATION RETWEEN BANKER AND CUSTOMER.
against the banker ; but the customer is the proper party to
sue, and, as will be seen, may recover substantial damages
for the injury, always assuming that his account at the
time shows a sufficient balance in his favour. The customer
has also the right of ordering the banker to carry his balance,
or any part of it, to any other account kept with the banker
by any other person, and this may be effectually done either
by a cheque or an order in writing or orally, though a formal
mode is usually adopted (r) , It is of the nature and essence
of the transactions between banker and customer, that the
latter, having a balance in his favour, will be able to com-
mand payment at sight (.s).
It must be clearly remembered, then, that the ordinary
relation between a banker and his customer is that of debtor
and creditor, and not that of trustee and cestui que trust {t).
But although there is nothing in this relation to consti-
tute the banker a trustee, he may, of course, by agreement,
take upon himself the character of an agent, or make him-
self a trustee towards a cestui que trust ; for example, if a
customer deposits exchequer bills with a banker, and he
undertakes to receive the interest upon them, or undertakes
to negotiate or make sale of them, and to credit the cus-
tomer's account with the proceeds of the sale, in this case,
it is obvious, he is in the position of a trustee, and partly,
at least, sustains a fiduciary character; but this service may
or may not be appended to his employment of banker; his
trade of banker is totally independent of it ; his trade of
banker consists of the general trade, to which the other is
an accidental addition (»).
Where three trustees, two of whom were bankers, were
empowered by a creditors' deed to carry on the business of
not affected by subsect. 6, sect. 25 of the Judicature Act, 1873. Schroeder
V. Central Bank of London, 24 W. R. 710; 3i L. T. 735.
()•) Jfattsv. Christie, li Beav. 651.
(i) 11 Beav. 546.
{t) In re Agra and Masterman'' s Bank, Ex parte Waring, 36 L. J., Chanc.
151 ; L. R., '6 Chanc. 206 ; 24 L. T. 376 ; 19 W. R. 486.
{a) Per Lord Brougham in Foley v. Hill, 2 H. L. Gas. 4^ .
THE RELATION BETWEEN BANKER AND CUSTOMER.
the debtor, and to borrow money " from any bankers or
otber persons" for that purpose, and the bankers made ad-
vances of money to the trust at compound interest, the
Court held that, having regard to their fiduciary cha-
racter, they could make no profit, and were entitled to
simple interest only on their advances {x) .
So when a banker receives money to invest in stocks, or
receives orders to appropriate the customer's balance, or a
specified part of it, to any specific purpose, and assents, or
does not repudiate the orders, he is in the situation of a
trustee or of an agent with reference to that money.
But it is not necessarily part of the business of bankers
to invest money for their customers (y).
Where bankers take a mortgage security from their
customer, for a fixed sum owing to them by the latter, the
relation of banker and customer ceases thenceforth as to
that sum, and it cannot be included in the customer's
current account, so as to entitle the bankers to charge
compound interest thereon ; and in reference to the sum
so secured, the mutual rights and obligations are thence-
forth those of mortgagees and mortgagor (-).
As the right of the customer is to draw out the whole of
the sum he deposits with the banker at any time that he
may so please, the acceptance by the banker of a bill
drawn upon him by his customer against the amount of
the balance in his favour, and made payable at a distant
day, is in effect a borrowing of the sum until that day by
the banker ; for the customer, by drawing the bill, consents
that that which is payable immediately shall not be pay-
able until the maturity of the bill (a).
It is the duty of a banker in no way to disclose the
state of his customer's account, except on a reasonable and
(.»■) Crcsskill V. Doicer, 32 Beav. 8G ; 32 L. J., Clianc. 540.
ll/) Bishop V. Countess of Jersey, 2 Drew. 143 ; 23 L. J., Chanc. 483.
(;) Mossc V. Salt, 32 Beav. 269 ; 32 L. J., Chanc. 7-56.
{a) Bank of England v. Afidtrson, 4 Scott, 118 ; 3 B'mg. N. C. G63.
THE RELATION BETWEEN BANKER AND CUSTOMER.
proper occasion (b). It has been doubted wliether an
action will lie at all against a banker, unless the customer
has been damnified by the act of disclosure (b). "When a
cheque is presented for payment, and there are not suffi-
cient assets of the drawer's in the banker's hands, he
cannot say to the holder, "not enough to meet it by
such a sum," and so enable the holder to pay in the
deficiency to the drawer's account, and obtain payment of
the cheque to the prejudice of other creditors. A banker
is not justified when such is the case in going fui'ther than
saying "not sufficient assets" (c), or, what is more usual,
" apply to the drawer."
Bankers, as we have said, are bound to obey the orders
of their customers within the usual course of business ; if
they disobey them they are responsible both for the delay
and for any consequence which directly follows the delay.
Thus a house in America employed an agent in Birming-
ham to purchase and ship goods for them : on account of
which they sent to him a bill drawn by A. in America on
B. in London, but without indorsing it. The agent
directed his bankers to obtain B.'s acceptance of it ; B.
refused to accept ; of which, however, the bankers omitted
to give any notice until the bill was due, when they again
presented it and it was dishonoured. Before the bill ar-
rived in this country A. had become bankrupt, never
having had any funds in the hands of B. Then here was
a damage done to the agent, but to what amount ? Not
to the whole amount of the bill, because of the circum-
stance that the house in America, not having indorsed,
was not entitled to notice of dishonour of the bill, and still
remained liable to him for the price of the goods he had
sent out to them; also the drawer was not entitled to
notice, because he had no funds in the hands of the
{b) Eardy v. Veasey, L. K., 3 Exch. 107 ; 37 L. J., Exch. 76. If the
duty not to disclose rests on an implied contract not to do so, then, it is
submitted, an action would lie though no damage could be proved.
(c) Foster v. Bank of London, 3 F. & F. 214.
THE RELATION BETWEEN BANKER AND CUSTOMER.
drawee ; therefore all that the agent was entitled to re-
cover, as the circumstances of the case stood, was the
damage which he had sustained by reason of his having
been delayed in prosecuting his remedy against the
drawer {d).
In ordinary circumstances it is obvious that the bankers
might have become liable for the whole amount of the bill,
namely, if the American house had indorsed, and the bill
had been drawn against effects.
But, as has been said, it is only to their customer that,
in the absence of any act of theirs, they are responsible ;
thus bankers, when they receive bills from a foreign cor-
respondent with directions to pay the amount to the
plaintiff, and when he applies to them, they refuse, and
afterwards the amount of the bills comes to their hands,
the plaintiff cannot sustain an action against them as for
money had and received to his use {c) .
If, however, the bankers had assented to the order, and
informed the plaintiff that they held the money for him,
he might, of course, have sued them (/).
So an order by a customer to his bankers to hold the
customer's money at the disposal of A. B., is revocable
until actual appropriation or payment of the money ac-
cordingly (g), or until a promise by the banker to A. B.
to make such payment (A).
We have already stated the duty of a banker to be to
conform to the orders of his customer, with respect to the
money deposited by the customer, so long as there is in
his hands a balance in favour of the customer, and the
orders relate to matters which it is the usage and practice
of the particular bank, or of the bankers in the district,
to do for their customers, or which the bank has specially
((I) Van Wort v. Woolley, 3 B. C: C. 439.
{r) WUUams v. Everett, U East, 582; Stcuart v. Fry, 7 Taunt. S39; IFcd-
lake V. Uurktj, 1 C. & J. 83.
(/) FruhVwg v. Schrordcr, 2 Biiig. N. C. 77.
\g) Gibson v. Mbut, R. & M. G8 ; 1 C. & P. 247 ; 2 Bing. 7.
(it) Lilly V. llu'js, 5 A. & E. 548 ; Ilod^json v. Anderson, 8 B. & C. 342.
THE RELATION BETWEEN CANKER AND CUSTOMER.
agreed witli the customer to do for him. Now, if tlie
bankers perfoiTii sucli orders punctually, they will often be
exonerated from loss in cases where it may be difficult,
perhaps, to see any other ground for holding them irre-
sponsible except that the customer's orders have been
faithfully and fully performed without negligence or
delay.
Much more, then, will they be irresponsible if, acting
as the agents of other bankers with Avhom a party has an
account, they conform to the orders of that party, though
with him they have no account at all.
Thus, A.'s broker, by his directions, was accustomed to
pay dividends into a banker's in London to A.'s credit in
account with a bank at Abingdon, where A. resided, and
the London bankers had been accustomed to act accord-
ingly, accepting the payments, giving credit to the Abing-
don bank and advising them by post next day. A certain
payment of this kind was made on the 14th of October
into the London house by cheque, and they wrote to
advise the Abingdon bank in the usual way by the post of
the 15th, on the morning of which day the Abingdon
bank stopped payment, and never again opened the bank
for business. On that day the Abingdon bankers were
indebted to the London house to a large amount. It was
held that A. had no claim against the London bank for
the payment so made ; for the com-se of business showed
that A. and the country bankers had agreed that they
should account to him for all sums so to be paid into the
London house as above, and that the London house had
actually carried the money to their credit (/).
Here the ground of decision seems to be, that the
London bankers, by conforming to the arrangement by
which in efEect they undertook to comply with A.'s orders
as to any money that might come to their hands pm*-
porting to be paid in by his authority and under directions
(i) JFUUams v. Deacon, 4 Excli. 401.
IQ THE RELATION BETWEEN BANKER AND CUSTOMER.
from him as regarded his account with the country bank,
of which conformity the course of dealing was evidence
conclusive as not being met by counter proof, the London
bankers were exonerated from liabihty to him ; but, pos-
sibly, if it could have been shown that they had not in fact
given credit for the money in account with the Abingdon
bank before it was reclaimed by A., the result would have
been otherv/ise Qc).
It will be observed that A. was not a customer of the
London bank ; but, in another case, where a person paid
money into a London bank, also not being a customer of
the bank, in order that they might cause it to be paid to
him or his order, through their correspondents, bankers in
a country town, on a certain day, and they received the
money, but did not cause the money to be paid on the
day, whereby the party suffered damage, he was appa-
rently considered to have a good cause of action against
the London bank, on the ground that the receipt of the
money was a good consideration for an undertaking to the
above effect, and that they might be sued for the breach
of their promise in that respect. Now here the London
bankers, it is submitted, must either be considered as
gratuitous bailees or as debtors in respect of the money
paid in ; but if they were the former, then it would have
been a breach of their duty if they had not remitted the
identical coins or bank notes paid in — a proposition which
could hardly be maintained as against bankers ; therefore
it would seem that the party paying in, though not having
a running account with them as a customer, must be con-
sidered as a customer pro Iidc vice, and the bankers as
debtors to him 2^>'0 tan to, and liable to comply with his
orders according to tho usual relation of banker and cus-
tomer (/).
(k) See Stevens v. Madcrman, cited in -1 Exch. 401,wliere Lord Abinger,
C. B., held at Nisi Prius that such a pajinent might be countermanded.
See Atldn v. Uarwirk, 1 Stra. 1G6; ir) Ilex V. Ellor, 1 Leach, C. C. 323, was an indictment on the 7 Geo. 2,
c. 22, for forging an order for payment of moncj'. The order was in the
following words: — " Messrs. Songer, — Please to send ten pounds by the
" bearer, as I am so ill I cannot wait on you. Eliiiabeth Wcry." The
AS TO THE ADDRESS OR DIRECTION. 13
sum of money, will suffice, provided the following points
are observed : —
1. That the jxqjer is directed to the hcudcer h>j his 2)roper Constituent
or usual name, style or firm. elements.
2. That it is dated.
3. That it contains the sum to he paid.
4. That it is stamped.
5. That it is made payahle to hearer, or to order, on
demand.
6. That it is signed hy the party drawinfj or entitled so
to do.
It seems that a cheque, in any other language than the
English, would not he according to the usage of bankers
in this country, and therefore a banker might legally refuse
to cash such a cheque if he had any doubt as to the
genuineness of the drawer's signature.
We ^ill now state the reasons for these several requisites
in theu" order, together with the principles and rules that
have been laid down respecting them, and such illustra-
tions and examples as appear to conduce to the full com-
prehension of the subject.
1. As to the Address or Direction. — A cheque, being Addresser
in fact an open letter of request, must, it is obvious, to be '^'^"^ction.
operative, bear upon it the name of the person who is
requested, as well to indicate to the holder where to pre-
Court said, " The Act of Parliament moans such an order for payment of
money as, if genuine, the party g'iving- it had a right to make ; but this
appears to be a mere letter, rather requesting the loan of money than
ordering the payment of it. The terms do not import anything conipul-
soiy on the part of the drawee to pay it." In the case of Little v. Slack -
ford, M. & M. 171, where the paper was in these words: — "Mr. Little,
' ' please to let the bearer have seven pounds, and place it to my account,
" and you will oblige your hvunblo servant, E. Slackford," Lord Teu-
terden, C. J., held, that it did not require a stamp, and was not a bill of
exchange. "I think no stamp is necessary ; the paper does not purport
" to be a demand by a party having a right to call on the other party.
" The fair meaning is, you will oblige me by doing it;" or, as it was
said in MitchcW s case, 1 Leach, C. C. 95, n., a man has no right posi-
tively to expect pcrfoiTnance, when rcqiiisition is not a right and per-
fomiance a dutv.
14 CHEQUES.
sent it for payment, as to show the banker who it is that
is called upon to cash the order. On the same grounds
that a bill of exchange must have an address according
to the custom and usage of merchants, a cheque ought to
have one {d).
If the bank is carried on under a firm or company, either
the proper and full style of the firm or company, or the
style by which it is usually designated and known, ought
to be used.
No person but the person addressed could, after cashing
the cheque, have a right to recover from, or have allowed
in account with, the drawer, the sum so advanced, which
would in fact be in the nature of a gratuitous payment.
Date. 2. As to the Bate.— A cheque may be dated on any day
before, or on the day, on which it is issued. A cheque is
issued when it is in the hands of a person entitled to
demand cash for it (e). There is no objection to dating a
cheque on a Sunday (./), though of course it would not be
presentable or payable on that day.
But if a banker cashes a cheque before the day of its
date, or before it is due, he will not be protected; and,
therefore, where a banker cashed such a cheque that had
been lost, he was made to repay the amount to the party
who had lost the cheque (g).
A cheque, whether payable to bearer or to order, may
be post-dated, that is, dated on a day after that on which
it is in fact drawn or issued, without being invalid, if it is
stamped, as will hereafter appear {h).
Altering the date of a cheque is a material alteration,
and will invalidate the cheque (/).
{d) Beawes, Lex Mercatoria, p. 563, pi. 3, edit. 1813; Com. Dig. Mer-
chant, F. 5.
(e) Ex parte Bignold, 1 Deac. 735 ; 2 Mont. & A. 633.
if) Bcghic V. Levy, 1 C. & J. 180.
If,) J)a Silra v. Fnllcr, Chitty on Bills, 180, 272, 10th edit. ; and per
Parke, B., 7M. & W. 178.
Ui) Post, p. 20. ^. „
■ (i)Va»ce V. Loicihcr, L. R., 1 Ex. D. 176; 45 L. J., Ex. D. 200; 34 L. T.
280 : 24 W. R. 372.
TO CONTAIN THE SUM TO EE PAID.
u
3. T/ie Cheque must contain the Sum to be paid. — The Tlie cheque
i,'i. T_i J 1-j'j. must contain
relation between a banker and a person who deposits ^^^^ j.^^^^, ^^ ^^
money in his bank being simply that of a debtor to a P^i'^-
creditor, to the amount deposited, which, by the nsage of
bankers, the banker is, at all times, bound to pay out again
to the customer upon his cheques under his hand, until the
whole, miiuis the banker's commission (where commission
is payable), is exhausted, provided the cheques are pre-
sented within banking hours : it follows, that the payments
cannot be required by the drawer of the cheque to be
made, in any other mode, than that in which an ordinary
debtor can be required to pay an ordinary debt, that is to
say, in English money only. The banker is not a bailee,
who is bound to return in specie the coins or other kind
of money deposited, upon demand ; therefore, although one
thousand pounds have been deposited with him in gold, he
is not bound to retui-n gold in payment of chec^ues drawn
against it ; any cheque which may be presented will be
duly honom'ed by paying it in whatever form a legal tender
of pajTnent of a debt, of the particular amount specified in
the cheque, may be made.
Formerly, a cheque for less than twenty shillings was
absolutely void, and the uttering or negotiating such an
instrument rendered a person liable to a penalty of 20/.,
mitigable to 5/. ; and it was an offence to utter a cheque
on which less than twenty shillings remained due, under
the 48 G-eo. III. c. 88, s. 3. But by the 23 & 24 Vict.
c. Ill, s. 19, it is expressly provided that notwithstanding
anything in any act of parliament contained to the con-
trary, it shall be lawful for any person to draw upon his
banker, who shall hojid fide hold money to or for his use,
any draft or order for the payment to the bearer, or to
order on demand, of any sum less than 20.s-. (/).
(j) See also 26 & 27 Vict. c. 105, s. 1. This restriction did not extend
to cheques drawn upon a party's own banker in Ireland after the 8 & 9
Vict. c. 37, s. 28, or in a similar case in Scotland, after the 8 & 9 Vict,
c. 38, s. 20.
16 CHEQUES.
A clieque must not be expressed in foreign money, as
dollars, rupees, francs, rubles, &c., because it is no part of
the banker's i?)iplied {/c) contract with his customer nor of
his duty of debtor, to pay the debt in any but the known
and current money of England (/).
The money of account of England is expressed in pounds,
shillings, pence and farthings ; accordingly £ s. d. is taken
in law to mean Enghsh money ; pounds, shillings, pence ;
and not foreign money, as, c. g. livres, sous, deniers (;;?),
and the word sterling means current money (/?) .
/, If the sum in the body of a cheque differs from that in
/the margin, the sum in the body is the sum which the banker
ought to pay (o).
Hence, a cheque, in the body of which the sum was
expressed only in figm'es, with the letters £ s. d. [thus,
£100 : lOs. 8f/.] could not legally be refused payment by a
banker having assets in his hands, and such a cheque,
purporting to bear date at a place in France, and properly
stamped and duly presented, would be valid and binding
on all parties for the amount expressed in English money.
But to prevent mistakes, and to render frauds less easy,
the form already given, in which the sum is tv/ice stated,
once in words, and a second time in figures, with the above
letters attached, is the one in general use, and ought always
to be adopted. For although the Court would prevent a
merely obvious omission or slip from being turned to the
prejudice of any one connected with the cheque, as, for
instance, if a cheque was drawn for " twenty-five, seven-
teen shillings and three pence," it would be held to mean
twenty-five pounds sterKng, and seventeen shillings and
(A) Of course such a epecial contract may be made between a banker
and a customer or other person, but the order for such payment would
not be, it is conceived, a cheque iu l;iw. See Parker, 11. 45.
(/) llaskllw Draper, Yelv. j, 19 L. J.,
C. P. 373 ; 9 C. B. 827.
26
CHEQUES.
Executors
and adminis-
trators.
Infants. W/io may he drawer — Infants. — An infant cannot draw or
sign a valid clieque ; in other words, a banker cashing the
cheque of an infant, is not thereby discharged ; for a
person under age cannot draw a cheque, for he cannot give
a legal discharge {n).
Executors and Administrators. — Executors, however
numerous, are regarded in law as an individual person ;
and therefore the acts of one of them, in respect of the
administration of the effects, are deemed to be the acts of
all. Hence payment to one is payment to all; and it
follows that if a number of- executors has a fund standing
in their joint names at a banker's, payment of a cheque
signed by one of the executors will discharge the banker
as to all of them (o). So it would be, although the exe-
cutors were acting under a forged will {p).
So a payment of the cheque of any of several admi-
nistrators, made hand fide, would discharge the banker,
although a will should afterwards be found {q).
So a payment of the cheque of a surviving administrator
of several, exonerates the banker: in a case where such
survivor drew out a fund and absconded, the loss fell ou
the estate of the deceased administrator (r).
Trustees of Trustee in Banhrujitcy. — Under the Bankruptcy Act,
bankrupts. 18G9, a single trustee now represents the interests of the
creditors, and to whom, when appointed, all property of a
bankrupt passes. A banker, therefore, having in his
hands funds of the bankrupt, is justified in paying the
same to the trustee. The creditors may, by sect. 83 (1), if
they think fit, appoint more persons than one to the office
of trustee, and where more than one is appointed, they
shall declare whether any act required or authorized to bo
(«) See per Lord Abinpror, C. B., in C'aUaml v. Lloyd, G M. & "W. 31.
io) Ex parte Rhjh•) Per Maiile, J., Norton v. Seymour, 3 C. B. 792, 794 ; Hogarth v.
Latham, supra.
(.s) Backhonse v. Charlton, 8 Ch. D, 444,
32 CHEQUES.
be liis solely ; the banker may prove that the partner was
acting as agent for the firm, in so opening the account ; but
the mere fact of the money deposited being partnership
property is not sufficient to show this, in an action by the
other partner for dishonouring his cheque (.s).
There is no implication of law from the mere existence
of a trade partnership, that one partner has authority to
bind the firm by opening a banking account on its behalf
in his own name (/).
What has been said respecting partners signing cheques
relates only to persons who are known to the bankers to
be members of the firm, and not to partners who are not
so known ; for a banker would not be bound to honour the
cheque of a dormant partner, whom he was ignorant to be
jointly interested in the fund with the others, although he
were satisfied of the genuineness of the signature, and he
could not, therefore, safely do so until he had got the
authority of the firm (ti).
The name in the pass-book is not conclusive that the
bankers contracted with that person alone {v).
Where two houses of business are partners in a par-
ticular transaction, and have a joint sum to the account of
the transaction in the hands of a bank, payment of the
cheque of one house, out of that fund, is payment to both {tr).
Corporations. Corporations. — When a corporate body has a deposit at
linkers, it is in accordance with strict principles to lay
down, that the bankers would not, at common law, be dis-
charged by payment of a cheque that was not under the
common seal, or signed by some officer of the corporation,/
whose signature the bankers were authorized to honour,/
by authority expressly given in an instrument under the!
common seal ; but in most cases of statutory corporations
(«) CooJcc V. Seek)/, 2 Exch. 746.
(t) Alliance Bank v. Krarsley, L. R., 6 C. P. 433; 40 L. J., C. P. 249.
[h) See per Parke, P.., Coole v. Scelci/, 2 Exch. 749.
(v) Sims V. Bund, 5 B. & Ad. 389.
(«') CollyiT on Partnership, 455.
drawer's signature. 33
power is given to three directors, or to a finance committee,
or to otlier officers or persons designated in the act, to draw
and sign cheques, &c. In such cases the cheques ought to
bear the signature (and, where that is required, the counter-
sign) of all the parties designated {z) .
" A banker," it has been said, " dealing with a com- Companies,
pany must be taken to be acquainted with the manner in
which, under the articles of association, the monies of the
company may be dra^Noi out of his bank for the pui'poses
of the company .... and the banker must also be taken
to have had knowledge, from the articles, of the duties of
the directors, and the mode in which the directors were to
be appointed. But after that, when there are persons
conducting the affairs of the company in a manner which
appears to be perfectly consonant with the articles of
association, then those so dealing with them, externa 11}',
are not to be affected by any irregularities which may
take place in the internal management of the company.
They are entitled to presume that that of which only they
can have knowledge, viz., the external acts, are rightly
done, when those external acts purport to be performed
in the mode in which they ought to be performed" (a).
So, bankers who have funds of a company (formed
under the Companies Act, 1862) in their hands may (acting
hoiid fide) lawfully honour the cheques of the directors of
the company, signed according to a form sent by them to
the bank, without being bound, previously, to inquire
whether the persons intending to sign as du-ectors have
been duly appointed to office, in conformity with the pro-
visions of the memorandum and articles of association:
thus, —
W., in concert with some friends and dependents of his,
[z] See Scrrellx. Dcrl>)/sli'-Iar, 4 B. .•), and that they
have priority before the cheques which come in on that
day (.si). Formerly it was held that this marking was
equivalent to an acceptance, and that the bankers so
marking rendered themselves liable to pay the cheque.
Now, however, by 19 & 20 Yict. c. 97, s. 6, and 41 Vict,
c. 13, an acceptance, though it need not bear the word
" accepted," must be signed by the drawee.
(p) Hare V. Ilenti/, 10 C. B., N. S. 65; 30 L. J., C. P. 302.
{q) See 4 B. & Ad. 754.
(/•) M'CuUoch, Commerc. Diet. roc. Cleai-ing Hovise, 4 B. & Ad. 753 ;
Warwick v. Eof/ers, 5 M. & G. 348; Jiobarts v. Tucker, 16 Q. B. 570; Bel-
lainy v. JIaJoribaiiks, 7 Exch. 3S9 ; Boddington v. Sckkiickcr, 2 B. & Ad.
752.
(«) Iiobso7i V. Bennett, 2 Taunt. 388 ; Stevens v. Hill, 5 Esp. 247.
CHEQUES.
From this practice, as above detailed, it is obvious that
a large portion of the clieques whicli are paid into banks
in London by customers, in order that the amounts may
be carried to their accounts as money, is never presented
by such bankers, as bearers, at the banking houses on
which they are drawn ; but that, instead, is established
the practice of placing them in the drawers at the Clear-
ing House belonging to the latter banks. In other vv^ords,
they are presented to the clerks of the latter, who attend
at the Clearing House; and such presentment has been
held to be sufficient (/) .
If the bearer banks with the same bankers on whom the
cheque is drawn, no promise to pay can be implied from
the bankers receiving the cheque without observation, and
keeping it till the following day ; for iirimd facie they will
be taken to have received it as agents for the bearer (»).
As least they will be so where they had no funds of the
drawer's in their hands at the time.
But where A. and B. severally kept accounts at the
same bank, and A. paid in a cheque in his favour, drawn
by B., who was at the time considerably indebted to the
bank, and the bankers received the cheque without obser-
vation, and on the same day received moneys on account of
B., and paid cheques drawn by him, and on the next day
received moneys on his account, but in each case appro-
priated those moneys to other claims upon B., and they
had written to A. saying that they had not carried the
cheque to his credit, but would retain it in the hope of
its being provided for, and promised B. that they would
pay it when they had funds ; it was held, that A. might
recover from the bankers the amount of the cheque, in
an action for money had and received {x), the bankers
having had funds of B.'s in their hands subsequently to
the receipt of the cheque, sufficient to have paid it but for
their appropriation of them to other claims on him.
(.') Ri'unohh x.rhfttlr, 2 Ciimp. 'lOO.
(«) Jioi/d V. Eiiimersoii, 2 A. ^; E. 181.
{x) Kihby V. WiUiamH, 5 B. & A. «15.
PKESENTMKNT THROUGH THE CLEARING HOUSE. 55
Presentation of Country Cheques through the Clearing Presentation
House. — Cheques on country bankers situate at a distance chequrs*''^
from each other, when intended for collection in London, through the
are crossed with the name of a London banker to whom hou«e?^
thej are sent by post, and who presents them in regular
course at the country Clearing House to the London cor-
respondent of the country banker whose correspondent's
name is printed on the cheques. The London agent of
the country banker does not mark them at once, or, in
other words, as with cheques upon a London banker, does
not give credit for them, but he transmits them by the
next post to the country banker, who advises his London
agent, by return of post, to debit his account with the
same, and the London agent thereupon gives a draft for
the amount to the banker from whom he received the
cheques. The country Clearing House is used as a con-
venient medium for the presentment of country cheques to
the drawees {if).
A., a banker at Worthing, received from B., a customer,
a cheque drawn upon C, a banker at Lewes, distant about
eighteen miles from Worthing, on the morning of Friday,
the 8th of July, 1859, and sent it that evening by post to
his London correspondent, D., for presentment through the
country Clearing House. D.'s clerk handed the cheque at
the Clearing House on the morning of Saturday, the 9th
of July, to the clerk of E., the London correspondent of
C, the drawer of the cheque, who sent it down by post of
that evening to C, and it Avas held that the presentment
v/as in due time (y).
The following is another case on the same subject : —
B., on Wednesday, the 6th of May, 1864, drew a cheque
on his bankers, Morgan & Co., of Ross, Herefordshii'e,
payable to Mr. Watkins, or bearer, with the memorandum
at the foot, " London agents, Messrs. Barclay & Co."
He paid the cheque on the same day to Watkins, in Mon-
[y) Hare v. JlcnUj, 10 C. B., N. S. Co; 30 L. .7., C. T. 302.
56
CHEQUES.
moutli, a post town ten miles from Eoss ; Watkins kept it
from that day until Friday, when he paid it to the credit of
his account at his bankers, Bailey & Co., Monmouth. They
sent it by the post of Friday to the City Bank, their London
agents, to be presented to the London agents of the Ross
Bank, through the country Clearing House. The City
Bank, on the following morning, accordingly presented it
to Messrs. Barclay at the Clearing House, and were then
informed that Morgan & Co. had closed their account with
them on the Thursday preceding, and the City Bank then
sent it back by post to Morgan & Co., at Ross, where it
arrived on Sunday morning, the 10th of May. Morgan &
Co., however, kept it till the 15th, when it was returned
by them to the City Bank, through the post, dishonoured.
The City Bank received it on the 16th, and by the same
day's post sent it to Bailey & Co., who, on the 19th, gave
notice of its dishonour to the drawer. Morgan & Co. paid
money over the counter and to country bankers by letter
till the 13th, when they stopped payment. B., from the
time he drew the cheque down to their stoppage, had a
balance more than sufficient to cover the amount of the
cheque. In an action on the cheque by Bailey & Co.
against B., the Court held, that there had been laches on
the part of the holder in presenting or giving notice of
its dislionour, and that the drawer was therefore dis-
charged (a).
It was intimated by the Com-t that it was reasonable to
send the cheque to the London agents of Morgan & Co.,
but that it ought to have been retm-ned to Bailey & Co.
when it was found tliat Barclay & Co. liad ceased to bo
the agents of Morgan & Co. (a) .
The payee of a cheque drawn on Monday, the 4th June,
on a bank at Falmouth, paid it on Tuesday, the 5th, to
the credit of his account in a bank at Truro, which is
about ten miles from Falmouth. On Tuesday, the 5th,
(«) Baihi/ V. Bodatluan, IG C. B., N. S. 288; 33 L. J., C. P. 252.
PRESENTMENT THROUGH THE CLEARING HOUSE. 57
the Truro Bank, having no agent at Falmouth, sent the
cheque to Barclay & Co. their London agents, who
received it on Wednesday, the 6th, and handed it through
the Clearing House to the London agents of the Falmouth
Bank ; they forwarded it to the Falmouth Bank, who
received it on Thui'sday, the 7th, and debited the di^awer's
account with the amount and cancelled the cheque, and
by post of the same day wrote to their London agents to
pay it on their account. On the morning of that day
their London agents stopped payment, and the London
agents of the Truro Bank wrote to the Falmouth Bank
requesting them to return the cheque or pay it. On
Friday, the 8th, the Falmouth Bank wrote, refusing to do
either, and on the following day stopped payment. On
Saturday, the 9th, the Truro Bank gave the payee notice
of its dishonour : the Court of Uueen's Bench held, that
the Truro Bank was entitled to debit the payee with the
amount of the cheque, inasmuch as it was not bound to
send the cheque direct to the Falmouth Bank, and there-
fore it was presented in due time, and notice of dishonour
was given to the payee in due time (b).
Presentment by Pod. — Sending a cheque in a letter by Presentment
post to the drawee is a good presentment, but there ought ^■^ P°^**
to be a notice of dishonour if the money is not received
by return of post (c).
Witli respect to the Presentation of stale or orcrdue Cheques. Presentment
— It is Avell settled, and may be regarded as a fixed rule, overdue "'^
that the indorsee of an ordinary bill of exchange, or pro- cheques,
missory note, takes it if overdue with tlie equities that
attach to it in the hands of the person from whom he
received it ; but whether the bearer of a cheque is affected
{h) rrhleaux v. Crlddk, 10 B. & S. 515; L. R., 4 Q. B. 455. See also
Pollard x.Baiik of EiKjland, L. R., 6 Q. B. 623; jVational Han/c of America
V. Jiangs, 8 Amer. R. 349.
(f) Bailc)/ V. Bodmham, 16 C. B., K S. 288; 33 L. J., C. P. 252; Fri-
deaax x.Criddlc, suiDra; UcijiroodY. Fkkiriny, L. R., 9 Q. B. 428.
68 CHEQUES.
by the same rule, seems to have been laid down with some
variation at different times.
In a case where a cheque for 50/. was casually lost by
the payee, and it was tendered, five days after its date, in
payment for goods at a shop, and the shopkeeper took it
and gave change out of it, and on the next day presented
the cheque and received cash for it, and a verdict was
found for the payee, in an action for money had and re-
ceived against the shopkeeper, the Court treated cheques
on the same footing, in this respect, as bills and notes,
holding that the person tendering the cheque, not having
any title, could not transfer a title {d). But in a later case,
where a cheque had been fraudulently obtained from the
drawer, and a trading firm, to whom it was handed six
days after date, had given cash for it, and afterwards pre-
sented it and received the amount at the banker's, the
drawer failed to recover against the trading firm, in an
action for money had and received, and it was said not to
be true, as a matter of law, that a party taking a cheque
overdue has it with the same title, and no other, as the
person from whom he receives it, though the rule, it was
allowed, was certainly so with respect to bills of exchange
and promissory notes (c).
There is an obvious distinction between a bill or a note
having a fixed day for payment, which is taken when over-
due, and a cheque found in circulation long after its date ;
in the first case, suspicion of necessity attaches, in the
latter, suspicion may or may not justly arise, according to
circumstances ; whether it does, is for the jury to say. The
staleness of a cheque may be a ground on which they may
infer fraud, but there does not seem to be any rule of law
which points out any given degree of staleness, as evidence
conclusive on that point (./').
(d) Down V. HaUimj, 4 B. & C. 330.
(«) Rothschild v. Come;/, 9 B. & C. 389, 391; f^errcU v. Dcrl»jslnrc, (Jr.
Itailwai/ Compel ti J/, 9 C. B. 811.
(/) Sec JJc/iui-.i V. Ifarriutt, 1 Show. 1C4; Broun v. Dnvics, 3 T. R. 80;
Sliirtcrmil v. Fordt; 1 «cott, N. R. 670; ^w Tarke, B., 9 M. & W. 17, 18.
PRESENTMENT OF STALE OR OVERDUE CHEQUES. 59
So gross negligence may be considered, hy the jury, to
be sliown in the circumstances under which a person takes
a stale cheque as cash ; viz., negligence of the duty, which
those circumstances imposed upon him, of inquiring into
the connexion between the bearer and the parties named
on the cheque, and if he has been guilty of such gross
negligence, they may consider him to have been a fraudu-
lent taker ; but no rule of law, it would a,ppear, lays dowu,
with respect to such a cheque, what has been formerly laid
down in the case of a party taking a promissory note after
the date at which it was made payable in the body of it,
that the taking it, after it v>^as due, is a suspicious circum-
stance, from which the law infers that the taker had know-
ledge of some infirmity in the title of the holder, and
therefore takes it subject to all the objections to which it
was liable in the hands of the person from whom he took
itifj).
Here the negligence consisted, apparently, in want of
inquiry' to see whether the drawer had not revoked the
cheque, which its appearance indicated he had done {//).
When presenfahk for Paymrnt. — Bankers are not justi- When pre -
fied in paying a cheque which is presented to them before pa^*^eat.^°^
the day on which it purports to have been drawn, or bears
date, for by so doing they may be liable to pay over again
the amount of the cheque ; e. g., if it has been lost by
the payee, the banker must repay him, it being out of the
usual course of banking business to cash cheques before the
day of the date (/).
{g) Amort/ v. Mereweather, 2 B. & C. 578; Willis v. The BanJc of Encjland,
4 A. & E. 32.
ill) Scholey v. Samslottom, 2 Camp. 485, recognized in Ingliam v. Trim-
rosc, 7 C. B., N. S. 82; 28 L. J., C. P. 294. Since printing the above the
s'lbject of overdue cheques has been ag'ain considered, and the law, for the
present, at least, settled. In London and Coiniti/ Bankinj Co. v. Groome
(L. R., 8 Q. B. D. 288), Mr. Justice Field held, that therule of law as to
bills of exchange and promissoiy notes, that an indorsee taking them
after maturity takes them upon the credit of and can stand in no better
IDOsition than his indorser, does not apply to cheques.
(0 Dn Silva v. Fuller,- Chitty on Bills, 180 (10th ed.), cited ^^tv Parke, B.,
iu Jlorh-!/ V. C/dvenccll, 7 M. & W. 178.
60 ' CHEQUES.
On the other hand, no days of grace are allowed on the
presentment of a cheque (/.•).
Cheques drawn hy the Treasury on the Bank of Eng-
land are not payable after three o'clock p.m. (/), and they
usually bear a memorandum, to this effect, printed at the
top of the paper on which they are drawn.
A cheque of the ordinary kind is strictly payable, or at
least intended to be paid, immediately on demand ; and
this appears to be universally the case, with the exception
of cheques drawn on bankers in the city of London, where
the usage of trade establishes the rule, that a cheque may
be retained by the banker, on whom it is drawn, until
five o'clock p.m. of the day on which it is presented, and,
if there are no assets, it may then be returned to the person
presenting it, and that too, although it has been, in the
first instance, by mistake cancelled, as intended to be
honoured. Thus, where a plaintiff paid into the bank of
Y. & Co. a cheque drawn upon the defendant's house, and
V.'s clerk took it to the Clearing House to be paid, and
put it into the defendant's drawer, and received it back
before five o'clock cancelled, but with a memorandum, can-
celled by mistahe {m), written under, and it was proved that
several cheques drawn by the same person had been paid
on that day, but that, when the cheque in cpiestion came
in, the clerk who received it immediately cancelled it,
thinking it was to be paid, but finding, in a few minutes,
that no more of such cheques were to be paid, wrote the
memorandum above mentioned, and it Avas retm-ned to
V.'s clerk accordingly. The Court held that, notwith-
standing the cancelling, the defendant, according to the
usage proved at the trial, had until five o'clock to return
it, and that, having so returned it, this amounted to a
(/.) Jfoi/ser V. Whitaln; 9 B. k C. 400; Siitto» v. Toomcr, 7 B. & C. 41G;
Dixnn x.'XtdtdU, 1 C, M. & R. 307. And by tlic Bills of Exchange Act,
1871, 31 & 3") Vict. c. 74, bills of exchange and promissoiy notes, paj'able
at sight or on presentation, arc payable on demand, and without days of
grace.
(/) 4 k o Will. IV. c. 15, s. 21.
{m) Seedier BuUcr, J., lrf(lf>/ v. Mill.", 4 T. R. 175.
PRESENTMENT ON DRAWEr's BANKRUPTCY. 6%
refusal to pay (n). A cheque given after banking hours
on the 25th of February, upon an understanding that it
should not be presented for a few days, is presented in
time on the 10th of March (o).
Dispensation with Presentment. — Knowledge of the bank- Dispensing
ruptcy or insolvency of the banker on whom a cheque is "^^*^ P^'^f
i- -J -J T. sentment.
drawn does not excuse presentment (7;) ; but it would
seem the notorious stoppage of such bank will do so {q) .
Braicer^s Banknqitcy. — The bankruptcy of the drawer Drawer's
has been already intimated to be a good ground of refusal ^^^J^^i^ptcy.
by the bankers to honour his cheques. In fact bankers
stand in no different position, as regards the laws of bank-
ruptcy, than other persons ; and, therefore, they are liable,
like all other persons who pay money to a bankrupt,
after knowledge of an act of bankruptcy, to be obliged
to pay it over again to the assignees or trustee. Hence, if
a banker, after knowledge of an act of bankruptcy com-
mitted by a customer, nevertheless honours his cheques,
the banker will be liable to repay the money to the bank-
rupt's trustee; for, knowing of the act of bankruptcy,
the bankers have imputed to them the knowledge of the
legal consequences of the act, which is to render the
party no longer a free agent and deprive him of the right
to dispose of his property (r) .
The only remedy of the trustee seems to be against
(«) Fernandez v. Glynn, 1 Camp. 426, n.
(o) Careiv v. Duckworth, L. E,., 4 Exch. 313.
[p) Camidge v. Allenby, G B. & C. 373, as explained in Robson v. Oliver,
10 Q. B. 704.
('/) In the case of bankers who have stopped payment, it is forcibly
put, in Byles on Bills (13th ed.), p. 207, that it cannot be necessary for
the holders of the notes of a bank which has notoriously stojiped pay-
ment, and is shut up, to go thi-ough the empty form of can-ying their
notes up to the bank doors and then carrying them home again (see
note (A), ibid.). But the stopinng payment by a bank, which issues
notes payable on demand, does not operate to dispense with the necessity
of making a demand iu order that interest may be payable on its notes
on winding up. In re East of England Banking Companij, L. R., 4 Ch. 14 ;
38 L. J., Chanc. 121.
(;•) Vernon v. Hankctj, 2 T. E. 119.
Notice of
dishouoiir.
62 CHEQUES.
tlie bankers ; lie cannot sue the creditor to whom the
cheque was delivered and the money paid on it, he not
knowing of any act of bankruptcy («). Nor is it a valid
excuse for the banker, that he pays to a creditor who
does not know of the act of bankruptcy, to whom a
direct payment by the trader would stand good(f). At
all events, if the trustee recover from the bankers the
amount of a cheque paid to a creditor of the trader, under
the above circumstances, he cannot also recover it from the
creditor, though the creditor, when he received the money,
knew of the act of bankruptcy [u).
When a cheque is presented, and is not paid, notice of
its dishonour is unnecessary, if there were no sufficient
effects of the drawer in the hands of the banker to meet
the cheque at the time, or a reasonable probability or ex-
pectation of payment, for the drawer cannot be damnified
for want of notice in such case (,r) . Where there had been
eight days, during which there were no funds in the hands
of the banker to meet a cheque, it was said there was no
ground to contend that the drawer had a reasonable ex-
pectation of the cheque being paid, and the case bore no
resemblance to cases where funds might be expected to
come in — as, for instance, in the case of a landlord whose
tenants were accustomed to pay their rents into the bank,
and who had therefore a right to expect there would be
assets to meet the draft, and might, perhaps, for want
of notice, lose his opportunity of recovering rent by
distress {x).
(.s) Mafhcio V. Sherirdl, 2 Tiiunt. 439; 1 Rose, 118.
{t) See Vcr)ioH v. llankcii, 2 T. E,. 117.
{n) Vernon v. JIankeij, 2T. R. 287.
(.'•) Cariw V. Buckwoyth, L. R., 4 Exoh. 313. See Ex ^mrtc Bii/noliI, 1
Deac. 728; IVirth v. Aitstht, L. R., 10 C. P. 689.
( 63 )
CHAPTER VI.
CROSSED CHEQUES.
Previously to the alteration of the law of crossed cheques Practice as to
effected by the statutes hereinafter referred to, in the ciiemiefbe-
metropolis, and in many other places, it was a common fore alteration
practice for a person drawing a cheque, to write across the
cheque the name of a hanker, ordinarily the banker of the
party in whose favour it was drawn. The intention of this
was to advertise the bankers upon whom the cheque was
drawn that they were to cash the cheque only to or in
favour of the banker whose name so af)peared written
across the instrument ; the reason for adopting the precau-
tion was to prevent its being paid to a wrongful bearer,
e. (J., one who had found it, or got possession of it by
fraud or felony.
If, however, a cheque so crossed was handed to another
person as bearer, there was no objection to his erasing the
name of the banker that he found upon it, provided he
substituted the name of another banker {a).
It was not unusual to write across a cheque " and
Co.," leaving a blank space on the left hand side of the
word, " and," in order that it might be filled in with the
name of the banker through whom the payee, or any one
to whom he might pass the cheque, intended that the
cheque should be presented ; and when so crossed, as in
the former case, the banker on whom the cheque was
drawn was in the habit, in London and other places, of
refusing to cash the cheque, if presented otherwise than
through the banker ; and so, if the blank were not filled
(ff) f. C7, note (').
CROSSING.
to the true owner of the cheque by reason only of having
received such pajonent" (/.•).
(k) In the recent case of Matlilcson v. London and Coiotfij Bank (5 C. P.
D. 7), it was contended that the protection chiuse in this section only
applied to cases in which the cheque had been specially or generally
crossed with the words "not negotiable," and that if a cheque merely
generally or specially crossed had been paid into a banker for collection,
the proceeds could be recovered from him by the true owner, should the
customer's title to the cheque prove defective. The contention, however,
was overrided, and it was decided that the banker was relieved from
responsibility to the true owner of a cheque crossed in blank, but without
the Avords "not negotiable," where he had bond Jidc, and in the usual
coiu'se of business, and without negligence, received payment of it for a
customer, notwithstanding any defect in the title of the latter.
71
CHEQUES.
CHAPTEE VII.
CASHED CHEQUES.
Let us consider what is the proper mode of disposing of a
cheque after it has heen cashed.
By the Stamp Act, 1870, s. 51 (2), the hanker must
cancel it ; hut is the banker, or the drawer, entitled to its
possession ? "We have seen that when a cheque is dis-
honoured, it is returned, in the technical phrase, with " no
effects," or words to that effect, written upon it. When
the hanker hands hack the cheque to the drawer, after
it has heen cashed by the banker, this restoration is not
known as a return of the cheque. In fact, however, such
restoration nearly always takes place ; the banker's duty,
in the absence of any agreement with his customer to
the contrary, being to return the cheque after cashing
it. Except where there is such an agreement, a banker
has no more right to a cheque which he has honoured,
than the payee of a bill of exchange has to the bill when
paid. It is always considered that the cheque when
paid (a) is the property of the drawer and in his posses-
sion ; the banker, _/br tliis ptirpouc, being his agent, and the
possession of the banker his possession {h) ; and therefore
where the drawer is one of the parties to an action, a notice
to produce is all that is necessary to get the paid cheque
before the Court {c).
This is the rule witli respect to all clieques drawn in the
usual mode. But in some cases bankers require their cus-
tomers before opening an account to consent to their cheques
being retained by the bank, and there may also be instances
('/) Pa- Wilde, C. J., in AVy. v. mut.s, 2 Dou. C. C. 21.
(i) I'artridge v. Coates, R. & ]\I. 156.
[c) Jiinlon V. Fffi/nc, 2 C. & P. ')20.
CASHED. 73
where a cheque is drawn with the intention that it should
remain in the banker's hands, after he has paid out the
amount of it, as a kind of security for repayment, on
which he may be able, if necessary, to proceed against the
customer (d).
The reason of the above rule is immediately seen when
we consider that the cheque, bearing the tokens of having
been cashed by the bankers, affords evidence, when pro-
duced, that the money for which it is drawn has been
paid, according to the requirement of the drawer, by the
drawees ; it is, therefore, the di-awer's proof, or voucher, of
the payment of the debt due to the payee of the cheque.
When the drawer draws, on his own account, against his
own moneys deposited with the bankers, the cheque in its
cancelled state is his evidence against the payee that the
debt has been discharged. When the drawer draws on a
fund in the banker's, upon which he is specially empowered,
in respect of some office or situation which he holds, to
draw, it is his voucher, as against his constituents to whom
the fund belongs, that their debt to the payee has been
duly discharged. In either case equally, the cheque, or
the piece of paper, is the property of the drawer (e).
Where a drawer of a cheque, after it had been paid and
returned to him cancelled by his bankers, darkened the
signature so as to give it the appearance of a forgery ; and
then took it to his bankers and represented it to them as
the forgery of another person : it was held, that the altera-
tion of his own cheque by the drawer, although a cheat on
his bankers, was not a forgery (/).
(d) See Otkey v. Iveson, 24 L. J., Ch. 654.
(e) Jieff. V. Watts, 2 Den. C. C. 14, 22.
(/) Brittain v. Bank of London, 3 F. & F. 465; 11 W. R. 569.
74 CHEQUES.
CHAPTER VIII.
CHEQUES AS EVIDENCE OF PAYMENT, ETC.
Where the plaintiff was tenant, and the defendant land
steward, of a proprietor of land, and the defendant had
received from a railway company a sum of money to he
handed over to the plaintiff, as compensation for injury
done to his temporary interest, as tenant, by the com-
pany's works, and the defendant had drawn a cheque, for
15/., upon his bankers in favour of the plaintiff, who had
presented it to the bankers and obtained payment of
it from them ; but there was no evidence that the cheque
had been delivered by the defendant to the plaintiff, it
was held, notwithstanding this, that the cheque, upon
being produced by the defendant in a cancelled state, was
evidence of the payment to the plaintiff of the 15/. (a).
Here, it will be o1)served, there was independent evidence
to establish the fact of money being due from the defen-
dant to the plaintiff : but unless a consideration for
delivering the cheque, and the circumstances under which
it is delivered, are shown, the proof of the delivery and
payment of a cheque to a party is not sufficient to prove
a debt {h) ; so that to produce a cheque di-awn by the de-
fendant is not an admissible mode of enforcing against
him an alleged debt due to the plaintiff. But the produc-
tion of a cancelled cheque, after it has been shown aliintdr
that there was duo from the drawer a debt to the payee
before the date of the delivery to him of the cheque d^■a^\•n
in his favour, is always evidence of payment, without
explicitly tracing tlie clieque from the drawer to the
(a) Mountfurdv. lltirpo; 10 M. k "W. 825: IG L. J., Excli. IS'2.
\h) Anhcvt V. ll'dlili, 4 Tiiunt. "JDS: Lhi/d v. S,ii/dih>id'<, Gow, 1'), as cur-
r.'ctfd, rrr AMcrs..Ti, H.. IC. M. .^: ^Y. sL>7.
AS EVIDENCE OF PAYMENT, ETC. 75
payee. To prove a payment, it is enough to put in evi-
dence a cheque shown to have been in circulation ().
Another instance of the value of cancelled cheques, as
evidence, is the following : — On a certain day A. had a
claim, to a certain amount, on B., 0. and D., partners.
Many months afterwards B. signed a cheque for a larger
sum, in the nam? of himself and C. and D., which was
proved to have passed through A.'s hands, and to have
been appropriated by him. In an action by A.'s executors
against the partners for the original claim, it was held that
the cheque yvas prii/id facie evidence of payment ; but there
being other circumstances from which a loan for its amount
might be inferred, it was left to the jury to say whether
the cheque represented a loan from B. alone or from the
partnership (c/).
It may be convenient to add here some further instances
in which cheques are available in evidence.
Many bankers are in the habit of supplying their cus-
tomers with printed forms, in blank, of cheques, which is
convenient for their customers, as saving time and trouble,
and useful for both parties, as increasing the difficulty
of forging or altering cheques. It is also not unusual,
upon a change in the firm of a banking house which
adopts this practice, to alter the printed form of the
cheques accordingly, and to supply to its customers the
altered form, in order that it may be used by them for
the future, instead of the old one. Such alteration in the
name and style of the firm, when made in the printed
form supplied, has been held to constitute a sufficient noti-
fication of the change to a customer to whom the altered
form has been delivered, and who has used it in drawing
cheques (e) .
The Bank of England requires its customers to use
(r) T/ionijJson v. Pitman, 1 F. & F. 339.
{(l) Boswell T. Smith, 6 C. & P. 60.
(e) Barfoot v. Goodall, 3 Camp. 147.
76 CHEQUES.
tte engraved forms of cheques, whicli it supplies, and re-
fuses to pay their cheques drawn otherwise (/).
A cheque has been shown, upon the authority of various
decisions, to be admissible, when cancelled, as evidence of
payment, the existence of the debt and other circumstances
relating to the giving of the cheque being previously esta-
blished; but it is not, therefore, to be concluded that the
drawing of a cheque in favour of a creditor by the debtor,
and the delivery of it to the former, operate per se as pay-
ment, for a cheque is not money {g), nor is it a legal tender;
the creditor may always object to it as payment, and if
he has done so, when it was delivered to him, he may sue
for the original debt, although he retains the cheque (//).
But it is otherwise in the case of payment by a di'aft on
the debtor's banker, accepted by the banker and payable
after so many days' sight ; in this case the creditor, not
having returned the draft to the debtor, cannot sue before
the expiration of the period, because the assets of the
debtor in the hands of the banker are bound to the extent
of the draft, which sum the debtor cannot withdraw (/).
statute of With respect to the Statute of Limitations, it has been
held, that when a bill of exchange or promissory note has
been given, in part payment of a debt, under such circum-
stances as to raise the implication of a promise to pay the
balance, the defence of the Statute of Limitations is an-
swered, as from the time of the delivery of the negotiable
security, whatever afterwards becomes of it (/,•). The ques-
tion in the case deciding this point was, whether a bill of
exchange, drawn by the creditor and accepted by the
debtor in part payment of an antecedent debt, was suffi-
cient to take the case out of the statute, and the Court
(/) Sec G C. (k p. 730.
\g) Moore v. Barthrup, 1 B. & C. 5.
{h) Hough V. May, 4 A. & E. 9.54.
(t) Stuart V. Cause, 28 L. J., C. P. 193 ; o C. B., N. S. 737.
{k) Turiie>i V. Dodwell, 23 L. J., Q. B. 137; 3 El. & BI. 13G ; Irviiiy v.
Yeitch, 3 M! & W. 90.
AS EVIDEISCE OF PAYMENT, ETC. 77
determined that it was, and upon principles and reasoning
which seem to apply equally to part payment by a cheque.
The plaintiff having agreed to lend to the defendant a
sum of money gave him a cheque for the amount, which
the defendant paid into his own bankers, receiving credit
for the amount. The cheque was not paid by the plaintiff's
bankers till some days afterwards. The plaintiff brought
an action for money lent, and it was held, that the Statute
of Limitations only ran from the time of the payment of
the cheque by his bankers (/) .
Where, however, a purchaser, at a sale, gives a cheque
for the amount of the deposit required by the conditions
of sale, he may resist an action on the cheque on any
grounds which would have enabled him to recover, at law,
the deposit, if it had been made in money (>;?).
Again, to establish a petitioning creditor's debt, it is not
enough to show that a cheque was drawn by him in favour
of the trader before the bankruptcy; it must be proved
that the amount of the cheque was paid by the petitioning
creditor's bankers (n). The mere drawing of a cheque on
his bankers by A. in favour of B. is not per se evidence of
a loan of so much from A. to B., without proof that it was
presented and paid (o) .
As we have seen, the ordinary relation of customer and
banker is that of creditor and debtor respectively ; conse-
quently, where a banker is the petitioning creditor, the
production of cancelled cheques, drawn on him by the
trader before the' bankruj)tcy, is prima facie evidence of a
payment of a debt due from the banker to the customer,
not of a loan made by the banker to him, nor can this
effect of such evidence be rebutted, and the existence of a
loan established, so as to constitute a petitioning creditor's
debt, without the clearest proof that the trader's account
{I) Garden v. Bruce, L. E., 3 C. P. 300; 37 L. J., C. P. 112.
[m) Mills V. Oddij, 6 C. & P. 735 ; 2 C, M. & R. 103.
(«) Blcasbi/ V. Crossley, 3 Bing. 430.
(o) Pearce v. Davl'<, 1 M. & Rob. 36;') ; Cary v. Gerrish, 4 Esp. 9.
78
CHEQUES.
with the bank was overdrawn at the time the cheques were
honom-ed (p). The point does not appear to have been
raised in this case, that the circumstance of the banker's
having retained, in his own hands, these cashed cheques,
contrary to the practice in the case of cheques drawn in
ordinary circumstances, and the trader's submitting to the
banker's doing so, in contravention of what would have been
his right, if the cheques had been drawn in the ordinary
com'se, was evidence to show a loan from the banker. The
banker, in that case, would have a right to retain the
cheques, because to part with them would be to put beyond
his control the only conclusive evidence he might have of
the loan, beyond the entries in his own books correspond-
ing with the cheques, which would be perhaps open to the
objection, that to let them in would be to allow the making
of evidence in a man's own favour.
In all cases of loans to customers some security, inde-
pendent of cheques of the character of those just mentioned,
ought, if possible, to be taken by the banker.
It has been already mentioned, that if bankers, knowing
of an act of bankruptcy of a customer having funds in
their hands, honour his cheques, they are liable to the
assignees of the customer, on his becoming bankrupt, for
the amount they have paid out to such orders ().
Bankers sfojyping Payment. — As to the operation of a
cheque drawn after the stoppage of payment by the bankers ;
A. and B., who were partners, had a joint account with
their bankers ; A. had also a separate account ; on the
22nd April, 1843, the bankers announced a suspension of
payment, and that they could not answer any more cheques:
at that time A. and B. were indebted, on the joint account,
335/. to the bank, but the bank was indebted to A., on his
separate account, 478/. ; after this no cash payments were
made by the bank ; on the 25th May, A. assigned the
(j») Fletcher v. MaiDihiff, 12 M. & W. 57!).
() JW>imi V. Henley, 2 T. R. 113.
AS EVIDENCE OF PAYMENT, ETC. 79
balance of 478/., clue to him, to the joint account of A. and
B., and gave a written notice to the bankers of such as-
signment, and A. and B. jointly required the bankers to
place such balance to their joint account, which was
not complied with ; on the 30th May an act of bank-
ruptcy was committed by the bankers, on which the fiat
issued on the 31st : it was held that A. and B. had
no right to set off the two debts, their conduct show-
ing that, though they knew they could not obtain pay-
ment of a cheque, they had attempted to have the full
benefit of A.'s debt. " The plaintiffs (A. and B.)," the
Master of the EoUs said, " knowing that no cheque drawn
upon the bank would be answered, resolved to have the
benefit of the balance, in a way which they might not
have considered prejudicial to any one, but which was
nevertheless contrary to the policy of the bankrupt laws ;
and this was by transferring the balance due to Thomas
Watts (A.) on his separate account, and which could not
be recovered, to the partnership account. They might
have been encouraged to this course, as the same thing
had been done by the bankers for other persons ; but it
was a course which the law did not sanction " (/■).
(>•) Watts V. Christie, 11 Beav. 546 ; 13 Jui-. 845.
80 CHEQUES,
CHAPTEE IX.
CHEQUES CONS[DERED AS MONEY.
By the usage of trade cheques have been, in some cases,
considered as money. For instance, by the usage of
banking, if a bill was sent uji to a London banker from a
country correspondent, to be presented for payment, the
London banker was thought to be justified in receiving a
cheque in payment for it, though the cheque should be
dishonom-ed after he has given up the bill {a) ; but it may
be doubted whether this usage would be considered, at the
present day, to be a reasonable usage so as to protect the
London banker.
Another case in which a cheque has been regarded as
payment is the following : — A cheque given for stock sold
was lost by the vendor in going home ; the purchaser was
immediately apprised of the loss, but refused to pay the
price of the stock without an indemnity. Four months
after this the bankers on whom the cheque was di-awn
failed, with sufficient money of the drawer's in theii- hands
to cover it. Held that, under these circumstances, an
action would not lie by the vendor for the price {b).
Cheques belonging to a person, against whose effects a
writ of Jieri facias may have been sued out of any superior
or inferior Court, may now, and must, be seized by the
sheriff, by virtue of the 1 & 2 Yict. c. 110, s. 12, but the
statute makes a distinction between cheques, and money or
bank notes (both of which it empowers and orders the
sheriff to seize) , in this way : it directs that money and
bank notes shall bo given up to the judgment creditor,
(n) JtiissfU V. Jfiiiilrii, G T. li. 12; IthUr,/ v. niackitt, Peakc, Add.
Can. 02.
(i) lievan v. Hilly 2 Camp. 381.
AS MONEY. 81
but the sheriff is to hold cheques as a security for the sum
directed by the writ to be levied, and is enabled to sue
upon them, and the payment by the party liable on such
cheque, with or without suit, or the recovery and levying
execution against the party so liable, is to discharge such
party from his liability on the cheque, and then the sheriff
is to pay over the money so recovered to the judgment
creditor : provided that no sheriff shall be boimd to sue
any party upon such cheque, unless the judgment creditor
shall enter into a bond with two sureties for indemnifying
him from all costs and expenses to be incurred in the pro-
secution of the action.
A judgment creditor, finding that a sum of money was
about to be paid out, in a cause in Chancery, to his debtor,
applied to the Com't to order that the sheriff might be at
liberty to seize, in the hands of the Accountant- General in
Chancery, a cheque by means of which the sum was to be
paid out : it was held, that the cheque was liable, by
virtue of the above statute, to seizure : it was also held,
that, inasmuch as the cheque was in the hands of the
Accountant- General of the Com-t, the application was pro-
per () ; that is, that it would not have been proper for the
sheriff to seize without being authorized by an order of the
Com't.
In another case, subsequent to this, it was said that a
cheque of the Accountant- General in favour of A., but not
delivered out, is not A.'s property, so as to be liable to
seizure ; and leave to seize was refused, the case being, it
was said, distinguishable from the last-mentioned case, by
the circumstance that the cheque had been delivered out
by the Accountant-General in the former case, which was
not so in the latter ; a stop order v/as accordingly granted
restraining the Accountant-General from parting with tbe
cheque out of his possession {d). It may be observed, with
respect to the distinction taken between the two cases,
((-■) Watts V. Jef erics, 3 Mac. & G. 422.
(d) Courtoy v. Vincent, 15 Bear. 486.
CHEQUES.
that, in the first case, the cheque had heen delivered out,
but had heen replaced in the Aecountant-Generars hands,
so that, the property in it having passed to the creditor,
the Accountant-Greneral held it as agent for the creditor,
and, the possession of the agent being the possession of the
principal, it might be seized in the hands of the one, on the
same grounds that it might be seized in the hands of the
other.
A cheque may have been treated throughout a transac-
tion as money by all the parties, in which case no one of
them can turn round and insist upon any right that he
might have derived out of the cheque, considered as an
order for the payment of money. Thus, it was held that
•where a cheque had been deposited with a person to abide
a certain event, it was no breach of the stakeholder's duty
to get the cheque cashed before the occurrence of the
event {e).
Where a person fraudulently gives a cheque, which he
has no reasonable ground to expect will be honoured, in
payment for goods, such cheque v,'ill hot be considered as
money, and the creditor may sue for the price (/).
On the sale of goods for ready money, if the purchaser
gives in payment his cheque which he then knows he has
not funds in the bank to meet, this amounts to a false re-
presentation of a material fact, which vitiates the sale and
entitles the seller to rescind the contract, even though the
purchaser at the time believed, and had reasonable grounds
for believing, that the cheque would be paid (^7).
When a cheque is handed to a person, on a condition
which the drawer finds is to be broken or eluded, he has
a right to stop the payment of the cheque (//). A house
in Westphalia having received a smn of money on account
[e) Wilkinson v. Godefrotj, 9 A. & E. 536.
(/■) Ilaicse V. Crowe, R. & M. 414 ; Xobfe v. Adams, 7 Taunt. 59 ; J^arl
of Bristol \. Wihmorr, 1 B. & C. 514.
((j) Loufjhnan v. Barry, G Ir. R., C L. 457.
(h) Wienluilt v. SpiUa, 3 Camp. 37G ; .'*ee Spincer \. Spiiicer, 2 M. & G,
295.
AS MONEY. 83
of the plaintiff, directed the defendants, who were their
correspondents in London, to pay it to him, but said they
could not allow him interest upon it, as they had made
none themselves. This being communicated to the plain-
tiff, he at first insisted on interest ; but finally agreed, on
having a cheque for the principal, to give a receipt in
full. He accordingly wrote such receipt, and received a
cheque for 532/. in exchange. Having got it into his
hands, he said he should prosecute the house abroad for
interest before the Chamber of Commerce in Paris. The
defendants thereupon ordered payment of the cheque to
be stopped. Lord Ellenborough said : — *' If I give a draft
upon a condition, and I find the condition is to be eluded,
I may stop the payment. This was a conditional dehvery
of the draft when it was delivered, all still remained in
fieri. The defendants, on discovering the plaintiff's in-
tentions, were fully justified in resisting the demand.
The draft in his hands had become a piece of waste
paper" (Jt). But if A., by means of a false pretence or
a promise, or a condition which he does not fulfil, procures
B. to give him a cheque in favour of C, to whom he pays
it, and who receives it bond fide for value, B. remains liable
on it, and, if cashed by C, he cannot recover the money
from him (/) .
A banker has no right to debit the customer, who draws
a cheque, from the date at which it is drawn ; he is bound
to make the entry, as of the date when the cheque was
cashed (/.•).
(i) Watson V. Russell, 3 B. & S. U\ 31 L. J., Q. B. 304. See also
Currie v. 2[isa, L. E., 1 App. Ca. 554; 45 L. J., Q. B. 852; 24 W. R. 450.
[h) Goodbodij v. Foster, cited in Bvles on Bills, 24 (13th edit.).
CHEQUES.
CHAPTER X.
CHEQUES ANALOGOUS TO BILLS OF EXCHANGE.
Cheques are by recent legislation imposing a stamp duty
upon them, and creating a class payable to order, nearly
on the same footing as bills of exchange ; and the decisions
of the Courts have been of late in favour of putting them
on the same footing as to theu" general legal incidents and
characteristics. Cheques, though not usually, may be ac-
cepted by the banker (a) . When payable to bearer, they
pass by delivery ; if to order, by indorsement (a) . A holder
is affected by the same equities and infirmities as attach
to the title of holders of bills of exchange {b). Cheques
were also within the Bills of Exchange Act, 1855 (18 &
19 Vict. c. 67), by which a summary mode of proceeding
to recover upon them was provided (c). This procedure
is, however, now abolished by Order II. r. 6 of the Rules
of the Supreme Court, 1880. The Courts, on various
occasions, have pointed out differences and analogies
existing between the rules and principles applicable to
cheques and bills of exchange. Thus, no days of grace
are allowed with respect to cheques, which are always to
be cashed speedily, if not immediately; on bills of ex-
change, except when dra\^^l on demand or at sight or on
presentation {(/), days of grace are allowed. The payee
of a cheque does not obtain any more time for present-
ment by employing a banker to make it, while in the
case of a bill of exchange, by the custom of merchants,
the holder obtains a day more for giving notice of
{a) Keene v. Beard, 8 C. B., N. S. 372, 380.
(i) Whistler v. I'orster, 14 C. B., N. S. 248; 32 L. J., C. P. 101-
Watson V. Riis.'ieU, 3 B. & S. 40.
{c) Eyre v. Waller, b H. & N. 400; 2() I.. J., Exnh. 246.
{(I) 34 & 3') Virt. <:. 74.
ANALOGOUS TO BILLS OF EXCHANGE.
dishonoiu', by presenting it througli a banker, than if he
presented the bill himself (e). Again, the death of the
drawer of a cheque rescinds the banker's authority to pay
it (/) ; the death of the drawer of a bill of exchange has no
operation to diminish or alter the nature of the responsi-
bilities of the other parties to it {g) .
In another respect a cheque differs from a bill of ex-
change, — it is an appropriation of so much money of the
drawer's in the hands of the banker upon whom it is
drawn, for the pm'pose of discharging a debt or liability of
the drawer to a third person ; whereas it is not necessary
that there shoidd be money of the drawer's in the hands
of the drawee of a bill of exchange {h) .
There is another difference between the two instru-
ments ; in the case of a bill of exchange, the di-awer is
discharged by want of a due presentment to the acceptor ;
but in the case of a cheque, the drawer is not discharged
by a delay in the presentment, unless it is shown that he
has been prejudiced thereby ; for instance, by the failure
of the banker on whom it is drawn (/).
A cheque is not due before payment is demanded, and
in this respect differs from all such bills of exchange as are
payable on a fixed day (A-).
In an action by the holder against the drawer of a dis-
honoured cheque, notice of dishonoui' is excused for want
of effects in the hands of the drawee at the time when the
drawer would reasonably expect the cheque to be presented
(f) Alemnder v. Burchfcld, 7 M. & G. 1060.
(/) Though, if the banker pay the cheque in ignorance of his cus-
tomer's death, it would seem the pajTnent is vahd ; Tate v. Silbcrt, 2
Ves. juu. 118 ; Bromleij v. Brunton, L. E,., 6 Ec[. 275. See, however, as
to cheques payable to order, Rolls v. Pearce, L. R., 5 Ch. D. 730; and
post, p. 88.
(il) jnilbiff V. Devaiu; 3 M. & G. 571, 572, 573.
(li) Keem v. Beard, 8 C. B., N. S. 372, 381 ; 29 L. J., C. P. 287, 290,
per Byles, J. ; and see severs,! points of difference pointed out by
Tindal, C. J., and Maule, J., in Warxnch v. Rogets, 5 M. & G. 363 ; and
by Parke, B., in Ramchurn MuUick v. Liwhiiiccchund Radakisscn, 9 Moore,
P. C. C. 48, 69 ; and in Serle v. Norton, 2 M. & Rob. 404, n.
(i) Ante, p. 49.
(/.} Per Lord Keuyou, C. J., Boehin v. Stcrlln//, 7 T. R. 430 ; Alexander
V. Biirchjhld, 7 M. & G. 1067.
CHEQUES.
for payment, provided the drawer had no reasonable ex-
pectation that it Avould be paid (/). The want of effects
which -svill excuse notice of dishonour need not be a want
of any effects ; it is sufficient if there are no effects suffi-
cient for the payment of the cheque (/).
If there are funds in the hands of the banker sufficient
to meet his cheque, the drawer will be entitled to notice,
though he knew that the bank would not honour the
cheque, for he would be entitled to say that they were
bound to honour it, even though they had told him they
would not (/).
(0 Carew v. Buckworth, L. R., 4 Exch. 31o ; 38 L. J., Exch. 149 ;
Wirth V. Austen, L. R., 10 C. P. 689,
( ^r )
CHAPTER XI.
PERSONS ENTITLED TO SUE ON NON-PAYMENT OF CHEQUES.
The bearer of a cheque, if payable to bearer, or to order
(if indorsed generally, or in blank), is the person entitled
to receive the money therein specified ; and whoever has
possession of it, as bearer, may maintain an action upon
it (a). But the holder cannot sue the bankers upon whom
it is drawn for refusing payment, in the absence of proof
that it has been accepted by the bankers, or that they
have entered into some binding engagement to pay
him {b) . The remedy of the holder on non-payment is
against the drawer, and his remedy ^^dll be an action for
damages against the bankers for dishonoming his cheque.
A cheque payable to bearer may be indorsed, so as to en-
title a holder to sue the indorser thereon (c). A cheque //
payable to order may be sued upon b}^ the paj'ee, without
indorsement, and if indorsed, by the bearer or party
entitled to the money.
(«) Ter Martin, B., in Ancona y. 2Iarks, 7 H. & jST. 696 ; Hodgson v.
Andersou , 8 B. & C. 342 ; I'into v. Santos, o Taunt. 447.
(i) See ante, p. 8 ; National Bank of the Republic v. Jlillard, 7 Canada
L. J., N. S. 44, Supreme Court, U. S. Jlr. Justice Davi.s, in giving judg-
ment there, said : — " On principle, there can be no foundation for an action
on the part of the holder, unless there is a privity of contract between him
and the bank. How can there be such a privity when the bank owes
no duty and is under no obligation to the holder ■;" The holder takes the
cheque on the credit of the drawer, in the belief that he has funds to
meet it ; but in no sense can the bank be said to be connected with the
transaction. If it were true that there was a privity of contract between
tlie banker and holder when the cheque was given, the bank would be
obliged to pay the cheque, although the drawer, before it was ^jresented,
had countermanded it, and although other cheques, drawn after it was
issued, had exhausted the funds of the depositor." But Mr. Morse, in
his Treatise on Banks and Banking, pp. 466, 469, elaborately and arti-
ftcially argues in favour of a right of action by the holder against the
banker on the ground of an implied promise xchlch the laiv raises in his
hi'half from the usage or course of dealing of the parties or of the com-
munity generally. ' ' There can be no possible difficulty, ' ' he says, ' ' in
assuming-, in view of the well-known conduct of all banking institutions,
and the multitude of daily transactions wliich the entire community bases
and is obliged to base upon this well-known conduct, that the under-
taking of the bank to pay the depositor's cheque is designed to enure,
and by virtue of this intent and of usage in accordance therewith actually
does enure, for the benefit of the holder of the cheque, and does raise
sucli an implied agreement as will suffice to overthrow the technical
obstacle to his obtaining his rights which grows out of a supposed want
of privity between him and the bank."
(f) Ecenc v. Beard, 8 C. B., N. S. 372 ; 29 L. J., C. P. 287.
88 CHEQUES.
CHAPTER XII.
GIFTS OF CHEQUES.
A CHEQUE drawn by A., in favour of B. as a gift, canuot,
according to the general principle that there must be a
consideration for an undertaking not under seal, be en-
forced by B. in an action against A. (a). A cheque payable
to bearer cannot be the subject of a good donatio mortis
cfiKsd, unless it is presented for payment or paid before
the death of the donor (b). Where, however, the cheque is
made payable to order, the rule, it seems, is otherwise (c).
Sometimes the gift of a cheque on death may operate
as a declaration of trust in favour of the donee. A lady
gave a cheque for 5,000/. to the surgeon who attended
her, to be laid out in the erection, establishment, and
support of a hospital. The money was invested by the
sm^geon in Consols in the names of himself and another
as trustees, and both immediately after executed a deed of
trust declaring the objects of the gift. The declaration of
trust was not made known to the donor, who died a few
days after its execution, but as the object of the gift did
not exclude the acquisition of land, and the donor having
died within twelve months after the execution of the deed,
the gift was invalid under the Mortmain Act, 9 Geo. 2,
c. 36 (r/).
A cheque may be admitted to probate, as a paper of a
testamentary character (r).
(a) Easton V. Fralchctt, 1 C, M. & R. 808, where Lord Abingcr, C. B.,
says: — "If a inau ) See Beian x. Eill, 2 Camp. 381.
(r) Johns v. Mason, 9 Hare, 29 ; 20 L. J., Chanc. 305.
[d) King v. Zimmerman, L. E.., 6 G. P. 466.
{e) Taylor v. Scrinns, 1 Bcav. 571.
90
CHEQUES.
CHAPTER XIV.
Cheating by
means of
cheques.
CRIMINAL OFFENCES IN RELATION TO CHEQUES.
For a person to give ■what purports to be his cheque
upon his banker, in payment for goods, when in truth he
has no account with the banker named, is a false pretence
within the 24 & 25 Yict. o. 96, s. 88 («). So, where a
prisoner was charged with falsely pretending that a post-
dated cheque, drawn by himself, was a good and genuine
order for 25/., whereby he obtained a watch and chain,
and the jury found that before the completion of the trans-
action — of the sale and delivery of the watch and chain,
by the prosecutor, to the prisoner — he represented to the
prosecutor, that he had an account with the bankers on
whom the cheque was drawn, and that he had a right to
draw the cheque, though he jiostponed the date for his
own convenience, which was all false, and that he repre-
sented that the chec^ue would be paid on or after the day
of the date, but he had in reality no funds to pay it, the
prisoner was held to be properly convicted (/>) .
It is no false pretence, as regards the banker, to draw on
and present to him a cheque for a larger amount than you
have in his hands (r). A. drew a bill on B., on whom
he had no right to draw, in order to induce bankers to
honour his cheque, which they did ; and it was held not
to be a false pretence, because A. only obtained credit, and
not any specific sum on the bill {d). But to give a
cheque by way of payment for an amount which exceeds
(rt) Hix V. Jucl-ao)!, 3 Camp. 370.
{b) lice V. rarlar, 2 Mood. C. C. 1 ; 7 C. & P. 825 ; .see also Itrg. v.
Wahic, 23 L. T. 748.
(c) /Vr Maule, J., in Brrj. v. Garrett, 23 L. J., M. C. 22.
(d) Hex V. U'urell, 1 a[ood. C. C. 224 ; see 11 Cox, C. C, App. xi., for
precedents of coiiutf? in an indictment fur jjrcscnting a false cheque.
OFFENCES IN RELATION TO CHEQUES, 91
the assets available to meet it, with tlie knowledge that
there is no authority to overdraw, and that it will he
dishonoured on presentation, renders the di'awer liable
to a conviction for false pretences {e) . A cashier of a bank
has a general authority to part with the bank's money in
payment of such cheques as he may think genuine, and,
therefore, when money has been obtained from a cashier
at the bank on a forged cheque knowingly, it • does not
amount to larceny, but to obtaining the money by false
pretences (/').
Formerly, the stealing of a cheque, qua cheque, did not stealing,
amount to larceny, but now, by 24 & 25 Vict. c. 96, s. 27,
it is made so ( g) .
A person may be indicted for forging a cheque as " an Forging,
order for the payment of money " under 24 & 25 Vict. c. 98,
s. 39. If the charge in the indictment is for forging a
warrant and order, proof of a document which is a warrant
but not an order for the payment of money, will not sup-
port the indictment (A).
A cheque of a railway company, signed by the secretary,
addressed to their bankers, directed the latter to pay to A.
a shareholder, or his order, the sum therein mentioned.
There was a memorandum at the bottom of the docu-
ment, " The shareholder's name must be indorsed at the
back of the cheque :" it was held, that a person who
forged the shareholder's indorsement on the cheque was
guilty of forging an order or a warrant for the payment of
money (/).
Forging and uttering an indorsement on a cheque, with
a view to get it cashed by the credit of the name, will ■
(t) Bci/. V. Ifazclloii, L. E., 2 C. C. 1^4 ; 44 L. J., M. C. 11.
(/) lii'ff. V. Trimr; 38 L. J., M. C. 8 ; 11 Cox, C. C. 193.
() Se.c V. IFaM, II. & R. 215; Rc!/. v. Ussex, 1 D. & B. C. C. 371 :
27 L. J., M. C. 20.
(A) Ecff. V. WiUiams, 2 C. & K. ol. Filling a form of clieque already-
signed, with blanks left in it for the sum, is forgery ; Ilotcer v. Hhaiv, 2
C. & K. 703. So, iilling in a blank cheque with a larger sum than that
authorized by the drawer, is a forgery ; licq. v. V/ilao/i, 17 L. J., M. C. 82.
(') Hoj. Y. A'deij, 1 D. & B. C. C. 291 ; "26 L. J., M. (J. 190.
92 CHEQUES.
sustain an indictment for forgery, althougli tlie cheque is
valid (i).
A cheque, although post-dated, is an order for the pay-
ment of money {k) .
Where an instrument is, in any respect, incomplete, and
therefore not operative, an indictment for forging, or felo-
niously uttering, an indorsement on it wiU not lie. Semble,
however, -the facts would support an indictment for forgery
at common law (/).
A cheque drawn by a person in a fictitious name
amounts to a forgery under the act, unless the cheque
was drawn and uttered as /it's oini, and it was so received
•by the payee, in which case his subscribing a fictitious
name will not make it a forgery, the credit being there
given wholly to himself without any regard to the name
or any relation to a third party. Thus, the prisoner
Robert Martin, in payment for a pony and cart purchased
by him from the prosecutor, drew a cheque in the name of
William Martin in the presence of the prosecutor upon a
bank at which he, the prisoner, had no account, and gave
it to the prosecutor as his own cheque drawn in his own
name. At the time he drew the cheque, the prisoner
knew that it would be, as in fact it was, dishonoured.
The prosecutor received the cheque in the belief that it
was drawn in the prisoner's own name : — Held, that the
prisoner was not guilty of the offence of forgery (;//).
On an indictment for uttering a forged cheque, it is not
necessary to call the supposed maker to disprove an autho-
rity from him to any other person to sign in his name ; it
■ is sufficient to disprove the handwriting [a).
A cheque purported to be di-awn by G. A. upon
bankers ; evidence that no person named G. A. kept an
account with or had any right to draw on the bankers was
(t) Iter/. V. Wardill, 3 F. & F. 82.
{k) licg. V. Taylor, 1 C. & K. 213.
(0 lieg. V. Uurpcr, 7 Q. B. D. 78 ; Ren. v. Tui-pm, 2 C. & K. 820.
(;«) Req. V. Martin, •') Q. B. J). 34; see also Dimii^a case, 1 Lea. C. C. 59.
[)i) llnj. V. Hark,/, 2 M. & IJob. 473.
OFFENCES IN RELATION TO CHEQUES. 93
held 2)rimd facie sufficient proof that G. A. was a fictitious
person (o). Upon an indictment for forging a cheque,
dated Knighton, and purporting to be drawn by John
Hust, proof that no John Hust lived at Knighton, who
was likely to keep an account with a banker, was held suffi-
cient to show that John Hust was a fictitious person (j)).
To alter a cheque, which is crossed with the name of a
banker, with intent to defraud, is a forgery {q) .
In criminal proceedings, a cheque, although it may not Unstamped
be duly stamped, is admissible in evidence, by virtue of JnissiWein"
the exception contained in sect. 17 of the Stamp Act, evidence.
1870.
(o) Hex Y. Backler, 5 C. & P. 118.
(;j) Reg. v. Ashby, 2 F. & F. 560.
{q) Ante, p. 91.
( 91 )
CHAPTER XV.
LETTERS OF CREDIT AND CIRCULAR NOTES.
Letters of A LETTER of credit is an instrument, in common use
^^^ ^ ■ among bankers, for the transmission of money either within
the United Kingdom or to the colonies, or to foreign
countries (a). It is not negotiable as a cheque, but is
only an authority from the banker who signs it to the
banker or other person to whom it is addressed, upon
advice, to honour the drafts of the person named in it, and
who produces the letter ; and consequently he alone is
entitled to draw the drafts or to receive payment,
A letter of credit, saying "Please to honour the drafts
of A. to the amount of 460/. and charge the same to the
account of B.," is an authority to make the payment, but
the possession of the document by the person to whom it
is addressed does not prove that the payment has been
made {b). In order to show that the payment has been
made there must be a draft by A. in piu'suance of the
direction and authority of the letter {h).
As a letter of credit is not a negotiable instrument, if it
is stolen, or lost, and the banker, upon whom the letter of
credit is drawn, honours the drafts or pays the amount
uj)on a forged signature, he is not thereby discharged ;
neither is the banker granting the letter of credit : for
payment must be made in strict conformity witli the
letter (/;).
The statute 16 & 17 Yict. c. 50, s. 11), does not apply to
letters of credit (c) .
{a) Cliitty on Bills, S-jO (lOtli edit.) ; Story on Bills, ss. 459— 4G3 (4tli
edit.).
(i) Oir V. U>iioii Bank of Scotland, 1 Macq. H. L. Gas. 513 ; 2 C. L. K.
16GG ; Brithh Linen Company v. Caledonian Insurance Companij, 4 Macq.
H. L. Gas. 107j 7 Jur., N. S. 587.
(p) British Linen Company v. Caledonian Insurance Company, 4 Macq.
107. As to this stnttit«, see p. 22.
LETTERS OF CREDIT AND CIRCULAR NOTES. 95
A letter of credit, which had been issued hy bankers in
this country in favour of Mr. Robert Thomas with a re-
quest to honour his draft for the amount therein mentioned,
was addressed to their agents, the Oriental Bank Corpora-
tion, Melbourne, in Australia; a person, having wrongfully
obtained possession of it, presented it with a forged in-
dorsement of the payee to a banker in this country to get
cashed or collected for him, and was indicted for forging and
uttering an order ; at the trial evidence was given that,
according to banking practice in this countrj^, a letter of
credit of this description was usually paid on the simple
indorsement of the payee, but whether it would be so paid
at Melbourne was not shown ; though, according to usage,
on the presentation of the letter of credit at Melbourne,
the bank there would take pains to ascertain the identity
of the person credited, and, on being satisfied, would credit
him to that amoimt, and, in the terms of the letter of
credit, would honour the draft of the party to the extent
of the letter of credit.
It was objected, on behalf of the prisoner, that the in-
dorsement was not shown to be an order, and Bramwell, B.,
said, " It is quite true that, if the bank at Melbourne chose
to pay such a letter on the simple indorsement of the person
credited, the latter could not afterwards oblige the bank
to pay him a second time. But the letter of credit was
directed to the Oriental Bank at Melbourne, which was to
* honour the draft ' of ' Robert Thomas.' I think the
simple indorsement in this country is not an order, not
being within the original mandate, and I must direct the
jury to acquit the prisoner. Perhaps," the learned judge
added, " the prisoner might be indicted for the misde-
meanor of attempting to obtain the money by false pre-
tences" {(l).
By the Companies Act, 1862, s, 41, a company ha-\ang Issue by
its liability limited, either by shares or by guarantee, shall ij^^^i^ty com-
panies.
{f?) Pxeg V. WiUon, 1 F. & F. 391.
96
LETTERS OF CREDIT AND CIRCULAR NOTES.
Marginal
letters of
credit.
have its name mentioned in legible characters on letters
of credit, purporting to be signed by or on behalf of the
company; and by sect. 42, if a director, manager, or
officer of the company, or any person on its behalf, signs,
or authorizes to be signed, on behalf of the company, a
letter of credit, wherein its name is not so mentioned, he
shall be liable to a penalty of oO/., and shall further be
personally liable to the holder of such letter of credit, for
the amount thereof, unless the same is duly paid by the
company.
If the drafts drawn by the owner of the letters are not
honoured, he may recover from the grantor monies paid by
him in respect thereof, and the same rule applies where
after payment of the drafts any surplus remains. It is his
duty, however, first to restore the letters to the grantor (e).
With respect to marginal letters of credit, which are
letters of credit written in the margin of blank bills of
exchange (,/'), they are described in the report of a case in
which their real character and operation are defined ((/),
and from which the following account is derived.
The course of dealing and practice relative to the issue
and user of marginal letters of credit differs considerably
in different parts of the mercantile world, and the terms
of such issue and user depend upon the actual agreement
between the parties, and upon the terms apparent on the
{e) Conflam Quarry CompaDij v. Parker, L. R., 3 C. P. 1.
(/) The fonn of a marginal letter of credit is as follows :
No. 39.
o Credit for £2,000 stg. in duplicate. 4907.
*{ National Bank of Scotland, Edinburgh,
^ 24th June, 18G4.
To Messrs. Flrtdior & Coinpimy, Cliina.
I hereby, for the National Bank of Scotland,
authorize you to diaw the annexed BUI of Ex-
change at six montlis' sight for Two thousand
pounds sterling on Messrs. Glyn k. Co., Bankers,
in London, wlio ■nill honour the same in confor-
mity with its tenor, if presented along with this
Letter of Credit within one year from this date.
Tiios. Anukkso.v, Secretary-.
Jso. J. Shearer, P. Manager.
First of Exchange for £2,000 sterhng. No. ^^ F.
— ^ — " 4907
Place and date of drawing, Shanghai, 5th April,
1865.
Si.x months after sight \>ny this fii-st of Ex-
change (second of the .same tenoi- and date not
being accepted or paid), to oui' order, the sum of
Two thousand pounds sterling, which charge to
the National Bank of Scotland as per annexed
Ijotter of Credit.
To Messrs. (rlj-n & Co.,
Bankers, Ivondon.
Drawer signs here, Fletcher & Co.
{g) Maiilaiid v. The Churtvnd MircoHlUc Bank of linlui, Lumlun and Chltia, S8 L. J.,
Chanc. 3G3.
LETTERS OF CREDIT AND CIRCULAR NOTES. 97
face of sucli marginal letters of credit. It is a common, but
by no means an invariable, practice, that wben such mar-
ginal letters of credit are granted by a bank in this
country, in favour of a firm carrying on business abroad,
the bank granting the letters of credit requires the secu-
rity of some firm carrying on business in England for the
rejDayment of any money which may be paid in respect of
any draft drawn under such letter of credit ; but if the
credit of the foreign firm were good, such security would
not in all cases be considered necessary ; and, accordingly,
whether such security is given or not depends on the
credit and standing of the firm in whose favour such
letters of credit are granted. The marginal letters of
credit which are issued in this country, according to the
usual practice, are sent to the foreign firm, not merely to
enable it to raise funds for buying produce to be con-
signed to England, but as a guarantee to the purchasers
of the bills of such foreign firm that such bills will on
presentation be accepted, and also to give more complete
facilities for raising money to the foreign firm in whose
favour such marginal letters of credit are issued {h).
Marginal letters of credit are usually either " open ere- Open credits
dits " or " documentary credits." " Open credits " are, on t^iy CTeditr""
the face of them, engagements on the part of the person
giving such credits to accept the drafts drawn under sucli
credits unconditionally, except that generally there is a
certain limit as to the time within which the credits are
to be available ; whereas " documentary credits " are en-
gagements to accept bills drawn under them subject to a
condition or a proviso on the face of the credit that the
drafts, when presented for acceptance, are to be accom-
panied by bills of lading or shipping documents (?').
A bond fide holder of a bill of exchange, drawn under
(//) Ibid, at pp. 366-7.
((■) In re Agra and Mastcrma it's Bank, Ex parte Asiatic Company, L. R.,
2 Ch. 391; 'Banner v. Johnston, L. R., 5 H. L. Cas. 157; 40 L. J.,
Chanc. 730 ; Vnion Bank of Canada v. Cole, 47 L. J., C. P. 100-C. A.
G. 11
98 LETTERS OF CREDIT AND CIRCULAR NOTES.
one of these open letters of credit and taken by Mm, can
maintain an action against the grantor of the letter of
credit in case of his refusal to accept the bill. " The
marginal note which is put upon the face of the bill of
exchange," Yice- Chancellor James said, "is intended to
be a representation or a promise to any person who should
become in due course the holder of that bill of exchange,
that the bill would be duly honoured, and it would be
clearly a contract with the owner, which would be a legal
contract, the right of which would attach with the bill of
exchange, and in that sense the contract is negotiable and
assignable with the bill of exchange" {J).
So, where open letters of credit were granted to Fletcher
& Co., a China firm, on the guarantie of Maitland & Co.,
an English firm, and Fletcher & Co., in fraud and viola-
tion of their agreement with Maitland & Co., drew bills
under them not protected by shipping documents, and
indorsed them for value to a bank who had no actual
notice of the agreement between Fletcher & Co. and
Maitland & Co. ; Vice- Chancellor James held, that the
bank was entitled to require the grantors of the letters of
credit to accept the bills, and that Maitland & Co. had no
equity to restrain them from procuring such acceptance (,/).
But as to the custom alleged that, according to the
ordinary course of dealing in reference to letters of credit
granted to foreign firms, the foreign firm could only obtain
letters of credit upon the guarantie of some English firm,
and that the foreign firm stipulated to use the letters of
credit only for the purpose of buying goods to be consigned
to England, and to transmit the bills of lading to the
English firm as a security for the repayment of the bills
of exchange drawn under the letters of credit by a mail
not later than that which carried the bills of exchange ;
the Vicc-Chancellor determined no such custom existed
as Maitland & Co. averred, and that even if there was
such a custom, the rights of tho bank as a bond fide holder
{j) Maitland v. The Chartered jlfcrc<(>itile ]>ank of India, Londf»i and
China, 38 L. -T.. Chaiip. ^63.
LETTERS OF CREDIT AND CIRCULAR NOTES. 99
for value could not be affected by tbe mere constructive
notice of the agreement between Maitland & Co. and
Fletcher & Co. which the custom would imply. " It is
quite a novelty," the Yice- Chancellor observed, " to me
to have it suggested that the negotiability of a negotiable
instrument is to be affected by any private arrangement of
that kind, which parties do not choose to put on the face
of the document. That distinction seems to me to be
actually expressed in the paragraph of the answer which
draws a wide distinction between an open letter of credit
and a documentary letter of credit. If it were intended
to limit Fletcher & Co. in the use of this letter of credit
as between themselves and the world at large to a use for
mercantile purposes connected with the purchase of goods,
it would have been very easy to have expressed upon the
face of the document that it was to be accepted if pre-
sented accompanied by biQs of lading, or other documents
representing mercantile transactions" (/»•).
An open letter of credit constitutes also a contract to the
benefit of which persons taking and paying for bills on the
faith of it, are entitled in equity, without regard to any
equities between the bank granting it and the parties to
whom it is addressed, and the holder is entitled to prove
on the winding-up of the bank for the amount due on the
bills without regard to the state of the account between the
bank and the addressees of the letter of credit (/) .
An indorsee of a marginal letter of credit, not being on
the face of it a document of credit, is not bound, in the
absence of notice, to inquire whether it is being used for
the purposes for which the credit was given {m) .
But when a bank issues a letter of credit, on the terms
that the bills which they agree to accept are to be covered
by bills of lading to a like amount, suspension of payment
(/.) Ibid, at p. 368, and see ante, p. 97.
(/) In re A(/ra and Masterman'' s Bank, Ex parte Asiatic Banking Com-
pan>j, 2 L. R., Ch. 391.
{m) Maitland v. Chartered Mercantile Bank of India, London and China,
2 H. & M. 440 : 12 L. T., N. S. 372.
h2
100 LETTERS OF CREDIT AND CIRCULAR NOTES.
by the bank, before there has been time for the letter of
credit to be used, is not a breach or a repudiation of the
contract ; inasmuch as permission might have been given
to the liquidators under the winding-up to negotiate the
bills, and a claim by the holder of the letter of credit for
damages for the alleged breach will be disallowed {n).
Where the grantor of a marginal letter stops payment,
and fails to meet it, the grantee is entitled to recover com-
mission, notarial and all other necessary expenses (o).
A bank granted a letter of credit to a company on terms
that the company should ship tea and forward bills of
lading, invoices, and policy of insurance on the tea to the
bank, and should also draw on Barber & Co. bills, to be
accepted by Barber & Co. to an amount sufficient to
cover the amount authorised by the letter of credit.
Barber & Co. guaranteed the performance by the company
of these terms " holding themselves responsible for the
same." The company drew on the bank, and the bank
accepted the bills, but owing to the failure of the bank
after the dates when the bills were drawn, and before they
became due, the company shipped no tea, and did not
perform any of the terms agreed on. All the bills were
eventually paid : — It was held, that the failure of the bank
was no reason why the comj)any should not have per-
formed its part of the contract, and that Barber & Co.
Avere not relieved from their guarantie (p).
Stamping. By the Stamp Act, 1870, s. 48 (1), the term " bill of ex-
change" for the purpose of the stamp duties includes {infer
{») In re Agra Bank, Ex }Hirte Tondcur, L. R., 5 Eq. 160.
\o) Prchn V. Liverpool Bank, L. R., 5 Ex. 92; 39 L. J., Exch. 41; In
re General South American Company, Ex parte Jianco de Lima, 7 Ch. D. 537;
47 L. J., Chanc. 67; 37 L. T. 599; 26 W. R. 232. As to proving in
winding-up companies, see Barned's Banking Company, L. R., 5 Ch. 167;
KeUock'fi ease, L. R., 3 Ch. 767; Forivood's Claim, L. R., 6 Ch. 18. By
the Judicature Act (38 & 39 Vict. c. 77), s. 10, the rules in a winding-up
of a company are assimilated to those in bankruptcy. See In re West-
bourne Grove Drapery Company, L. R., 5 Ch. D. 248; In re Suche, 1 Ch.
D. 48; In re Withernsea Brickworks Company, 16 Ch. D. 337; T/tomas
V. I'atcnt Lionite Company, 17 Ch. D. at p. 258.
{p) Ex parte Agra Bank, In re Barber cj- Co., L. R., 9 Eq. 725; 39 L. J.,
Bank. 30.
notes.
LETTERS OF CREDIT AND CIRCULAR NOTES. 101
alia) a letter of credit, and any document or WTiting
(except a bank note) entitling or purporting to entitle any
person, whether named therein or not, to payment by any
other person of, or to draw upon any other person for, any
sum of money therein mentioned {q) ; but (4) a letter of
credit granted in the United Kingdom authorizing drafts
to be drawn out of the United Kingdom payable in the
United Kingdom is exempt from duty.
Circular notes are instruments similar to letters of credit, Circular
drawn by bankers in this country upon their foreign cor-
respondents, in favour of persons travelling abroad (r).
The persons in whose favour these notes are granted
usually carry with them gi letter containing their signature
(called a letter of indication), for exhibition to the corre-
spondents on presentation of the notes, and for comparison
with the signature, which the holders are required to give
before payment, in order to satisfy the correspondents of
their identity. A banker is not bound to return the amount
paid for a circular note so long as the note is outstanding,
and there remains a possibility of his being called upon to
pay a correspondent who may cash it. The banker, in
such case, before he returns the money paid for the note,
is entitled to receive a sufficient indemnity in respect of
the outstanding note, which is only enforceable imder the
terms of the 17 & 18 Yict. c. 125, s. 87. In case of its
non-negotiation the banker is bound on the production of
the circular note to return the money is) .
{q) The 16 & 17 Vict. c. 59, Sched., defined a letter of credit to Le "a
document or writing whereby any person to whom any such document is,
or is intended to he, delivered or sent, shall he entitled, or be intended, to
have credit with, or in account with, or to draw upon any other person
for, or to receive from such other person, any money therein mentioned."
Letters of credit were expressly chargeable with the stamp duty of one
penny, imposed by that statute upon drafts payable to order on demand ;
but letters of credit, whether drawn in set.s or not, which were sent by
persons in the United Kingdom to persons abroad, authorizing drafts on
the United Kingdom, were exempt. This statute is repealed.
(r) Hare v. Copland, 13 Ir. Com. Law Rep. 443.
(s) Conjlans Stone Quarry Company v. Parhcr, 37 L. J., C. P. 51; L. K.,
3C. P. 1.
102 ORDERS TO BANKERS.
OHAPTEE XVI.
ORDERS TO BANKERS.
I. Orders to Pay.
Bills of Exchange. — We will next pass to the considera-
tion of the duties of bankers, and their liabilities and
rights, as regards bills of exchange made payable at their
banking houses.
General or Formerly, it was for a long time much disputed whether
acceptance. ^ ^^^^ ^^ exchange drawn generally, but accepted payable
at a particular place named on itf ought to be presented at
that place, in order to ground a cause of action by the
holder against the acceptor. At length this doubt was set
at rest by a decision of the House of Lords, which de-
clared the law to be, that an acceptance made payable at
a specified place was a qualified acceptance, which im-
posed upon the holder, in an action against the acceptor,
the necessity of stating and proving presentment at that
place, in order to recover on the bill {a). The Legislature,
however, thought this part of the law required some alte-
ration, and accordingly the statute 1 & 2 Geo. IV. c. 78,
was passed, enacting, that an acceptance payable, on the
face of it, at the house of a banker or other place shall
be considered to be a general acceptance, unless it be ex-
pressed to be payable there onhj, and not othencise or else-
where {b). The statute, it is to be observed, only mentions
acceptances ; it has been decided that a drawer cannot
render the bill payable only at a particular place, by
stating it to be so in the body of the instrument, so that
(a) Jiour V. Yoiatff, 2 B. & E. IGo ; 2 Blis-h, 391.
(h) The holder of a draft may refuse to take a sjoecial acceptance, and
resort to the drawer at once. Gammo)i v. Sc/imolf, 5 Taunt. 353. A
person who takes a qualified acceptance is bound to p-ivc notice to the
drawer ; for iioii constat that he will assent to the qualified acceptance,
see 9 M. & W. 509. A draft accepted i)ayablo at a banker's is not a
.special or qualified acceptance, and is generally esteemed of higher com-
mercial credit than a special or qualified acceptance, or an acceptance not
made payable at a banker's.
ORDERS TO PAY. IQ',
a bill made by the drawer, payable at a particular place,
is nevertheless accepted generally, unless the acceptor
accepts it in the above terms, saying, that it shall be paid
at that place only, and not otherwise or elsewhere (c).
Since the statute there are three different modes (two
of them, however, differing chiefly in form) in which a
bill may be accepted; 1, generally; 2, payable at a
banker's named ; 3, payable at a particular banker's only,
or not otherwise or elsewhere ((/). Now, if the drawee
accepts generally, there can be no doubt that he undertakes
generally to pay the bill, at maturity, when presented to
himself ; if he accepts in the second form, then the holder
has the option either of presenting to the acceptor himself,
or at the bankers specified, and that within banking hours ;
for in that case the acceptor's undertaking is to pay the
bill, at maturity, on its being presented in either way ; if
the acceptor adopts the third mode, then, of course, he ex-
cludes the holder from any other mode of presentment,
than to the banker named, and that within banking
hours (e). Hence, in suing an acceptor of a bill accepted
payable at a banker's in the second mode, it is not neces-
sary to allege or prove presentment there {e) . In suing the
drawer, or an indorser, however, the case is different ;
for, as against them, it is still necessary, if the bill is
accepted payable at a banker's named by the acceptor, to
prove presentment there (/) ; so if made payable in the
body at a banker's and accepted generally (_/') ; and if the
(r) Sclhy V. Eden, 3 Eing. 611 ; 11 Moore, 511 ; Faijlc v. Bird, 6 B. & C.
531.
{d) It "will suffice to accept payable at such a bauk, "and not other-
wise," without adding "only." Wu/glns v. Nichols, 7 Dowl. 551.
{<■) mihtead V. Skclton, 5 Q. B. 92"; Bailey v. PorUr, 14 M. & W. 44.
There is no objection, in declaring in an action against an acceptor, to a
statement that the bill is accepted payable at a particular bankers,
though, in fact, the acceptance is in the second foiin. Blaise v. Beau-
mont, 4 M. & G. 7 ; 1 Dowl. (N. S.) C97. That the presentment must be
made within baiJdng hoiu-s, see Farker v. Gordon, 7 East, 385 ; JFhitakcr
V. Bank of England, 1 C, M. & E. 744; Wilkins v. Jadis, 2 B. & Ad.
188 ; it may be made after, if the bank is not shut, or if any one is there
to say if there are no orders. Garnctt v. Woodcock, 6 M. & S. 44.
(/) Gihh V. Mather, 8 Bing. 214 ; 2 C. & J. 251 ; Saul v. Jones, 1 El. k
Bl. 59 ; 28 L. J., Q. B. 37.
ORDERS TO BANKERS.
bill is dmivn payable at a particular place, in order to
cbarge the drawer, or an indorser, it is necessary to show
a presentment at that place; for such must have been the
case before the statute, and the statute was not intended to
alter, and has not altered, the liability of drawers or in-
dorsers of bills of exchange ; it is confined in its operation
to acceptances alone {[/).
If a bill of exchange is accepted, payable at bankers',
and, in the course of business, is indorsed to the bankers,
they, on suing the indorser, have no need to show that
they presented it to the acceptor ; for, as the bankers, at
whose house the bill was to be paid, were themselves the
holders of it, it was a sufficient demand, for them to turn
to their books and ascertain the state of the acceptor's
account with them, and a sufficient refusal, to find that he
had no effects in their hands {//) ; and a letter written, on
the day when the bill became due to the indorser, on
behalf of the bankers, stating the acceptor's bill to be un-
paid, and requesting the indorser's immediate attention to
it, is sufficient notice of dishonour {/i).
Precisely the same has been laid down, as the law with
respect to a promissory note, stated by the maker in a
')nemorandum to be payable at a banker's, to whom it
was indorsed in the course of business, and who sued the
indorser (/).
Where the drawer of a bill of exchange, accepted gene-
rally (subsequently to the passing of the 1 & 2 Greo. IV.
c. 78), added the words "payable at R. & Co.'s, bankers,
Loudon," without the knowledge of the acceptor, and then
indorsed it for valuable consideration, the bill being over-
due, and the indorsee privy to the alteration, the alteration
was held to be a material one, and the acceptor was held to
be discharged ; notwithstanding the argument which was
iff) Hee Boi/dcll v. Harlcness, 3 C. B. 168; 4 D. & L. 179: Ilnn
Tarker, 3 Tyrw. 370 ; Fm±i v. J-Jflffe, 1 C. & M. 429.
(//) Bailci/ V, Porter, 14 M. & AV. 44.
('■) SnumlcrsoH v. J>((Iije, 2 II. Bl. 400.
ORDERS TO PAY. 105
pressed, that, since the statute, this was only a general
acceptance, and that no demand was necessary against
the acceptor, and that, consequently, in an action by the
indorsee against the acceptor, it was not possible to contend
that he was prejudiced (/).
A bill was accepted, payable at a bank, which was also
that of the drawer ; the drawer discounted it with them,
and indorsed to them ; they rediscounted, and, on maturity,
paid it, without indicating to the holder whether they paid
as indorsers, or as agents for the acceptor. The acceptor's
account being overdrawn, the bank gave notice of dis-
honour to the drawer, and he was debited with the amount.
It was held, they had a right to pay the bill as indorsers,
taking time to inquire if they W'ould honour the bill or
not {m).
Again, where a drawer, after getting a bill accepted,
payable at his bankers, kept the bill by him for some
years, during which period the bankers became bankrupt,
and then having erased their names, and substituted the
name of another banker, without the knowledge of the
acceptor, indorsed the bill, it was decided that the acceptor
was discharged, the alteration being considered to be mate-
rial ()i). Whether an acceptance is or is not a conditional
one is a question of law (o) .
A bill of exchange was accepted " payable on giving
up bill of lading for seventy-six bags of clover seed per
Amazon, at the London and Westminster Bank, Borough
Branch:" it was held, that this was a conditional accept-
ance to this extent, that the holder was only entitled to
receive the amount on delivering over to the acceptor the
bill of lading, but that he was not bound to present the
bill on the precise day on which it became due, and con-
(/) Mackinfoi^h v. Haydon, R. & M. 362 ; see Burchfivld v. Moore, 23
L. J., Q. B. 261 ; 3 El. & Bl. 683. As to the effect of altering a nego-
tiable instrument, see Master v. Miller, 1 Sm. L. Cas. 857, 8th ed., and
notes thereto.
(;«) Follard v. Ogden, 1 El. & Bl. 459.
(«) Tidmarsh v. Grocer, 1 M. & S. 735.
(o) Sjjroid V. Mathews, 1 T. R. 182.
106 ORDERS TO BANKERS.
sequently tliat the acceptor was not released from his
liability (p).
The fact of returning a bill, accepted payable at the
acceptor's bankers, to the indorsee's bankers, at the Clear-
ing House, with "orders not to pay'.' wiitten on it, and
" cancelled by mistake" also, does not enable the indorsee
to recover against the bankers, as for money had and re-
ceived ; but if the bankers have been guilty of negligence
or want of due and reasonable care, and special damage
has accrued therefrom to the holder, an action may be
maiutained against them {q) .
If a bill is accepted, payable at a particular town, pre-
sentment, it is said, at all the banking houses in the town
is sufficient (>■).
If a bill is made payable at a particular bank by the
acceptor, then, in an action by the indorser against the
drawer, it is not necessary to allege a presentment to the
acceptor at the bank; it has been decided to be enough
to aver the presentment to have been made there (s) .
As has been stated, where a bill is accepted payable at a
banker's, and the acceptor's address also appears on the
bill, the holder has not the option of presenting either at
the place named in the addi-ess or at the place named in the
acceptance, in order to charge the dmn-er or an indorser ;
but he must present it at the place indicated by the accept-
ance, viz., at the particular banker's mentioned {t) . If, how-
ever, the holder presents at the bank, and is refused pay-
ment, he may sue the other parties to the bill Avitliout any
other presentment {u). An acceptor, having funds to meet
{p) Smith V. Vcrtue, 9 C. B., N. S. 214 ; 30 L. J., 0. P. 56. See also
Banbury v. Zinsctl, 2 Str. 1211 ; Smtt/i v. Ahhott, ib. 1152.
[q) JFaniickw. Itofjers, 5 M. & G. 310; Wilkinson v. Johnston, 3 B. «&
C. 428 ; Ingham v. I'rimrose, 28 L. J., C. P. 204 ; Xovelti v. liossi, 2 B. &
Ad. 757; Eapcr v. Birkheek, 15 East, 17; J'lincc v. Oriental Bank Corpora-
tion, L. R., 3 App. Gas. 325 ; 2G W. P. 543.
Ir) llarchjy. Woudroofe, 2 Stark. 319.
(s) Shelton v. Braithicaite, 8 M. & W. 252 ; Bhilpot v. Bryant, 3 C. & P.
244.
{t) Saul V. Jones, 1 El. & Bl. 69 ; 28 L. J., Q. B. 37.
(m) Mackintosh v. Hai/don, R. & M. 362 ; Ilankcy v. Bcruick, 4 Bing.
135.
ORDERS TO PAY. 107
the bill in tlie bankers' hands, is, it is submitted, not
exonerated if thej fail after the maturity of the bill, but
before it has been presented, provided the holder has not
been guilty of laches (.r).
A bill, dated September 8th, 1856, was drawn on B. &
Co., payable in London at four months after date. It was
accepted as follows : " Accepted payable at Messrs. Over-
end, Gurney & Co., London. No. 1756. Due 11th
Dec. 1856. B. & Co.:" it was held, that the words
" Due 11th Dec. 1856," did not quahfy the acceptance,
but were, at most, an inaccurate description of the date of
the bill (y).
A person who accepts a bill, payable at his bankers', is
held thereby to give autliority to the bankers to apply to
the payment of it any funds of his in their hands, and
there is no necessity for them to have any other or more
specific authorization than the terms of the acceptance
itself (:;). Bankers refusing to pay such an instrument
when presented are liable to be sued by their customers («) .
The like authority would also be given to pay a promissory
note which the customer has made payable at his bankers'.
But from what has already been laid down, to the effect
that bankers are bound to know the handwriting of their
customer, it is manifest they would not be exonerated if
they paid the bill or note, and it turned out that the bill
or note was forged {b).
BUI, to whom 'payahle. — A banker paying a bill, accepted Bill, to whom
by a customer as above, and bearing an indorsement pur- ^^^^ ^'
porting to be in the handwriting of the payee, but being,
{x) Scbag V. Abiihol, 4 M. & S. 462 ; Turner v. Umjdon, 4 B. & C. 1 ;
Ehodes \. Gent, 6 B. & A. 246.
{y) Fanshau-e v. Feet, 2 H. & N. 1 ; 26 L. J., Exch. 314.
(s) Kijmer v. Laurie, 18 L. J., Q. B. 218. The bankers cannot sue on
the bill, for it is functus officio, by the law merchant, when once paid by
or on the behalf of the acceptor. See also Whit taker v. BanJc of Fiujland,
1 C. M. &R. 744; Farleii v. Turner, 26 L. J., Chanc. 710.
(a) mil V. Smith, 12 M. & W. 618 ; Bell v. Carey, 8 C. B. 887.
(A) Smith V. Mercer, 6 Taunt. 76; 1 Marsh. 453; Woods t. Thiedeman,
1 H. & C. 478.
ORDERS TO BANKERS.
in fact, a forgery, and being accepted after this and other
indorsements had been made on the bill, and presented at
the Clearing House by a banking firm, who were indorsees,
was not, it has been held, justified, by reason of such
forged indorsement, in paying to the holder or indorsee,
who could not give a legal discharge, and consequently the
banker could not debit the account of the acceptor with
the sum paid (c) . As to his right to recover as against the
holder of the bill the rule would seem to be that he is so
entitled, if the forgery has been immediately discovered,
and notice given to the holder (d).
If, when a person accepts a bill payable at his bankers',
his account with them is in such a state as not to be ade-
quate to pay the whole amount for which the bill is ac-
cepted, and they pay the whole amount, for the honour of
their customer, they would be entitled to recover from the
customer the difference between the amount of his moneys
in their hands, and the sum in the bill, either as so much
money lent to him, or paid for his use. But in order to
recover the amount, the bankers must prove the indorse-
ment by the payee, as well as the acceptance by their
customer ; if either is a forgery, they will not be en-
titled (^).
A banker, receiving a sum for the express purpose of
taking up a bill made payable at his bank (which purpose
should be expressed in writing in order to avoid any ques-
tion as to proper authority), without objection at the time,
cannot apply it to discharge the amount by which the
customer paying in the money has overdrawn his account,
nor ought he to pay cheques, drawn subsequently to the
bill, before he pays it (/).
i?/// icJien paid. — Next, when is a bill made payable at
a banker's said to be paid ? Now, in a case of a contract
{c) Tuclcer v. Roharts, IG Q. B. 5G0 ; Hall v. Fuller, 6 B. & C. 750.
(d) Cox V. Masterman, 9 B. & C. 902 ; Smith v. 3rerccr, 6 Taunt. 76.
{e) Forstry v. C/finoifs, 2 Camp. 1 7.
(/) Be Bcrnaks v. Fidlo; 14 East, oOO, u.
ORDERS TO PAY. 109
to pay money, that can only properly be called payment,
which is payment according to, and in the terms of, the
contract (/) ; so that payment, by a stranger, does not
discharge the party contracting to pay, unless made by
the stranger as his agent, and with liis prior authority or
subsequent ratification. Hence, payment by a stranger
of the amount of a bill of exchange to the bankers,
at whose house it was made payable by the acceptance,
under an arrangement with them, whereby the person
paying obtained possession of the bill for a collateral
purpose of his own, is not a payment of the bill by the
acceptor {g).
Payment of Bills of Exchange by Cheques Provisional Payment by
or Absolute.— T\iQ branch bank of the Bank of England ^^^i^^? P™'
o visional or
at Newcastle discounted a bill of exchange drawn by a absolute,
customer upon H. & Co., and accepted by them payable
at the bank of L. & Co., also bankers at Newcastle. Ac-
cording to the practice prevailing among bankers at New-
castle, the branch bank, on the morning when the bill
became due, took it to L. & Co., who marked it for pay-
ment, and gave a credit note, indicating that it with other
moneys was in order for payment and would be paid.
About 2 P.M. on the same day, a clerk of the branch bank,
in accordance with the practice, took all the cheques which
had been received, drawn on L. & Co., together with the
credit note, to the bank of L. & Co. The credit note
was admitted into the total amount, and a cheque upon
the branch bank was in accordance with the practice
handed by L. & Co. to the clerk for the amount of the
balance due to the branch bank. At 3 p.m. the banks at
Newcastle close to the public, but it is the practice for the
bankers who keep accounts with the branch bank to attend
at such bank, before it finally closes for the day at 4 p.m.,
(/) Simpson V. Efjgington, 24 L. J., Exch. 313; 10 Exch. 845; Church
V. Bishop, 2 Ves. sen. 272 ; Smith v. Craven, 1 C. «& J. 500.
[g) Dtacon v. Stodhart, 2 M. & G. 317: see Cook v. Lister, 13 C. B.,
N. S. 543; 32 L. J., C. P. 121.
110
ORDERS TO BANKERS.
for tlie purpose of having the day's accounts investigated,
and of rectifying any mistakes or errors which may have
arisen in the course of the day, and finding and striking
the final balances between them. When the bank of L. &
Co, closed at 3 o'clock it was ascertained that H. & Co.
had stopped payment, and that their balance was not suffi-
cient .to meet the bill. Notice was at once and before
4 P.M. given to the branch bank that the bill had been paid
in en'or, and they were requested to take it back. Before
such notice was received, the account of L. & Co. had
been debited with the amount in the accounts of the branch
bank. The Court held, that as it was not shown that the
giving the cheque was provisional only, or subject to recti-
fication upon going over the accounts later in the day,
such giving the cheque by L. & Co. amounted to payment
of the bill of exchange to the branch of the Bank of Eng-
land, and that the customer was entitled to have credit
with them for the amount of the bill (/) .
Refufsal to
pay-
lief used to pay. — No action will Ke by the holder against
a banker for refusing to pay a bill so accepted, there being
no privity between them (/.•) .
Specific ap-
propriation of
moneys to
take up bills.
Specific Appropriation of Moueijs to talx np Bills. — But
money paid in, by a customer, expressly for the purpose
of meeting a bill, accepted by him, and lying at the bank
for payment, is, so far as he is concerned, money paid and
received to the use of the holder of the bill, and cannot be
applied to the general account of the customer (/).
But where a person paid a sum into a country bankers'
with written directions to apply it to meet a bill of ex-
change payable the next day at the country bankers'
(i) Pollard v. Hank of Hiioland, 40 L. J., Q. B. 233: L. R., G Q. B.
623.
(k) Stewart v. Fry, 1 Moore, 74 ; 7 Taunt. 339 ; Eill v. Eomh, L. E.,
8Eq. 290; 38 L. J., Ch. 538.
(0 De Jhrtiales v. Fulhr, 14 EaHt, 590, n. ; J{iU v. S»iU/i, 12 M. k W.
G18 ; Fiirlr;/ v. Tnnicr, 26 L. J., Chanc. 710.
ORDERS TO PAY. Ill
London agents, and tlie country bankers stopped pajmient
the next day without having advised their London agents
of the payment of the sum, and the bill on being presented
was dishonoured, and the country bankers having made
no specific appropriation of the sioii, he was only entitled to
prove as a general creditor (/;«).
Customers of country bankers paid in to the bankers'
a sum of money in bank notes, and also some bills of ex-
change, to be remitted to London in order to meet certain
acceptances. The bankers sent to their London agents the
bills, and some bank notes, with a letter du-ecting them to
pay a certain sum of money, also giving them notice of
the acceptances as payable at their bank, and giving direc-
tions as to other business. The country bankers stopped
payment, owing a large balance to the London bankers : —
Held that, as between the country customers and the
London bankers, there was no appropriation of the bills
and notes to meet the acceptances, and that the London
bankers could retain the bills and notes without meeting
the acceptances (n) .
Cancellation by Bankers hy Mistal;c. — If a banker, at Cancellatlou
whose house a bill is accepted payable, by mistake (not ^ ""*' ^ ^'
under circumstances showing want of due care) cancels the
acceptance and refuses to pay the bill, he does not neces-
sarily render himself liable to the holder, in an action on
the case, or otherwise ; for instance, he will not be liable,
if he has no effects of the acceptor's to meet the bill(o).
Where, on the other hand, he has been guilty of such
(>«) Moore v. Biishell, 27 L. J., Exch. 3; Farley v. Turner, supra;
Hill V. Eoyds, supra. See also Thompson v. Simpson, L. R., 5 Ch.
App. 659 ; Louisiana Bank v. Bank of New Orleans, L. E., 6 H. L. Cas.
352 ; Barned^s Banking Company, In re, Massey, Ex parte, 39 L. J.,
Chanc. 635.
(w) Johnson v. Eolaris, L. R., 10 Ch. App. 505; 44 L. J., Chanc. 678.
(o) NoveUi V. Eossi, 2 B. & Ad. 757; Warwick v. Rogers, 5 M. & G.
340, 352. Though the right to sue on bills is generally destroyed by
cancellation, other rights ai'e not necessarily so affected. See Yglesias v.
Mercantile Plate Bank, 3 C. P. D. 60, 330.
112
ORDERS TO BANKERS.
want of due care, and damage has ensued in consequence
to the holder, an action will lie against him (p).
Refusal to
take.
-Bill payable
in case of
need.
Refusal to take. — The holder of a hill may refuse, as
has already been stated, to take a special or a qualified
acceptance ; on the other hand, an acceptor may refuse to
pay a bill, which, after a general acceptance by him, has
been, without his consent, altered so as to appear to be
payable at a banker's. The ground is, that the contract
is, by the alteration, made a different one from that into
which he entered (§'). But it does not appear that such
an alteration of the bill, as an acceptance by mistake,
c. ^., as in the last paragraph, operates to affect in any
way the liabilities of the other parties to the bill, both
because such is not, it is believed, the usage of merchants,
and because such alteration does not, in fact, vary the con-
tract into which the other parties entered, with respect to
the bill ; for the liability, which they originally undertook,
was to pay the bill, in case the drawee did not, and the
refusal to accept merely ascertains and announces that he
wUl not make himself liable to pay. It is, therefore, sub-
mitted, that such alteration is not a material alteration,
within the meaning of tlie principle as applied to deeds
and contracts, so as to destroy the validity of the instru-
ment in toto (>•).
The holders of a bill, through their agents in London,
presented it at the bank at which it was made payable by
the acceptor ; on its being dishonoured, they further pre-
sented it at the bank at which it had been specially in-
dorsed payable " in case of need " by the indorsers ; there
also it was dishonoured. The agents, on the same day,
sent the bill by post to the holders in Liverpool, who, on
the day following, sent it to the indorsers ; the Court held,
(;;) See Ingham v. Fnim-osc, 28 L. J., C. P. 294; 7 C. B., N. S. 82.
As to cancellation by mistake by other parties not (lestroyinij a bill, see
Jiaperv. Birkbcck, 15 East, 17; Davidson v. Cooper, 1 1 M. & W. 778.
{q) Burch field v. Moore, 23 L. J., Q B. 2G1 ; 3 El. k Bl. 683.
(V) ]\irni V. Nicholson, 13 M. & "W. 780.
ORDERS TO PAY. • 113
that no sufficient notice of dishonour had been given in
the first instance, and that the actual notice was a day too
late (s).
Promissory Notes. — Promissory notes, it should be ob- Promissory
served, are not within the above-mentioned statute 1 & 2 °° ^^'
Greo. IV. c. 78 ; the consequence is, to make it necessary,
in suing on a promissory note made payable in the body
of it at a bank, to aver in the statement of claim present-
ment at the bank (t), and to prove it at the trial, if denied;
and, in this respect, there is no distinction between notes
which are negotiable and those which are not {ii).
Where, however, the place of payment is not mentioned
in the hodij of the note, but merely in a memorandum at
the foot, then it is no part of the contract that the note
should be payable at the bank, or place mentioned, and it
is not necessary to present {.v), or allege presentment (y).
When a promissory note is made payable at a banking
house, it is not necessary to prove that the banker had
notice of its dishonour (~) .
»II. Orders other than mere Orders to pay.
Hitherto we have been considering those orders to pay
commonly coming under a banker's notice, but besides
these there are other orders respecting the funds of a
customer, not strictly orders to pay, and less frequently
to be met ^ith in practice. The first of these are what
(.v) In re Leeds Banh'uig Comjiaiuj, Ex parte Praiuje, L. R., 1 Eq. 1 ; 35
L. J., Chanc. 33.
(0 EmbVui V. DartneU, 12 M. & W. 830; Vanderdoncktv. ThvUttsson, 19
L. J., C. P. 13 ; 8 C. B. 812 ; Sands v. CJarJc, 8 C. B. 751.
(«) Spindler v. Grellett, 1 Exch. 384.
\x) Williams v. Waring, 10 B. & C. 2.
((/) Saunderson v. Judge, 2 H. Bl. 510; Masters v. Baretto, 19 L. J.,
C. P. 50; ^^r Lord Campbell, C. J., in Warrington v. Earh/, 23 L. J.,
Q. B. 48.
{z) Tearse v. reinberthy, 3 Camp. 261 ; Smith v. Thatcher, 4 B. & Aid.
200.
114
OllDERS TO BANKERS.
may be termed orders in tlie nature of an appropriation or
assignment of funds in favour of a third party.
Questions frequently arise as to liow far a banker who
has received an order to appropriate certain funds of his
customer in favour of a third party, which order has been
subsequently countermanded, is justified in nevertheless
making the payment. Before the Judicature Acts, the
rule in law apparently was this : — If the revocation was
made before the banker had assented to the appropriation,
and before that assent had been communicated to the
payee, the banker was bound to act upon it; and if he
made the payment he did it at his risk, and could not
charge his customer therewith {a) ; the reason of this being
that until the assent had been given and communicated to
the payee no property in the funds passed to him, and the
customer's right of control over them still continued (^>).
In equity, the assent of (f), or even the communication to,
the banker was immaterial (r/), so far as the assignee's
right as against the assignor went, for an order given by
a debtor to his creditor upon funds in the hands of a third
party has always been held to be sufficient to constitute
an equitable assignment (). That the assignee should have
had notice of the assignment, however, was absolutely
necessary ; for it has always been a well-established prin-
ciple of equity that a mere order from a creditor to his
debtor to pay a third person, uncommuuicated to sucli
person, passes no interest in the funds so directed to be
paid (/'). It must have appeared, moreover, from the
order that there was an intention to charge the funds in
{a) See Gibson v. Minet, 2 Bing. 7 ; Williams v. Evcritt, 14 East, 582 ;
Morrell v. Wootcn, IG Beav. 197 ; Hodgson v. Anderson, 8 B. & C. 342.
(h) Williams V. Everett, Walker v. Jiostron, 9 M. & "W. 411; Zili/ v.
JTai/s, 5 A. & E. .518; XohlcY. Xational Uiseoioit C'ompa)ni, 5 H. & N.
225; 29 L. J., Ex. 210.
(r) McGoivan v. Smith, 2G L. J., Cli. 8.
[d) Ex parte South, 3 Swanst. 392; RodieJc v. Gandcll, 1 D. M. & G-.
780 ; Diploek v. J[umnwnd, 2 Sm. & G. 141 ; 5 Do U., M. & G. 320.
{(■) lioir V. Dairson, 1 Ves. sen. 331 ; Letts v. Morris, 4 Sim. GOT ; Earn
V. Carralho, 4 M. & C. GOO.
(/) Earqnhar v. Citii of Toronto, 12 Gr. 186.
ORDERS OTHER THAN MERE ORDERS TO PAY. 115
favour of the payee (g). A mere clieque was held not to
be an equitable assignment of a drawer's balance at his
banker's {). Now, by sect. 25, sub-sect. 6, of the Judica-
ture Act, 1873, all debts or other legal choses in action
are now assignable, provided the assignment be an abso-
lute one {/i) (and not by way of charge only), and be in
WTiting under the hand of the assignor and notice thereof
be given to the debtor. The assignee takes subject to all
equities affecting the assignor (/), Assignments of equit-
able choses in action are not affected by this enactment,
except that the assignee may now sue in any court, whereas
before he could only sue in equity (j). Where the section
has not been complied with the assignor cannot be joined
as co-plaintiff without his consent, or without being com-
municated with, and properly indemnified {k) , An order to
pay a sum of money out of a debt is an absolute assign-
ment (/), and must be stamped as an assignment and not
as an order for payment {m) ; not so a cheque (n).
An order by a person depositing money at his bankers,
that it shall be distributed, in named amounts, between
certain persons, does not make the bankers liable to those
persons, or any of them ; they are only responsible, for the
sum deposited, to the depositor ; although they are aware
of the destination of the money (o) . Such an order re-
mains revocable by the party giving it, until the occurrence
of one of two events, — the payment over by the bankers
to the persons for whom the sum was deposited; or the
making of some binding engagement by the bankers ^ith
them, which gives the latter a right of action against the
{(/) HopJcinson v. Foster, L. E.., 19 Eq. 74.
{h) National Provincial Bank v. Harle, 6 Q. B. D. 626 ; West of England
Bank y. Batchelor, W. N. 18S2, p. 11.
(«■) Yotaiff V. KitcMn, L. R., 3 Ex. D. 127 ; 47 L. J., Ex. 579.
[j) See Coote's on Mortg-ages, p. 478.
\k) Turquand v. Fvaron, L. E,., 4 Q. B. D. 280. See In re Wluttimj, 10
Ch. D. 615.
(0 Brice V. Bannister, L. R., 3 Q. B. D. 569 ; Buck v. Rohson, ib. 686.
(«() Buck V. Rohson, supra ; Fisher v. Calvert, 27 W. R. 301.
(«) Schrwderv. Central Bank of London, 34 L. T. 735; 24 W. R. 710.
(o) Finto V. Santos, 5 Taunt. 447.
i2
116 ORDERS TO I5ANKERS.
fomier {p). For instance, had tlie bankers stated to
those persons, that they held the money for them, thus
assenting to the order of their customer, that woidd have
rendered them liable to the persons for whom they held
the money, for their assent could not be retracted (q).
A letter by bankers, stating that a special credit for a
certain sum has been opened by them at the instructions of
their customer, in favour of any particular person who
supplies goods on the faith of it, does not, of itself, con-
stitute a specific appropriation or an equitable assignment
of that sum in their hands, so as to make them liable to
be sued in a Court of Equity as trustees for the person in
whose favour the credit has been opened (>•).
To receive Order to receive Dmdends. — By the Stamp Act, 1870,
s. 103, a letter or power of attorney for the sale, transfer
or acceptance of any of the government or parliamentary
stocks or funds, duly stamped for that purpose is not to
be charged with any further duty by reason of containing
an authority for the receipt of the dividends on the same
stocks or funds («). And by sect. 104, a writing under
hand only containing an order, request or direction from
the owner or proprietor of any stock to any company or
to any officer of any company, or to any banker, to pay the
dividends or interest arising from any such stock to any
person therein named, is not chargeable with duty as a
letter or power of attorney. But although such order,
request or direction is not liable to stamp duty as a letter or
power of attorney, it requires to be stamped as an order
[p) Gibson v. Minet, 2 Bing. 7 ; Williams v. Everett, 14 East, 592 ; Scott
V. I'orcher, 3 Mer. 652 ; Lilli/ v. Ilays, 5 A. & E. 548 ; Briud v. Hamp-
shire, 1 M. & W. 372.
{q) Frilhling v. Schroeder, 2 Bing. N. C. 77 ; Walker v. Eostron, 9 M. &
W. 411, 421.
(/•) Morgan v. Lariviere, L. R,, 7 H. L. 423; 44 L. J., Ch. 457.
(«) In the schedule, a letter or power of attorney or other instrument
in the natiu-o thereof is chargeable as follows : — •
(3.) For the receipt of the dividends or interest of any stock, —
Where made for the receipt of one payment oiily, Is.
In any other case, 5.v.
ORDERS OTHKR THAN MERE ORDERS TO PAY. 117
for money payable on demand under sect. 48 (3) . When
bankers hold a power of attorney from the trustee of a
married woman to receive and pay to her the dividends on
government stock settled to her separate use, it will be
no payment, if they pay the dividends to her creditors or
nominees at her request (?").
Banlier as SfaJceholder. — In considering the position of Banker acting
the parties concerned where money has been paid into a bolder ^"
bank to abide the issue of an event it is necessary to call
attention to the Act 8 & 9 Yict. c. 109, s. 18. By that
act it is enacted that all contracts or agreements, whether
by parol or in writing, by way of gaming or wagering
shall be null and void ; and no suit shall be brought or
maintained, in any court of law or equity, for recovering
any sum of money or valuable thing, alleged to have been
won upon any wager, or which shall have been deposited
in the hands of any person to abide the event on which
any wager shall have been made. And by sect. 18 it is
provided that the preceding enactment shall not apply to a
subscription or agreement to subscribe, or contribute for, or
towards, any plate, prize or sum of money to be awarded
to the winner of any lawful game. The effect of the
words "no suit shall be brought or maintained," &c., is
to prohibit the recovery by the winner from the loser of
money which has been won in such a transaction as that
mentioned in that part of the section, or which has been
deposited by such loser in the hands of a stakeholder to
abide the event ; and the statute does not apply to cases
wherein the party seeks to recover his own stake upon a
repudiation of the wagering contract ; either party being
able to recover the sum he himself has deposited, although
he does not demand it till after the event (ii).
(i) Clerk v. Laurie, 1 H. & N. 452.
(«) Biggie v. Higgs, L. R., 2 Ex. D. 422 ; 2.) W. R. 777. See also
Ifnmpdai v. JFrihs/i, L. E., 1 Q. B. D. 189; 24 AV. E. G07 ; Thac/ar r.
llardg, 4 Q. B. D. G8.5.
118 ORDERS TO BANKERS.
To obtain Order to ohtalii Acceptcuwe. — If a person delivers a bill
accep ance. ^^ exchange to liis bankers to get accepted for him (he
being payee), and acceptance is refused, but they omit
to communicate the circumstance to the depositor, he
has a right of action against them, and may recover da-
mages in proportion to the injury he can show he has
siLstained (f).
To accept _ Order to accept Drafts against Bills of Lading. — A
bills of ° banker, receiving instructions from his customer to accept
lading, yilh, of exchange which a correspondent of his would
draw against bills of lading, is not bound to ascertain
the genuineness of the bills of lading before accepting or
paying the bills of exchange ; and if the banker pays the
bills, although the bills of lading should afterwards turn
out to be forgeries, he will be entitled to recover from his
customer what he may have paid in respect of the bills of
exchange {u).
To transfer to Order to transfer or place to Credit of Another. — We
another. iiext investigate the effect of an order given by a customer
to his bankers, directing them to transfer a sum of money
from his account to the credit of another person, who also
banks with them.
A., is debtor to B. A., with the consent of B., desires
his bankers, who also are the bankers of B., to place to
the credit of B., a sum of money (for goods sold), so
as to make the transaction similar to a bill of exchange
at one month, which the bankers consent to do, but only
consider it as a payment to be made at a future day.
Such a transaction does not amount to a payment ; and
where the bankers became bankrupt before the day on
which the credit would expire, tlio Court held that A. was
not discharged by such inchoate payment (,r) .
(0 Van Wart v. WuoUcij, 3 B. & C. 439.
(«) Woods V. ThitdemaHu, 1 11. & C. 478. Vhhr Bank v. Synnott, 5 Ir.
R., Eq. o9.5, is to the same cifect.
(.'•) Pcddvr V. Watts, 2 Chit. GIO.
ORDERS OTHER THAN MERE ORDERS TO PAY. 11j>, 15 M. & W. 37 ; Cavanagli on Money Securities,
p. 40. See also Moore V. Ulster Banking Conipan;/, 11 Ir. R., C. L. 512.
(p) Miller y. Austen, 13 Howard, U."S. Kop. 218.
(q) Jfewitt V. Ji'ai/c, L. R., G Eq. 198. Sec also In re Mead, 15 Cli. D.
G51.
(r) Pott V. Clo,,/, IG M. .V W. nil.
FORGING. 131
Forging. — Altering the sum, for whicli an accountable Forgiug.
receipt is given, is an altering in a material part, and in-
dictable as a forgery (s).
By 24 & 25 Yict. c. 98, s. 23, it is felony to forge an
accountable receipt, whether for money or for goods, or for
any note, bill, or other security for the payment of money,
or any indorsement on, or assignment of, any such ac-
countable receipt ; and so is the altering, or offering, utter-
ing, disposing of, or putting off, knowing the same to be
forged or altered, any such accountable receipt, with in-
tent to defraud. The punishment for these offences is
either penal servitude for life, or for a term of five years
(27 & 28 Yict. c. 47), or imprisonment for a period not
exceeding two years, with or without hard labour, and
with or without solitary confinement.
Where it was the practice of a bank to treat a receipt,
with the depositor's name thereon, as an order for the
payment of the money deposited and interest upon the
receipt being presented to the bank ; and a person took
the receipt to the bank, and, having written the depositor's
name thereon, delivered it to the bankers, who paid him
the principal and interest due thereon : it was held, that he
was properly convicted, as for a forgery of an order for the
payment of money (/) .
A person producing a forged receipt, purporting to be a
receipt for poor rates due from A., for the purpose of in-
ducing the prosecutor to send money to A. as a respon-
sible person, is within the above statute, for it is not neces-
sary that money should be obtained directly upon it, or by
the utterer at all {u).
A writing, purporting to authorize the bearer to receive
money deposited in a bank by a friendly society on ac-
countable receipts, and purporting to be signed by the
principal officers of the society, may be alleged, in an
(.s) Reg. V. Johnston, 5 Cox, C. C. 133.
[t\ Rcq. V. Atkinson, Car. & M. 325.
00 Heff. V. Ion, 2 Den. C. C. 475 ; 21 L. J., M. C. 166.
k2
132 ACCOUNTABLE OR DEPOSIT RECEIPTS.
indictment for forgery, to be a warrant for the payment of
money {x).
Obtaiuing by Obtaining hy False Pretences. — By 24 & 25 Vict. c. 96,
tences*^^" ^- ^^' ^^ ^^ indictable to procure, by any false pretence,
an accountable receipt to be delivered to another person
for the use or benefit of the person making the false pre-
tence {y).
{x) Reg. V. Roberts, 2 Mood. C. C. 258.
(y) See Reg. v. Garrett, 23 L. J., M. C. 20.
( 133 )
CHAPTER XYIII.
THE RELATION OF BANKER AND CORRESPONDENT.
It frequently happens in questions of banking law that
the incidence of a loss has to he determined as between
two parties, who are both equally innocent of fraud, or
crime, in the transaction. More especially is this the case
in questions arising on dealings of a customer with his
bankers, who are obliged, in order to complete the in-
tended transaction, to employ the agency of theii* cor-
respondents — other banking houses carrying on business
at a distance.
Thus, if a customer employs his bankers to perform
some duty for him, which can only be brought to a con-
clusion in some place at a distance, whether in this country
or in foreign parts, so that it becomes necessary for them
to employ the agency of persons acting there, and a loss
ensues from the conduct of such agents, whether direct or
intermediate, and the question arises whether the customer
or the bankers are to bear that loss, in all such cases it is
the bankers who must suffer ; for, of the two, they are
the parties whose conduct has led to the loss ; it was they
who chose the agents, or who chose the correspondents
who selected the actual agents; it is their act, therefore,
which has led to the occurrences which have caused the loss,
and for that loss, as between themselves and the customer,
they must be liable ; in other words, the customer has a
right of action against them, and vdW, in a Comi of law,
be compensated for the injury he has sustained. The
bankers, however, will have a right of recourse against
their correspondents, by whose laches or default, either
134 THE RELATION OF BANKER AND CORRESPONDENT.
primarily or througli the default of any one whom the
latter may have entrusted with the business, the bankers
have incurred the loss.
The following case well illustrates this position : —
A customer of a bank sent orders to his bankers to
obtain for him payment of a bill of exchange, drawn by
him on a person in Calcutta ; the bankers accepted the
employment, and wrote to him word that they had done
so, promising to credit him with the amount of the bill
when received. In the usual course they transmitted the
bill to their correspondents in London, by whom it was
forwarded to the house of A., in Calcutta, to get payment ;
it Avas paid into A.'s, immediately after which they failed.
The customer having been advised, by his bankers, that
the bill was paid, they were held to be his agents to obtain
payment, and it was also decided that, ipso facto, upon
payment being made, they became liable to him for the
amount received; and that any loss which might arise
from the conduct of the bankers' sub-agents, between
whom and himself no privity was established, must fall
on the bankers [a) . And the case was said not to be dis-
tinguishable from the case of a customer of a bank in
London sending them a bill or a cheque, with orders to
get payment, and their clearing-house clerk, instead of
returning with the balance, absconds ; in which case the
bankers would clearly be liable to the customer for the
amount of the bill [h).
Also, the state of the accounts, between the customer's
bankers and any of the correspondents they may employ
in the transaction, can make no difference.
Hence, in all cases where a customer desires his bankers
to obtain payment of a bill for him, and they do not refuse,
or if a stranger makes the same request, and they agree to
perform it, they are liable for the amount of the bill,
(«) Mackersy v. Ramsaij, 9 C. & F. 818.
(A) Per Lord Lyndhnrst, C, id. 818.
THE RELATION OF BAMvER AND CORRESPONDENT. 135
wliether, after remitting it to their correspondents, to
get the payment, its amount is returned to them or not,
provided, in the latter case, the cause is the default of their
correspondents.
Some country bankers pay the London banker, who
acts as their agent and correspondent, a fixed annual sum
for conducting their agency business. Others allow a
commission on the amount of the transactions during the
year. There are many country bankers who pay no com-
mission, but leave a sum of money in the hands of their
London agents, in the nature of a deposit, against which
they are not permitted to draw. In such cases this sum
is altogether withdrawn from the general account of the
country banker, and placed to another, called the deposit
account.
A question arising upon a remittance through a bank
may be mentioned here, as one of great practical import-
ance ; viz., if a customer of a country bank, who already
has a balance in his favour on his account with them, pays
in a further sum of 7071., with directions in writing that
500/. of it was to be paid into Messrs. Eobarts' bank in
London to meet a bill of exchange accepted by him, and
the 707/. is carried by the country bank to his general
account with them, and the 500/. is paid into E-obarts',
but, before the bill becomes due, the country bank stops
payment ; whether such 500/. is available for the general
creditors of the country bank or is so speciJicaJl// cq^j^rO'
priated to be apjolied in a particulav way as to remain the
property of the customer at the time of the closing of the
country bank ; and, under the above circumstances, the
latter has been held to be the case (c).
But, on the other hand, where there is no specific appro-
priation it is otherwise : so where M. paid a sum of money
into a country bankers', with written directions to apply it
to meet a bill payable the next day at their London agents,
(c) Farley v. Turner, 26 L. J., Chanc. 710. See also BarkworlJi y.
merman, 6 H. & N. 605.
THE RELATION OF BANKER AND CORRESPONDENT.
and the country bankers stopped payment the next day
without having advised their London agents of the pay-
ment, and the hill, on being presented, was dishonoured, as
the country bankers had made no specific ap2))'02)nafion of the
sum, he was only entitled to prove as a general creditor on
their estate (d).
Privity. — As between a banker and the customer of his
correspondent there is no privity ; consequently where one
sent to a banker from his correspondent, the former takes
them subject to the instructions of the correspondent and
not of the correspondent's customer ; so where a customer
of a country bankers paid in to the bankers a sum of
money in bank notes and also some bills of exchange to be
remitted to London in order to meet certain acceptances,
and the bankers sent to their London agents the bills and
some bank notes, with a letter directing them to pay a
certain sum of money, also giving them notice of the
acceptances as payable at their bank, and giving directions
as to other business, and the country bankers stopped pay-
ment, owing a large balance to the London bankers : it
was held that, as between the country customers and the
London bankers there was no appropriation of the bills
and notes to meet the acceptances, and that the London
bankers could retain the bills and notes without meeting
the acceptances {e) .
Where an acceptor of a bill paid money to his bankers
(at whose correspondents' house it was payable), for the
purpose of taking it and other bills up, and they promised
him to apply it to such purposes, and also entered the
particular bill to their credit in their books, but they had
{(l) In re BarneiVs Banking Cumpanij, Ex parte Mas^eij, 39 L. J., Chauc.
635. See also ThoippHon v. Simpson, L. K., 5 Ch. App. C59 ; Citizens
Jiank of Luxisiana v. Bank of New Orleans, L. II., 6 H. L. Cas. 3")2 ; Ex
parte Ifaring, 3G L. J., Chanc. 151 ; 19 Ves. 349 ; Ex parte Smart, L. R.,
8 Ch. 220 ; 42 L. J., Bank. 22; Ex parte Dcwhurst, L. R., 8 Ch. 965;
42 L. J., Bank. 47.
{e) Johnson v. lioharts, L. R., 10 Ch. App. 505 ; 44 L. J., Ch. 078 ; 23
W. R. 703.
THE RELATION OF BANKER AND CORRESPONDENT. 137
not advised their correspondents to pay it : the Court
held, that the drawer of the bill, who was also the holder
of the bill, could not sue the bankers for the amount of the
bill, as there was no privity between the drawer and the
bankers to sustain the action (/).
The object of the transmission of a bill for presentation
for acceptance and payment by a principal to his agent
being to obtain the acceptance and the payment of the bill,
or, if it is not accepted, to guard the rights of the principal
against the drawer, in case recourse is to be had to the
drawer, the duty of the agent must be measured by these
considerations, and the duty of the agent is to obtain
acceptance of the bill, if possible, but not to press unduly
for acceptance, provided he obtains acceptance or a refusal
^vithin the time, which will preserve the rights of the
principal against the drawer {[/) .
We may conclude by mentioning the following decision,
which is one of practical utility : — A bill of exchange was
sent by a bank in the United States to a bank in Toronto,
Canada, for collection and remittance, accompanying which
was a bill of lading for 10,000 bushels of wheat, which, on
the bill of exchange being accepted by the drawees, was
delivered over to them, they being the consignees named
in the bill of lading : it was held, that it was not the duty
of the bank in Canada, as the agent of the American
bank, in the absence of special instructions, to retain the
bill of lading until the bill of exchange was paid (h) .
(/) Moore v. Bushell, 27 L. J., Ex. 3.
{g) Bank of Van Diemoi's Land v. Bank of Victoria, L. E., 3 P. C. 526;
40 L. J., P. C. 28.
(A) Wisconsin Marine Company Bank v. Bank of British Xorth America,
10 Upper Canada, Law Journal, 151 ; it is the decision of the highest
Court of Appeal in that colony.
( i38 )
CHAPTER XIX.
DEPOSIT OF SECURITIES FOR SPECIAL PURPOSES.
We will next trace the rules of law which regulate the
obligations and rights of bankers, with respect to bills of
exchange and other securities deposited with them by their
customers and others. Questions of this nature commonly
arise between the customer, or other depositor, on the one
hand, and the trustee of the bankers, upon their bank-
ruptcy, on the other. The deposit of securities for safe
custody will be considered in the next chapter.
Special Purposes. — The primary or general rule is,
that when a banker is employed as an agent, with whom
undue bills are deposited by the customer, in order that
the banker may receive the proceeds, when the bills be-
come due, or for any other specific piu-pose (a), and the
banker becomes bankrupt, having the bills entrusted to
him remaining in specie in his hands, they continue the
property of the customer, and do not pass to the trustee,
and he may reclaim them in specie from the trustee.
But, on the other hand, if bills of exchange are remitted
to the banker on the general account between him and the
customer, and are not distinguished from the cash items of
the account, they cannot be reclaimed by the customer
from the trustee. In other words, if the relation of the
customer and the banker was that of principal and agent
with respect to the bills at the time of the latter's bank-
ruptcy, the customer may recover in trover from the
trustee ; if the relation had passed into that of debtor and
creditor at the time of the bankruptcy, then the customer
(«) B'-lchery. Campbell, 8 Q. B. 11.
BILLS OF EXCHANGE.
139
has no sucli riglit of action against the trustee {h), although
the customer might, of course, have sued the banker for
the amount of the bills, as soon as they were entered as
cash to the customer's credit, and the books of the banker
would have been evidence against him on this point.
This general rule, that bills deposited or remitted for
the pui'pose of the banker's receiving the proceeds when
due continue the property of the customer, if, at the time
of the bankruptcy, they remain in specie in the hands of
the banker, will be applied in all cases where there is no
bargain between the customer and the banker, that, as
soon as the bills reached the banker, the property in them
should be changed ; and such bargain cannot be inferred
from circumstances which fail to show any consideration
for the customer's assent, as it would be unreasonable in
the banker to ask, and imprudent in the customer to
accede to, such terms, in the absence of a consideration.
In one case (which has been fully confirmed) the course
of dealing between the customer and the bank, and the
usage of the banking trade throughout the county (of Lan-
caster), was shown to be in accordance with the following
facts : —
The account was kept in this form in the pass-book or
banking book.
A. B. (the customer), in account with C. D. (the banker).
Dr.
1821.
July 4.— To Bank..
„ 5.— To Draft
£ s. d.
80
100
Cr.
1821. £ s. d.
July 1.— By Balance.. 1,300
,, 2.— By Bills .... 750
At the end of every half-year an account was sent in to
the customer from the banker. In the account of Christ-
{b) Hx parte OitrseU, Amhler, 237; Ex parte Sarjeant, 1 Rose, 153, -which
are applications of the above rule of law to the several facts of those
cases. The general i-ule is established by Scott v. Stirman, Willcs, 400 ;
Bolton V. FtoUer, 1 B. & P. 539 ; Thompson v. Giks, 2 B. & C. 422 ; con-
finned in Ex parte Aikh/s, 3 M., D. & De G. 103 ; and in Ex parte Barl-
u-orth, In re Harrison, 2 De G. & J. 194 ; 27 L. J., Bank. 5.
DEPOSIT OF SECURITIES FOR SPECIAL PURPOSES.
mas, 1821, and also in the pass-book, a bill for 689/. 19s.
was included, being one of several bills paid in on tbe
10th of December, 1821, and it formed part of the cash
balance of 911/. 2s. 5d. therein stated to be due to the
customer. When the customers paid bills into the bank
the usage was, that (provided the banker approved of
the bills) they were never written short (c), but entered on
the day they u-ere paid in, both in the pass-book and in
the books of the bank, to the credit of the customer, in
the form above stated ; and after such entry, the customer
was at liberty to draw to the full amount appearing to his
credit, by cheques on the bank. Bills disapproved of
were not so entered, but were sometimes returned, some-
times deposited till due. A/l bilk so entered, whether
made speeialty jxtyable to the customer or not, icere indorsed
by him, or if, for any private reasons, he did not wish his
name to appear on the bills, a letter was given to the bank,
acknowledging himself to be equally liable as if he had
indorsed. An interest account was kept not in the pass-
book, but in the books of the bank, in wJiich the customer
was debited with intere^, on each cash payment to him,
from the date of the payment ; and on each j)ayment in
bills, from the period when the bills were due and paid ;
and, on the other hand, he had credit for interest from the
date of each cash payment by him, and from the period
when each bill paid in by him became due and was paid.
As the accounts were balanced half-yearly, if a bill was
paid in which did not become due before the end of the
half-year, the customer was debited with the interest up to
the time when the bill was due. The balance only of the
interest was entered in the pass-book, and this was the
usual mode of keeping an interest account. If only the
undue bills paid in by the customer wore taken out of his
account, in this case, as made up to the 31st of December,
1821, the customer's account would, at that date, appear
(r) For definition of " short" bills, aec post, p. lio.
BILLS OF EXCHANGE. 141
to be overdrawn ; but some of the payments by the banker
to the customer were made in bills payable at future times,
and some of them were also undue on 31st of December,
1821, and if all the undue bills on both sides had been
taken out of the account, the customer would have been
creditor on that account.
At the period of the bankruptcy, the cash balance was
in favour of the customer, exclusive of the bills in ques-
tion. It was proved to be the constant usage and course
of dealing of this bank and of others in the county of
Lancaster, to use bills so paid in, by paying them away to
their customers as they thought fit.
No direct proof was given that the customer was ac-
quainted with this practice, and the customer never re-
ceived anything from the banker but cash, notes and bills,
drawn by the banker upon his London agents {d).
On these facts and the usage above stated it was con-
tended, that a bargain or a contract between the customer
and banker was to be inferred, to the effect that bills so
deposited by the former were to become the property of
the banker, upon reaching his hands. But the Court con-
sidered that, though it appeared to be the practice to carry
the amount of the bills to the cash column of the accoimt,
the bills were entered, not as cash, but as bills (e) ; and
that, although the amount was so carried to the cash
column, it did not follow that the customer assented to
their being considered as cash. That merely amounted to
an undertaking on the part of the bank to answer cheques
in advance, to the amount of the bills so entered. By in-
dorsing the bnis paid in, or by giving a guarantie when he
did not choose to indorse, the customer might enable the
(d) Thompso)i v. Giles, 2 B. & C. 422. The usage of bankers was again
stated to prevail in Lancashire to the above effect in Ex parte Armistead,
In re Bihcorth S; Co., 2 Glyn & J. 379.
{e) Ibid, at pp. 431, 432. Even if they had been entered as cash, that
would have admitted of explanation; Giles v. Perhins, 9 East, 12 ; and
the customer, even in that case, might be shown to be entitled to the
bills. Ex parte Sarjeant, 1 Rose, 153, and per Bayley, J., 2 B. & C. 430.
DEPOSIT OF SECURITIES FOR SPECIAL PURPOSES.
"banker to negotiate the bills, and, in such case, a bond fide
holder might have a right to retain them. But the banker
could only be justified in negotiating them, when that was
rendered a reasonable course, by the state of the customer's
account. The custom or usage of bankers in Lancashire
was stated to be, it will be observed, to use bills paid in by
their customers ; but it was not stated to be the usage that
the bankers should so use the bills as their own, icithout
reference to the condition of the customer's account.
On the whole of the case it was concluded, that there
was no foundation for supposing a bargain to have been
made, enabling the banker to use, as his own, bills de-
posited with him ; and the customer recovered the bills
from the assignees.
The decision, it will be observed, is in accordance with
the general position that if a customer puts bills into his
banker's hands, although that gives him a right to expect
that his cheques will be honoured to the amount of the
bills paid in, still they remain his property, subject to
any lien the banker may have on them, to the extent of
his advances (./').
This decision received judicial recognition in a compara-
tively recent case in bankruptcy, as being in entire con-
formity with reason, good sense, and common honesty [g).
There undue bills of exchange were from time to time
remitted to his bankers by a customer and indorsed to the
bankers. The course of dealing was, that the bills were
not entered short, but though the bills were distinguished
in the customer's account as bills, the full amounts were
entered in the cash column under the dates on which the
bills were paid into the bank, and the customer was at all
times at liberty to draw cheques to the extent of the balance
in his favour, as appearing on the account thus made out.
Interest was allowed by the bankers upon the bills only
(/) Thompson v. G'dcs^ supra, per Holrnyd, J., at pp. -131, 433.
\g) Ex parte Barlcworth, In re Harrison, 27 L. J., Bank. 5 ; 2 De G. &
J. 194.
BILLS OF EXCHANGE. 143
from the time wlien their amounts were received ; and it
was held, in the absence of evidence of the customer's
acquiescing in or authorizing the bankers to treat the bills
as their own from the times of their being paid in, that the
bills remained the property of the customer, subject, how-
ever, to the lien of the bankers for their cash balance, and
that the bankers had no right to negotiate them, unless
the balance of the customer's account was in their favour ;
and that on the bankruptcy of the bankers, such of these
bills as remained in their hands in specie did not pass to
their assignees, but, subject to the lien above mentioned,
belonged to the customer. " The facts," said Knight
Bruce, L. J., in delivering his judgment, " are not nume-
rous. A firm of bankers has become bankrupt, and at
the time of their bankruptcy they had in their possession
short bills deposited with, or otherwise furnished to, them
by one of their customers. The customer then said to the
bankrupts : * I am ready to pay you the balance against
me on my account, upon its being ascertained, and I will
relieve you from all liability in respect of your transactions
with me or with my firm ; but return to us the short bills
belonging to us which you hold.' To this the bank-
rupts, or rather their assignees, replied, ' No ; the bills
now belong to us, and we have a right to retain them
as part of the assets, and you must come in as a cre-
ditor for the amount.' To me," said the learned judge,
" it appears that this proposition is as startling as a
demand by a bankrupt to retain the plate or the title
deeds which a customer has deposited with him for safe
custody" {h).
Bills under such circumstances are not in the order and
disposition of tlie banker, within the Bankruptcy Laws ;
for a banker, in his relation to his customer, is a factor for
bills, within the meaning of the exception of factor in
{h) 27 L. J., Bank. 6.
144 DEPOSIT OF SECURITIES FOR SPECIAL PURPOSES.
those laws (/) ; and it is well known that bankers receive
bills as factors, or agents, to get payment of them when
due.
Entering Bills as Cash. — The entry as cash in the banker's
books of such bills would not, of itself, change the pro-
perty (/i) ; for a banker's books cannot be evidence for him,
though they may be against him ; and the assent of the
customer to the bills being considered as cash, must be
proved in such case ; the onus of proving it being on the
banker (/) ; also, it is hard to suppose that, by entering the
full amount in the cash column of the account, the banker
intended to debit himself presently with the whole sum to
be received in future on the bills. In order to change the
property, it must be shown that the banker bought the
bills, or what is in general the same thing, discounted
them ; then the customer might have immediately sued the
banker for the price which the banker had agreed to give
for the bills, but still retained in his hands ; and if the
customer did not indorse the bills, and they were afterwards
dishonoured, the banker would have no remedy against
him (m).
In the pass-book in the case before mentioned (>i), it will
be observed, the bills were entered at the full amount,
which does not tend to show that they were discounted ;
nor do the entries in the interest account tend that way.
If it had been intended that the bills should become the
property of the banker, they would have been entered as
cash, deducting the discount.
Bills not due. Property in Bills not due. — It will be observed to fol-
low as a consequence of the rule above stated, that when
(i) 2 B. & C. 431, 433 ; per Lord Eldon, C, 1 Rose, 239, 253 ; £ri/son
V. Tl'ijlic, per BuUcr, J., 1 B. & V. 82, n.
(k) Giles V. FerkiuH, 9 East, 12; Jl/iff/us v. Spooner, cited in 2 B. & C.
425, and confirmed, per Holroyd, J., id. 431.
(/) Ex parte Sarjeant, 1 Rose, 153.
(wi) Per Holroyd, J., 2 B. & C. 431, 433.
{h) 'lliompson v. Giles, ante, pp. 139 et seq.
SHORT BILLS.
145
the property in bills not due, paid into a banker's, remains
in the customer, if by any accident they are destroyed
without the default of the banker, the loss does not fall
upon him, but upon the customer (n) .
The rule itself prevails equally where the bills are de-
posited for any other specijQc purpose, as well as that of
receiving the amount when due (o) .
As has been stated, however, bills ma// be jmid in under
circumstances furnishing evidence of a transfer of the pro-
perty in them from the customer to the banker; that is
a question of fact, to be determined by a jury upon the
whole of the circumstances in evidence {)i).
Short Bills. — The terms " short bills," and " entering Short biUs.
bills short," are very frequently met with in cases relating
to the law of bankers, being technical expressions, used
amongst persons engaged in banking : it is desirable,
therefore, before proceeding further, to state the meaning
that is attached to the words.
When, upon the receipt from a customer of an undue
bill the banker does not carry the amount directly to the
former's credit, as for a payment of so much cash into his
account, but notes down the receipt of the bill in the cus-
tomer's account, with its amount, and the time when due,
in a previous column of the same page, he (the banker) is
said to " enter those bills short" (/;). And the bills, when
BO entered, are commonly said to be "short bills" {q).
Though, whether they will be considered so by the Courts,
does not depend upon the particular mode in which they
are entered, but upon the dealings between the parties,
and the circumstances. Such bills, in the absence of
special agreement between the parties to the contraiy, or
(«) Fer Best, J., 2 B. & C. 433. A similar opinion was given by the
Judicial Committee of the Privy Council, in Youuff v. Batik of Bengal,
1 Deac. 681.
(o) Belcher v. Campbell, 8 Q. B. 11.
{p) Giles V. Perkins, 9 East, 12.
\q) Ex parte Pease, 1 Rose, 232, per Lorii Eldon, C.
G. L
DEPOSIT OF SECURITIES FOR SPECIAL PURPOSES.
modes of dealing from which such agreement may he
inferred, are considered in the nature of a deposit ; the
property in them is not changed ; on the bankruptcy of
the banker, with them in his hands, they may be recovered.
Crediting the customer with their amount as cash, is not
sufficient to change the property (r).
In other cases, it has appeared to be the usage of some
country banking houses to enter undue bills that are de-
posited to the credit of the customer, giving him either
cash for them, or liberty to draw for the amount upon the
bank, the customer always indorsing the bills. The prac-
tice of London bankers is to enter as above stated. The
difference between the effect of the two modes is this : the
London banker, if the customer's account is overdrawn,
has a lien on the bill deposited with him, though not in-
dorsed. The country banker, who, under this practice,
always takes the bill indorsed, has not only a lien upon it,
if the customer's account is overdrawn, but has also his
legal remedy upon the bill by the indorsement. It is to
be observed, however, that under neither system does any
lien accrue to the banker, until the customer's account be
overdrawn. Moreover, if, at the time of the country
banker's bankruptcy, the customer's balance is in his
favour, he has a right to recover, in specie, all such bills
of his, as are in the banker's hands {t), or have been
pledged by the banker with a third person with notice {n).
Whether a bill is to be considered as intended to be dis-
counted or deposited, does not depend on whether it is in-
dorsed, but on the question whether it was the intention to
make an absolute transfer, giving full power to go against
all parties to the bill, or merely to enable the person with
(r) J'Jx parte Dumas, 1 Atk. 233 ; 2 Ves. sen. 582 ; Zinek v. Walker, 2
W. Bl. 1150; Ex parte Atkins, 3 M., D. & Do G. 103; Jombart v.
Woollett, 2 M. & C. 402 ; Ex parte Barkivorth, In re Harrison, 2 De G. &
J. 194; 27 L. J., Bank. 5.
(t) Giles V. Perkins, 9 East, 12, 14. The presumption has heen said to
be tliat bills deposited with a banker are short bills. Ex parte Armitsteacl,
2 Glpi& J. 371.
{>() Collins V. Martin, I B. & P. C48.
SHORT BILLS.
whom it Is deposited to receive tlie amount from the other
parties. Indorsement, however, is lirimd fade evidence
of the former {x) .
The clearly settled rule is, that, if indorsed bills are
deposited with a banker, and they are by him negotiated,
and the banker afterwards becomes bankrupt, the original
owner, who deposited them with the banker, who fails, can
have no claim to recover them against the person holding
them, provided such person had no notice of the deposit (y) ;
and he can only come in as a general creditor of the
banker under his bankruptcy (s) .
Lord Eldon more than once observed, when sitting in
bankruptcy, that it ought to be generally known, that if
bills indorsed are remitted to bankers, they may dispose of
them effectually, though contrary to the faith of the under-
standing between the parties, and the remitters can only
come in as general creditors on the bankruptcy {a).
Permission to discount, given by the customer, for the
pm'pose of reducing the balance, when the banker shall be
in advance, is a cu'cumstance controlling his absolute autho-
rity over the indorsed bills of his customer {h) .
It is to be remembered also, that as, on the one hand,
writing bills short is only evidence (e) to be rebutted by
proof of the intentions of, or actual bargains or contracts
between , the customer and banker ; so, on the other hand,
the circumstance of the bills not having been written short
amounts to nothing, to show they were taken as cash,
" unless there be a concun-ence manifested at the time, or
to be infen-ed from the habits of dealing between the par-
ties, that they were to be considered as cash" {d). Hence,
in a case where such bills were entered, bills and cash
{x) Ex parte Toicgood, 19 Vea. 229.
(y) lioUoH V. Fuller, 1 B. & P. 646 ; ColUns v. Martin, 1 B. & P. 648.
(z) Ex-imrte Tease, 1 Rose, 238 ; Ex parte Wakefield Bank, 1 Eose, 246.
(«) Ibid.
{b) Ex xjarte Leeds Bank, 1 Rose, 254.
(c) Ex parte Pease, 1 Rose, 239 ; 19 Ves. 25.
{d) P.
(/) Ex parte Pease, 1 Rose, 239.
{g) Ex parte Armitstead, 2 Glyu & J. 371, 37^.
DOCTRINE OF EX PARTE WARING. 149
account with the bank in 1822 considered as cash, with-
out objection on his pai-t, that did not amount to a permis-
sion to discount or negotiate (//).
In a second case arising on the bankruptcy of the same
firm of Dil worth & Co., of Lancaster, it was ruled, that a
customer was not entitled to recover short bills in the
hands of his bankers on their bankruptcy, where the habit
of dealing between the parties was such as to warrant an
inference that they mutually considered and treated such
bills as cash. The bills in question were indorsed by the
customer generally, and paid into the bank, and indorsed
by the bankers to their London correspondents. These
bills were drawn previously to, but were not due until
after, the bankruptcy (/) .
Doctrine of Ex parte Waring. — Where undue bills are
held by a banker as security against his acceptances for a
customer, such bills will, on the bankruptcy of the former,
be ordered to be given up to the customer upon his under-
taking to indemnify the bankrupt estate against any
liability that may arise upon the acceptances (7 ) . If the
customer also becomes bankrupt the holders of the accept-
ances have a right to have the bills deposited with the
banker appropriated to meet the acceptances (/i). This
rule only applies where the estates are being judicially
administered (/). Nor does it apply to any case in which
the holders of the acceptances have not a right of double
proof («i), that is to say, against the estate both of the
drawer and the acceptor.
(7j) Ex parte Armitstead, 2 Glyn & J. 371, 379.
(i) Ex parte Thompson, In re LUworth, 1 Mont. & M'A. 102. See also
Ex parte Benson, In re Dilworth, 1 Deac. & C. 438.
{J) Ex parte Burton Bank, 2 Rose, 162.
(k) Ex parte Warincj, 19 Ves. 344. See also City Bank v. luclcie, L. R.,
5 Ch. 773 ; Ex parte Lambton, L. R., 10 Ch. App. 405 ; Ex parte Banner,
L. R., 2 Ch. D. 278 ; 45 L. J., Bank. 73 ; In re Keic Zealand Bank, L. R.,
4 Eq. 226; Ex parte Eewhurst, L. R., 8 Ch. App. 965 ; 42 L. J., Bank.
87 ; In re Earned Banking Company, L. R., 10 Ch. 198. ^
(}) Ex parte Gomez, L. R., 10 Ch. App. 639 ; Ex parte General South
American Company, L. R., 10 Ch. 625.
{m) Tavghan v. mdliday, L. R., 9 Ch. App. 561.
150 DEPOSIT OF SECURITIES FOR SPECIAL PURPOSES.
Criminal Liability of JBanker. — A banker, wlio in vio-
lation of good faith and without authority takes upon
himself to negotiate, transfer, or pledge any valuable secu-
rity entrusted to him for safe custody, or who in any
manner converts such security to his own use, is now liable
to be indicted for a misdemeanor imder the 24 & 25 Vict.
c. 96, s. 76.
Bills remitted J^iUs remitted for Sale. — Whenever bills of exchange
lOr S3>l6 *
are remitted for sale, and the proceeds are directed to be
applied to a specific pui-pose, the property in the bills
remains in the remitter, until the purpose for which they
were remitted is satisfied ; and, moreover, the value of the
bills may be recovered from the purchaser of the bills who
had notice of the purpose for which they were remitted,
and of the misapplication of the proceeds by the agent.
The bills, in the case in which this doctrine was recognized,
were not indorsed (m) .
A sale of bills of exchange by a factor is precisely the
same in principle, and must be dependent on the same
rules of law, as a sale of a biU by a banker ; it may, there-
fore, here be cited in illustration of the foregoing state-
ments, and as elucidating this part of the law of banking.
A foreign merchant remitted biUs to his factor in London,
with directions to sell them, advising him, at the same
time, of his intention to draw for the proceeds. The factor
received the biUs and sold them, but before the receipt of
the purchase-money became bankrupt and dishonoured the
merchant's drafts for the amount of the bills. The sale in
London of foreign bills of exchange usually (the report
states) takes place on foreign post-days, and it is the custom
of merchants not to pay the piu'chase-money until the
foreign post-day next after the day of sale. In this case
the bills were remitted on the 21st of March, on the 28th
they were sold, and the price, according to the custom,
(;«) MuUylull Seal v. Lent, 8 Moore, V. C. 319.
BANK POST BILLS. 151
would have been payable on the 31st : on the 30th, the
factor stopped payment ; and on the 20th of April follow-
ing a fiat issued. Here the merchant, and not the assignees
of the factor, were held to be entitled to the proceeds of
these bills, notwithstanding the bills had been indorsed
both by the principal and the factor, and were sold by the
factor in his own name. The factor did not receive a
del credere commission, nor did he take upon himself any
liabiHty, in case of non-payment of the purchase-money,
in respect of such bills, but was accustomed on such sales
to -inform the principal of the names of the purchasers (n) .
Bills in the hands of a banker are, in the event of On bank-
bankruptcy, to be delivered up, subject only to the lieu banked °
which the banker may have upon them for the balance of
his account. If indorsed bills are deposited with a banker,
and are by him negotiated to a third person, though the
purpose for which they were deposited should be ever so
cruelly disappointed by his becoming bankrupt, the original
owner can have no claim to recover them in trover against
such third person, provided he had no notice of such
purpose (o).
Bank Post Bills. — Bank post bills are instruments used Bank post
by bankers for remitting money abroad or to the country. ^ '
They are payable to order and at a certain number of
days after sight. When indorsed by the payee, they
become payable to bearer.
If a person goes to his banker, and says, here are
1,000/., in Bank of England notes, get me a bank post
bill for them ; the banker cannot receive them silently,
as though acquiescing in the object of the customer, and
then set up his lien and apply them in reduction of the
balance, against the customer, on his account (p).
(m) Ex parte FauU, 3 Deac. 169. The judgment was rested on Scott v.
■Surman, Willes, 400.
(o) BoUon V. Puller, 1 B. & P. 539, and see ante, pp. 146-7.
\p) See observations by Lord Lyadhurst, C, and Lord Brougham, iu
Brandao v. Barnett, 12 0. & F. 802.
152 DEPOSIT OF SECURITIES FOR SPECIAL PURPOSES.
Then, sucli expressions, used in the letters of remitters
of bills or otherwise, as, that they expected the banker "to
do the needful " [q), or " to cover us in due time " {r), do
not enlarge the powers of the banker, or constitute a
special contract, authorizing him to deal with the bills as
his own, or relieve him from the obligation of retaining
the bills till due, if remitted to receive payment of them.
A bank post bill had been remitted, by a customer
to his bankers, with a letter desiring them to place it to
his credit, and to send him a receipt, and credit had been
given him, in his account, for the amount of the bill, and
a receipt given him in the same way as if it had been
a cash payment ; the bank post bill, as is mostly the case
for the sake of security, when bills are sent into the
country, was unaccepted. Now, in such a case, if the
customer had drawn a cheque upon the bankers for a sum
exceeding liis balance, supposing the bank post bill, for
which he had credit in the banker's books, were not
reckoned, and the bankers had refused to honour the
cheque in respect of that deficiency, it seems probable
that an action, such as it had been already shown a cus-
tomer, who has an undoubted balance in his favour, may
maintain in general on refusal to pay his cheque, could
not have been supported ; for the bankers might have
answered truly, that an unaccepted bill, though of the
Bank of England, payable seven days after sight, is, for
many purposes, not equivalent to cash ; and, in fact, their
duty had been performed by transmitting the paper to
London for acceptance, and raising the money upon it
within a reasonable time. It was apparently, though
with hesitation, concluded, therefore, that the bank post
bill had never become vested, as property, in the bankers ;
in other words, it was never in the character of cash
between these parties; the ordinary relation of banker
and customer remaining between them not regulated or
qualified by any particular agreement, express, or to be
(y) Ex parte Smith, Buck. 35o.
(r) Jomhart v. WooUdt, 2 M. & C. 380.
WITH COUNTRY CORRESrOXDEXTS OF BAXKERS. 153
inferred from circumstances or habits of dealing. The
customer, therefore, was entitled to the proceeds as against
the assignees (s).
Relation of Banker and Country Correspondent. — With coimtiy
Having thus discussed the relations, rights and liabilities of baXers^''*
of customer and banker, upon the deposit of bills with
the latter, it remains to notice what are the relations, in
similar circumstances, when dealings between the banker
in the country and his London correspondents are added
to the former simple relation of banker and customer.
If a customer deposits indorsed bills with his country
banker to obtain payment of them, and the banker remits
them to the London bank, who are his correspondents
to receive and pay bills, and as such agents have an allow-
ance from him for so doing, and then the London bank
becomes bankrupt, with the bills remaining undue in his
hands, the trustee, upon receiving the proceeds of the
bills, must pay them over to the country bank, subject
to the lien of the London bankers for anything remaining
due from the country bank to them upon the contract be-
tween them ; the London bankers being the paid agents of
the country bank for this purpose of getting bills paid and
remitting the proceeds, and their power over the bills being
limited to that purpose.
The same would be the case if the London banker, in
the annual account between him and his correspondent in
the country, there being no proof of agency, had entered
the bills as the property of the correspondent. In the
former case he would be considered as the factor of the
country banker ; in the latter, there is raised an express
declaration of trust {t) .
Such, then, are the relations of country banker and
London correspondent, in case of the bankruptcy of the
(i) Ex parte Atkins, 3 M., D. & De G. 103. In place of tlie assignees
a trustee now represents the creditors, see ante, p. 26.
{f) Ex parte Tease, 1 Eose, 232; Ex parte Wakejield Bank, 1 Rose, 243.
154 DEPOSIT OF SECURITIES FOR SPECIAL PURPOSES.
latter. The result to the customer remains to be in-
quired into.
Now, it would manifestly be unjust, that the customer
should be affected by the bankruptcy of an agent whom
he has no voice in selecting, or by the state of the accounts
between his banker and that agent ; therefore, although the
country banker receives the proceeds of the bills, minus
the sum requisite to satisfy the London banker's lien for
advances (if any) and to indemnify his estate against ac-
ceptances or other engagements which he is under at the
time of his bankruptcy on account of the country bank {n),
yet he must pay a sum equal to the whole amount of the
proceeds of the bills to the customer (subject of com-se to
the state of the latter's account) ; for so only can his con-
tract with, or duty to, his customer be performed.
So where bills were remitted by a country bank to
their correspondents in London, and stood, at the bank-
ruptcy of the latter, entered short, not being then due, it
was ordered, on petition of the country bank, that the
biUs should be delivered up to them by the assignees.
The country bankers, in this instance, were not creditors
of the London bankers when this petition was first pre-
sented, the cash balance being against them, but had since
become so, turning the balance in their favour, by taking
up the acceptances given by the London house on their
account (r). The country bankers must have accounted
to the customer, who deposited the bills with them, for
the entire proceeds of them.
The following is a case of bills deposited by country
bankers with their London bankers, on which the London
bankers had a lien, and on which they were, therefore,
entitled to recover against the acceptor (who stood in the
character of surety for the country bank), by virtue of the
lien.
(k) Ex parte Buchanan, 1 Eose, 280,
(!•) Ibid.; Ex parte Jiowton, 1 Hose, 15; 17 Yes. 131; Ex i^artc Burton
Bank, 2 Rose, 162.
WITH COUNTRY CORRESPONDENTS OF BANKERS. 155
A banking house at Abingdon, being indebted to their
London correspondents, were urged by them to send them
up any bills they could procure. Accordingly they sent
up two bills for account, which had been accepted by A.
for their accommodation, and which became due respec-
tively the 19th March and the 19th April, 1814, each of
them being dated the 13th December, 1813. The balance
of the cash accoimt, on each of the two first-mentioned
dates, was considerably in favour of the country bankers.
There were also periods subsequent to those dates, when
the general account was in favour of the Abingdon bankers,
but they afterwards failed, being at that time indebted to
the London bankers in a sum exceeding the principal and
interest of the bills. Lord Ellenborough, at Nisi Prius,
held the meaning of the expression " for account," to be
for the then floating account ; and it was remarked, " There
was a period when the lien on the bills of the London
bankers ceased to attach, and when the bills might have
been redeemed ; but they were not reclaimed, and by
allowing them to remain in the hands of the London
bankers, their lien revested when, upon fresh advances
made, the balance turned in favour of the London bankers."
The action was brought by the London bankers against
the acceptor, in viiiue of their lien, and by way of en-
forcing and realizing it ; and there having been a verdict
in their favour, the Court in banc confirmed the verdict (»■).
The decision on the following facts illustrates the rela-
tion of country banker and London correspondent, when
the former deposits with the latter a security by way of
pledge.
A customer gave his promissory note to his bankers to
secure repayment of advances. They became bankrupt,
but, at that time, the customer held bank notes of their
bank to a greater amount than his promissory note, which
■he had all along reason to believe was still in the posses-
{w) Atwood V. Crowdie, 1 Stark. 483.
156 DEPOSIT OF SECUKITIES FOR SPECIAL PURPOSES.
sion of the bankers. In fact they had deposited it, hy
way of pledge, with their London correspondents. The
London bankers enforced the payment of it from the
maker, the customer of the country bank ; but the secu-
rities in the hands of the London bank were altogether
more than sufficient to cover what was due to them
from the bankrupts, and the surplus was returned to the
assignees (x) . As the customer might have set off the notes
he held against the note in the hands of the bankrupts,
he was entitled to recover its amount from the assignees.
The promissory note was payable on demand, with
interest. The case is singular in its circumstances. It is
obvious that the customer, thinking that his promissory
note was still in the hands of the bankers and so taking
their notes, in the way of business, which he might
have decHned to do if he had known that they had
parted with his note, was put in a different situation by
their conduct {//).
Bills depo8ited Biils deposited hy Strangers. — Several of the examples
T strangers. j^^gg^(jy cited have been cases where short bills have been
deposited by customers, it being the law, that bills are
considered short, not merely from the fact of their being
entered so, but from a consideration of the habits of deal-
ing between the parties, and all the circumstances.
The following is an instance of a decision upon facts
somewhat different : where, viz., the bills were not short
bills, and the party depositing was not a customer: — A
person deposited with bankers two bills (one for 600/. and
the other for 400/.) indorsed by him ; it being agreed that
he should draw for the amount of 1,000/., the bankers
refusing to discount them ; he, in fact, only drew to the
amount of 65/., and the bankers employed a broker to dis-
coimt the bills, and then became bankrupt in less than
three weeks after the bills had been deposited with them.
{j:) Sec autc, p. 2G.
(y) Ex parte Utaddon, 3 M., D. & De Gr. 256.
IN REPUTED OWNERSHIP OF BANKERS. 157
It was not the usage of the bankers to treat any bills paid
in by a customer as short bills, but to consider all paid
in by any person as the property of the bankers, and to be
paid in on the customer's general account ; and in keeping
their accounts they had not, like many other bankers, a
cash column and a bill column, in their books, but it was
their practice to blend both bills and cash; these were
entered as bills. There was no cash balance in favour of
the person who paid in these bills, at the time of the bank-
ruptcy, and no evidence of any other banking account in
his name than that on the bills. It was part of the agree-
ment for his drawing, &c., that he was not to draw out the
amount of the 400/. bill until the 600/. bill was paid. He
was held to be entitled, on the bankruptcy, to the proceeds
of the biU (s).
Here, it is evident, the property in the bills had never
passed from the depositor ; he was led to consider that the
bankers would not buy them ; their discounting them
afterwards was without his knowledge ; he would have
been entitled to the bills, if they had remained in specie in
the hands of the bankers.
Bills and other Property in reputed Ownership of Bankers. — Bills and
It has been stated that bills of exchange, remitted to a rfties^^'
banker, clothed with a trust, do not pass to the trustee reputed
upon the bankruptcy of the banker, as they would do if bankers,
they were, in such case, within the doctrine of reputed
ownership [a] ; but, nevertheless, under all other circimi-
stances, bills of exchange, placed in the hands of a banker,
will so pass. For instance, if A., icho has had no previous
dealings icifh a banker in the country, applies to him to
give him a bill on London for three bills of exchange of
which the aj)plicant is holder, and the banker does so, and
the bill given by the banker is afterwards dishonoured,
this transaction is a complete exchange of securities, and
(z) Ex parte Edwards, 2 M., D. & De G. 625.
(«) B:iukruptcj Act, 1869, 32 & 33 Vict. c. 71, s. 15 (5).
158 DEPOSIT OF SECURITIES FOR SPECIAL PURPOSES.
trover will not lie at tlie suit of A. for tlie tlu'ee bills ; and
even if the exchange has not been absolute and complete,
the banker having become bankrupt, the three bills, having
come to the hands of the assignees, must be considered as
goods and chattels in the order and disposition of the
bankrupt at the time of his bankruptcy, within the mean-
ing of the bankrupt law. For the bills being indorsed to
the bankers, they have the power of disposing of them, and,
in like manner, A. has a similar power over the bill handed
to liim in exchange : and the former, being negotiable
securities, and remaining in the hands of the bankers
until their bankruptcy, must necessarily be held within
the doctrine. This case has been held quite distinguish-
able from that of bills deposited by a customer clothed
with a trust, for trust property is always considered
not to be within the principle of the bankrupt law in
this respect (b).
But it is not only when bills of exchange or other
securities are deposited for a specific purpose with bankers,
that the property remains in the depositor ; there is another
class of cases, where money paid into a bank may, imder
certain circumstances, remain the property of the party
paying in, and be, therefore, recoverable on bankruptcy
from the trustee.
Thus, where a person deposited, after banking hours, a
large sum of money with the manager of a provincial
bank, at the banking house, the manager knowing that
the bank was on the eve of stopping, though no resolu-
tion to that effect had been, in form, come to by the
bankers, and he had put the money in a place by itself,
separately from the funds of the bank, and the bank never
after that day opened for business ; Lord Tenterden, C. J.,
held that the depositor was entitled to recover from the
assignees (r).
(i) ITornhlowcr v. rroud, 2 B. & A. 327; Edicards v. Ghjn, 2 El. & El.
29 ; 28 L. J., Q. B. 350 ; 5 Jur., N. S. 1307.
((•) Threlfalv. Giles, cited 2 M. & Rob. 492; now trustee, ante, p. 2G.
IN REPUTED OWNERSHIP OF BANKERS. 159
So where it was the usage of a banking house, that
money, paid in after banking hours, should be put into a
separate place of deposit, and entered in a counter book,
but not carried to the customer's account till the next day;
and a customer paid in a 500/. Bank of England note after
banking hours, and the banker having before resolved not
to re-open for business, put the note in a separate place,
and next morning stopped payment and became bankrupt,
the customer recovered from the assignees, the bank note
being held to remain his property {d).
It may be further observed, that by the usage the cus-
tomer was considered to be entitled to draw upon money so
paid in, at the opening of the bank on the following morn-
ing. The counter book was a book in which an entry was
made of all moneys paid into the bank, as they were paid in,
and was always resorted to, for the purpose of ascertaining
whether money had been paid in by a customer dming the
day, before a cheque of such customer was dishonoured.
The bank note was not entered in any other book of the
bank, nor was it in any way carried to the account of the
customer, or entered in his pass book, and never was
mixed with the assets of the house (d) .
A sum of money, consisting partly of Bank of England
notes and of country bank notes, partly of cheques on country
bankers and partly of coin, was, after banking hours on a
Saturday evening, placed in the hands of the manager of
the bank, at the banking house, where he resided, and he
gave a receipt for the same, wifh the words " to he ac-
counted for on demand,^' dated as of the following Monday ;
they were not entered in any of the bank books by the
manager, or in any way mixed with the bank moneys, but
were placed by the manager in a bag, in which there was
nothing else. The bank never opened again for business.
The partners in it were afterwards made bankruj)ts : the
money so deposited was held, in bankruptcy, to pass to
{d) Sadler v. Belcher, 2 M. & Rob. 489.
160 DEPOSIT OF SECURITIES FOR SPECIAL PURPOSES.
the assignees (/) , In this case, however, the manager
was in the habit of receiving deposits after banking
hours, and the customers, from whom the above-mentioned
deposit was received, were in the habit of making deposits
after the bank had closed, and such deposits had always
been treated by both parties as if regularly made. One
of the partners had already resolved to commit an act of
bankruptcy, and, on the same evening of Saturday, did
commit an inchoate act, unknown to the other and remain-
ing partner ; the firm did not become bankrupt until the
Monday.
Stock or Stock or Bonds. — Cases of fraudulent disposal by
bonds. bankers of stock or bonds belonging to customers some-
times occur, in which they have attempted to repair the
injury done to the customers by substituting securities of
their own in the place of the securities with which they
have improperly dealt, but such attempts are, for the most
part, wholly ineffectual, in the case of bankruptcy, as
against the trustee.
Thus, a customer of a banking house was owner of
16,000/. Navy Five per Cent. Stock, which stood in the
name of one of the partners of the bank ; the partner
sold out the whole of the stock, and applied the proceeds
to the purposes of the banking house, at the same time
enclosing in an envelope certain bonds belonging to the
house, together with a memorandum to this effect — " Bor-
rowed and received of J. Balfour, Esq. (the customer)
16,000/. Navy Five per Cents., which we promise to
replace ; and we have deposited with him, as collateral
securities, these bonds of the Earl of Oxford and Mor-
timer, and others, which we promise to assign when
required," — and sealing up the bonds, and writing on the
envelope, "The property of J. Balfour, Esq. ;" this packet
(/) Ex parte Clutton, 1 Fonb. 167 ; see Sadler v. Belcher, 2 M. & Rob.
489, the differonoc between the two cases i.", thnt, in the Litter, the deter-
miniition to commit un act of bankruptcy has been taken by all the
partners before the money was paid in; moreover, no receipt was given.
POLICIES OF IXSURANCE, ETC. 161
was deposited in an iron chest, among securities belonging
to other customers ; and in the evening of the day before
the bank stopped payment, it was sent to the customer,
who then first learnt that the stock had been sold : — It
was held that, as the possession of the bonds had never
been out of the bankers till the very eve of the bankruptcy,
when they could not give a preference, the customer had
no lien on the bonds, but must give them up to the as-
signees (./').
DEPOSIT OF SECURITIES AGAINST ADVANCES.
Having observed what is the effect of depositing secu- Securities
rities for some specific purpose, not giving any property yfnces.
in them to the bankers, in cases which, for the most part,
have arisen where the customer's account with the bankers
has been in his favour, let us proceed to investigate the
effect of depositing securities when the balance is against
him, and when the object of the deposit is to save harm-
less the bankers against their advances to the customer.
Policies of Insurance — Notice. — A policy of insurance is Policies of
a chose in action within the meaning of the proviso in sub- jJotfcT
section 15 of section 5 of the Bankruptcy Act of 1869 ;
and, consequently, is exempt from the operation of the
" apparent ownership" clause. A banker, therefore, who
receives such an instrument by way of equitable mortgage
for money advanced by him to the mortgagor, need not
give notice to the office in order to protect himself against
the trustees in bankruptcy of the mortgagor (^) . Under
the late Bankruptcy Act no such exemption in favour of
choses in action was made, accordingly notice was formerly
necessary to take the policy out of the apparent ownership
of the assured {h) .
(/) Wilson V. Balfoto; 2 Camp. 580.
(V) Sj: parte Ihbitson, 8 Ch. D. 519 ; In re Irving, 7 Ch. D. 419.
{h) Ex parte Armstrong, 3 M., D. & De G. 143 ; Gordon v. East India
Company, 7 T. R. 237 ; Ex parte Tennyson, Mont. & Bli. 67 ; Edwards v.
Martin, L. R., 1 Eq. 121.
G. M
insurance —
162
DEPOSIT OF SECURITIES AGAINST AD^'ANCES.
As to whom
the notice
should be
sent.
Assignment
of policies.
Notice, however, sliould be given to guard against any-
subsequent mortgagee without notice gaining priority by
giving notice (k). And to perfect the title as against the
office, and so prevent it from taking a surrender of the
policy (/), or from paying the sum secured thereby to the
assured (;;.'), notice to the office miist now be in writing,
by 30 & 31 Yict. c. 144 (ii).
As to u-hom the Notice should he sent. — All risks as to
whether notice has been properly given to the insurance
company will be avoided, hy gh-ing u-rittoi notice to the
officer representing the company, which, in the case of an
incorporated company, would be the head or chairman,
or the directors, or the secretary, according to the terms
of the charter, or incorporating statute ; and in the case of
a joint-stock companj^ would be the public officer of the
company, or secretary, or agent of the company, according
to the terms of the deed of settlement or articles of asso-
ciation, and the usual practice of the company (o).
Assignment- of Policies. — By 30 & 31 Yict. c. 144, an
assignee of a policy of insurance may sue at law in his own
name, provided a written notice has been given to the
company. The date of such notice shall regulate the
priority of all claims under any assignment. S. having
effected two policies upon his life for the purpose, as he
expressly informed the assurance company, of enabling
him to give C. a security for a debt which exceeded the
(/.•) Wihnot V. Tihc, 5 Hare, 19. ^^'^^cre a person lent money on Scrip certificates,
when proved by custom to pass by delivery, cannot be
recovered back from a bona fide holder for value who has
obtained them from a person in whom no title vested {h).
These certificates must bear a penny stamp (33 & 34 Yict.
c. 98, s. 23).
Title Deeds. — With respect to the deposit of title deeds, Title deeds,
it is desirable to state the principal results of the decisions,
many of which tend to show that bankers have acted at
{d) Shropshire Union Raihvaij and Canal Co. v. The Queen, supra.
{e) lb., per Lord Chancellor Cairns.
(/) Lindlej- on Partnership, p. 123.
{g) Eustace \. Dublin Trunk Railway, L. E., 6 Eq. 182.
[h) Goodu-in v. Eobarts, L. R., 1 App. Ca. 47G ; lo L. J., Ex. 748 ; 24
W. E. 987.
1G8 DEPOSIT OF SECURITIES AGAINST ADVANCES.
times, in sucli cases, as thoiigli they were inopes coiisilii,
and have suffered accordingly.
It is not necessary, for the purpose of effecting an equit-
able mortgage, that all the title deeds relating to the estate
should be deposited, provided real and material portions
of them are deposited {i) .
A deposit of title deeds, as a security for a debt, will, with-
out more, create in equity a charge upon the property ; but
where it is accompanied by a written document the terms
of that document must be referred to in order to ascertain
the exact nature of that charge {k) .
The prudence and propriety, with a view of preventing
disputes and removing all ground for question and litiga-
tion, have been pointed out, of always taking a memoran-
*dum of the object and purpose for which the deposit was
made, and numerous instances have occurred in which much
delay in realizing the securities would have been saved
to bankers if their advisers had been duly alive to these
considerations. For instance, it has been laid down, that
where there is no memorandum, an equitable mortgage so
created will prima facie be considered only as a security
for a debt then due {!). A deposit may, of course, be made
to cover futui'e advances and such an intention can be
proved by parol evidence {in).
An agreement to give a mortgage, and the delivery of
title deeds for the piu'pose of having the agreement carried
into effect, will constitute an equitable mortgage {n).
When title deeds are deposited by way of equitable
mortgage, and a memorandum merely states the purpose
fur which they are deposited, it is not an agreement for a
mortgage, and does not require to be stamped {o).
(i) Lacon v. Allen, 2C L. J., Chanc. 18.
(A-) Shaw V. Foster, L. R., 5 H. L. 321 ; 42 L. J., Chanc. 49.
\l) Ex parte Whitbread, 19 Ves. 209; Ex parte Mountfort, 14 Ves.
606.
(>«) Ex parte Mountfort, supra, Ex parte Hooper, 1 Mer. 7.
(w) Hockley v. Bantock, 1 Russ. 141 ; Keys v. Willianis, 3 Y. & C. 55.
(o) Meek V. Bayliss, 31 L. J., Chanc. 448. Sec Stamp Act, 1870, s. 105.
TITLE DEEDS. 169
Fixtures annexed to the realty, whetlier tenant's fixtures
or not, will be included in the equitable mortgage created
by the deposit of deeds, whether such deeds relate to free-
hold or leasehold property, and whether the fixtures are
erected subsequently to the deposit or before.
Thus a person deposited with his bankers the title deeds
relating to certain steam-mills, cottages, land, buildings
and machinery of which he was possessed, for an estate in
fee simj)le. The original memorandum of deposit was not
forthcoming, but a draft of it was proved, and it purported
to be made for securing to the bank all moneys then owing
to them by the depositor, and which should in futui-e be
advanced to him by them, together with bankers' com-
mission, and all other usual charges, and also all balances
which should at any time be due from the de^Dositor on his
banking account, together with interest for the same after
the rate of 51. per cent, per annum. After the date of the
deposit the depositor erected buildings for crushing bones,
and also for crushing oil seeds, with the necessary machi-
nery and steam-engine, all afiixed to the freehold. This
was held to be an equitable mortgage, giving a lien on the
fixtures, whether erected before or after the time of the
deposit, including those that were removable as between
landlord and tenant (j)).
In cases of equitable mortgages by manufacturers,
questions sometimes arise as to the passing, under the
deed, of the machinery, &c.
{p) J^j: parte Pr'ue, 2 M., D. &: De G. .518. See also Ex parte. Lloyd, 3
Deac. & C. 765 ; Ex parte Broadicood, 1 M., D. & De G. 631 ; Ex parte
CowcU, 17 L. J., Bank. 16; Ex parte Bcntleij, 2 M., D. & De G. .591 ;
Williams v. Evans, 23 Beav. 239 ; Tebb v. Hodfje, L. R., 5 C. P. 73 ; Mcux
V. Jacobs, L. E,., 7 H. L. Cas. 481. In Ex parte Tirecdy, In re Trethowan,
L. R., 5 Ch. D. 559 ; 46 L. J., Bank. 43, a lease of a shipbuilding yard,
and the trade fixtures therein were assigned to a shipbuilder to hold the
leasehold premises for the residue of the temi and the trade fixtm-es abso-
lutely. He deposited the lease and the assignment with his bankers for
advances made by them to him. No memorandum of charge was exe-
cuted. Held, among other things, that the equitable deposit did not
comprise the tenant's fixtures. This decision was appealed from, but the
parties effected a compromise before the case was reconsidered, and,
qaery, as to its correctness.
170 DEPOSIT OF SKCUlllTlES AGAINST ADVANCES.
In Re LloucVs Banking Compamj (), the rule was
stated to be that, where there is a mortgage of a manu-
factory and part of the machinery used in it is a fixture,
the mortgage passes the fixture.
The difficulty that arises is in deciding what constitutes
a fixture as a matter of fact. The following case may be
useful as showing the principle that has been adopted for
the decision of such questions : —
The owner in fee in possession of land and premises
deposited the title deeds with a banking company, as an
equitable mortgage to secure the balance of his account
with them for the time being. He then erected a mill,
and set up, not only steam power applicable to all mills,
but machinery applicable only to the purposes of a parti-
cular manufacture which he carried on there. He after-
wards granted a bill of sale of all the machinery, the
assignee having notice of the previous deposit of the deeds.
Held, as between the mortgagees and the assignee, that
all of the machinery which was annexed to the floor,
ceilings, or sides of the building in a quasi permanent
manner by means of bolts and screws passed to the mort-
gagees ; and that it made no difference that the object of
annexation was merely to steady the machines when in
use, and that they could be removed without any injury
to them or the freehold ; nor that the machines were in the
nature of trade fixtures, which would, as between landlord
and tenant, belong to the tenant (;■).
Again, in Holland v. Hodgson (s), it was held that an
article .affixed to the soil by the owner of the fee, though
only by the means of bolts and screws, was to be consi-
dered as part of the land ; at all events, where the object
of setting up the article is to enhance the value of the
premises to which it is annexed for the purposes to which
those premises are applied {t).
{q) L. R., 4 Ch. App. 634.
(r) LongboUom v. Berry, L. R., 5 Q. B. 123 ; 30 L. J., Q. B. 39.
\s) L. k, 7 C. P. 328.
{t) Sec also Tcbb v. llodf/c, anle, and Mcux v. Jacobs, autc, Ex purlc
TITJ.E DEEPS. 171
An equitable mortgagee hy deposit of a lease is not
bound, af the suit of the lessor, to take a legal assignment
of the lease, nor is be liable to the covenants of tlie
lease {u) ; for there is no privity between him and the
lessor until he has made himself legal assignee ; and so to
hold " would effectually prevent anybody from ever taking
a deposit of a lease as a security for a sum of money ; for
no man in his senses would take a deposit of a lease if ho
were thereby to render himself liable to the covenants of
the lease" (u).
Independently of the statute 15 & 16 Vict. c. 86, s. 48,
the proper remedy of an equitable mortgagee by deposit
of title deeds, whether with or without a memorandum,
is by foreclosure, and not sale, unless it is otherwise
agreed (;»).
If the banker, having such equitable mortgage by de-
posit of the title deeds of an estate in fee, enters into the
receipt of the rents of the mortgaged estate, such receipt
amounts to a payment, jirimd facie, either of the principal
or interest of the debt, as the case may be, so as to take
the case out of the Statute of Limitations (//).
It is to be borne in mind, however, that if a banker,
being equitable mortgagee of land, takes upon him to
assume the right of taking possession, without applying to
a Court of equity for leave or directions to do so, and un-
reasonably and unnecessarily, for the purpose of defending
any right given him by his mortgage, defends an action
brought against him in consequence of his so acting, and
Moore's Company, 14 Ch. D. 379 ; Reg. v. Inhabitants of the Parish of Zee,
L. E., 1 Q. B. 241 ; Langton v. Horton, 1 Hare, 549.
{h) Moore v. Greg, 2 Ph. 717; Cox v. Bishop, 26 L. J., Chauc. 389.
See Wright v. I'itt, L. R., 12 Eq. 408 ; 40 L. J., Ch. 558.
(.(•) James v. James, Jj. R., 16 £q. 153; Samblev. Wilson, 5 N. R. 395;
UuckhoHse V. Carlton, L. R., 8 Ch. D. 444.
(y) Broekleliurst v. Jcsiop, 7 Sim. 438. See Fordhamx. WaUis, 10 Hare,
228. Such a payment, however, within the meaning of 1 Vict. o. 28, so
as to take the case out of sect. 2, must be a payment of principal or
interest by the mortgagor or his agent, or some person bound to pay on
his behalf. The payment of rent by the tenant is not such a payment
on behalf of the niortgaijor. Cli inner y v. Evans, 11 H. L. C. 115; Ilar-
lock V. Ashhrrry, "W. N.,l882, p. 15.
172 DEPOSIT OF SECUKiTlES AGAIKST ADA'AXCES.
is unsuccessful in his defence, he will not be allowed the
costs out of the mortgaged estate (;;) .
In reference to questions respecting a freehold or lease-
hold security, it may be well to point out, that the deposit
of the lease of a house, or deeds of conveyance of a house
and furniture to the depositor, does not, by any means,
necessarily extend to charge the furniture in the house.
Thus, where A. deposited with B., as security for a
debt, certain deeds, by which a freehold house at Bognor
and the furniture therein were conveyed and assigned to
A., and the memorandum of deposit was as follows : —
" Herewith I hand you the title deeds of my Bognor estate,
to be held by you, &c. ;" these words were decided not to
extend to the furniture, which, imder them, did not pass to
B., nor did any interest in the fui'niture. If it had been
the intention that the furniture shoidd be included in the
security, B. ought to have taken care that A. so expressed
his memorandum of deposit as to include the furniture,
and that a schedule was added enumerating the different
articles {a) .
It seems, however, that, when a lease of a house engaged
in trade is deposited as an equitable mortgage, the depo-
sitee is entitled to the whole of the price, on the sale of the
lease or goodwill of the business whether it is considered to
arise from the goodwill, or from the value of the lease in-
dependently of the goodA\ill (b).
A written agreement for a lease in which the lessee
undertakes to put up fixtures of a given value, and the
lessor to grant a lease of, and to lend a sum on, the pre-
mises as fitted, creates an equitable mortgage (c).
When the deposited documents are title deeds which
have been deposited with the customer by a third party,
with a written memorandum of tlie object of their deposit
(z) Dri/clcn v. Frost, 3 M. & C. 670 ; Luiiia.r v. Jfi/de, 2 Vera. 185.
(a) Ex parte Jlxnt, 1 M., D. & Do G. 139.
(6) ChiKHum V. DcwcH, 5 Rxiss. 29. See Stiivart v. Gladstone, L. R., 10
Ch. D. (12G ; Lent v. Walker, ib. 136.
{e) Tvbb V. Jloelge, L. R., 5 C. P. 73,
TITLE DEEDS. 173
with him, it is not necessary, to constitute a valid and
equitable sub-mortgage to a banker, that the original
memorandum should also be deposited {d).
It is now settled that if bankers take a mortgage to
secure a specific sum and future advances, and the mort-
gagor makes a second mortgage to A. in a similar form
with notice of the prior mortgage, they will not be entitled
to priority for further advances made after notice of the
mortgage to A. (e).
The owner of land, after depositing the title deeds with
a bank as security for all sums then or thereafter to become
due on his general balance of his account with the bank,
contracted with the knowledge of the bank to sell the land
to one who had notice of the terms of the deposit. The
vendor afterwards paid into his own account at the bank
sums which in the whole exceeded the debt due to the bank
on his balance at the time of the contract of sale, so that on
the principle of Clai/foi/'s case (/), that debt was discharged.
The bank, without giving notice to the purchaser, continued
the account and made fresh advances to the vendor, so that
on the general balance there was always a debt to the
bank. The purchaser, who never had notice of the fresh
advances, paid the pui'chase-money by instalments to the
vendor : — Held, that, on the principle of the above case, the
bank had no charge on the land as against the purchaser
for the fresh advances, nor upon the purchase-money (^).
In giving judgment. Lord Blackburn said, " This raises the
question, whether anyone purchasing land, with notice that
the title deeds have been deposited with a bank, is bound
to enquire whether the bank has, after receiving notice
of this purchase, made fresh advances on the security
of the unpaid vendor's lien ; or whether the burden does
{d) Ex parte Smith, 2 D. & De G. 587 ; Ex parte Farley, 1 M., D. & De
G-. 683.
(«) Hopkinson v. RoU, 9 H. L. Cas. 541 ; 28 L. J., Chanc. 41. See
Menzies v. Lightfoot, L. R., 11 Eq. 459.
(/) 1 Mer. 585.
{(j) Loiiduii and Coiiidi/ Baiiling Cumpang v. llaiellffe, G App. Cas. 722.
174 DEPOSIT OF SECURITIES AGAINST ADVANCES.
not lie on the bank, advancing on the security of the un-
paid vendor's lien, to give notice to the purchaser that
it has so done, or intends so to do. No case was cited in
which any such point had heen discussed ; but I think
both convenience and principle strongly point to the burden
of giving notice lying on the bank, and not on the pur-
chaser, whose enquiries might often be annoying and im-
pertinent" (//).
A banking house, in consideration of an existing debt,
and of a further advance of money to a customer, obtained
from him a deposit of all the title deeds of certain freehold
and copyhold lands of which he was seised, with a written
memorandum signed by him, regularly charging the lands
with payment of the whole debt and interest. Other cre-
ditors subsequently recovered judgment against him, and,
under 1 & 2 Yict. c. 110, s. 13, sued out elegit!^, under
which the sheriff delivered to them the whole of the land.
The bankers, having filed a bill in chancery, praying that
they might be declared to have an equitable mortgage
upon the land, and to be entitled to priority over the elegifs
and judgments, had their prayer granted, fl/e)-c Jtaving been
no laches on their imrt, and their title being perfected before
the judgments were recovered (/).
The bankers, it may be observed, having perfected their
title as equitable mortgagees, must have been preferred to
the judgment creditors in this case, independently of the
statute (/) .
Indeed, such perfected eqiiitable mortgage will prevail,
even against an extent at the suit of the Crown (,/), except
where the mortgagor is an accountant to the Crown (/«•).
A banker's equitable mortgage will not prevail against
that of a prior equitable mortgagee unless the latter has
(//) Ibid., at p. 739.
(;) Whitworth V. Gaugain, 3 Hare, 416; affirmed, 1 Ph. 728, and
adopted, Waits v. roricr, 3 El. & Bl. 743.
(;) Caxbardy. Alt.-Geii., G Price, 411 ; confirmed, IJ'otts v. I'orto; 3 El.
& Bl. 743, 753.
(/■) Broi'fihio)! V. Dorii's, 1 Price, 21G.
EQUlTAliLE MORTGAGE BY COMPANY. 175
iDeen guilty of negligence (/), because wliere the equities
are equal priority in time prevails. When money has
"been lent on an equitable mortgage without notice of a
prior equitable agreement the lender gains no priority over
the owner of the prior equitable interest by getting in the
legal estate after he has had notice that his mortgagor has
made himself a trustee for the owner of the prior equity {m).
A banker's equitable mortgage, moreover, is defeated
by a person claiming under a legal title, though obtained
subsequently to the equitable mortgage, provided he had
no notice of the prior incumbrance and was a purchaser
for value. This proceeds on the doctrine that when the
equities are equal, the legal estate prevails (^/). But if
the legal owner has been guilty of negligence then the rule
is otherwise. Thus : A mortgagee of leasehold property
lent the lease to the mortgagor for the purpose of raising
money upon it ; but at the same time told the mortgagor
to inform the person from whom he proposed to borrow,
that he had a prior charge. The mortgagor borrowed
money fi'om his bankers, and deposited the lease as security
without giving them notice of the mortgage : — Held, that
the mortgage must be postponed to that of the bankers (o)
Equitable Mortgage hij Company. — A company deposited
title deeds with a bank as collateral security for bills under
discount. At the time the company was wound up, it was
indebted to the bank in respect of other bills than those
actually discounted, and the securities realized more than
was sufficient to cover the latter bills : — Held, that the
{I) Di.ro)i V. Mucklcston, L. E., 8 Ch. 155 ; Bradley v. HicJus, 9 Ch. D.
189; 39 L. T. 78.
(;h) Mmnfonl v. Sfoicasser, L. R., 18 Eq. 556. See also EatcUffcY.
Barnard, L. R., 6 Ch. 652 ; Maxfeldx. Burton, L. R., 17 Eq. 15 ; 43 L. J.,
Ch. 46; Saffron Walden Building Society v. Eayner, L. R., 10 Ch. D.
G96; 48 L. J., Ch. 402.
{») Young v. Youn//, L. R., 3 Eq. 801 ; Agra Bank v. Barry, L. R., 7
H. L. Cas. 135; Pitcher x. Bauiins, L. R., 7 Ch. 259; leey. Clutton, 45
L. J., Ch. 43. The fact of the banker possessing the title deeds will be
strong evidence to show the subsequent legal owner must have had notice
of the prior enciunbrance. Maxfield\. Burton, L. R., 17 Eq. 15; Spencer
T. Clar/.-e, 9 Ch. D. 137.
{'j) Briggs v. Jones, L. R., 10 Eq. 92; 22 L. T. 212.
176 DEPOSIT OF SECURITIES AGAINST ADVANCES.
company could effect a mortgage by deposit of deeds with-
out complying with the formalities by its articles of asso-
ciation upon the execution of mortgage deeds: that the
bankers were not in the position of officers of the company,
who are bound to see that the required formalities were
complied with, and that the bank was entitled to hold the
balance of the proceeds upon the sale of the securities to
meet the whole amount due to it by the company (7;).
But in a later case it has been held that the mortgagee
cannot so retain the surplus proceeds (q).
The articles of association provided that a company
might, v»'ith the sanction of a general meeting, borrow
money not exceeding in amount the one-half of the
nominal capital upon mortgage. The nominal capital of
the company was 100,000/. The company passed a reso-
lution authorizing a mortgage to the extent of one-third
of the nominal capital. A few weeks after this, the account
of the company being overdrawn to the extent of more
than 23,000/., and the bankers pressing for security, the
directors deposited with them the title deeds of the pro-
perty on which the company carried on their business, and
gave a memorandum of deposit under the seal of the
company, making the deeds a security for the balance of
account up to 25,000/. Within six months after this a
resolution was passed for winding up : — Held, that the
express power did not negative the general power, the nile
being that a company may mortgage its property, unless it
is expressly prohibited by its articles from so doing, and
that the security was valid, notwithstanding it was given
to secure a past debt (r).
Exchequer Exchequer Bilh. — Exchequer bills, provided their blanks
bills.
{p) General Provident Assurance Company, In re Xal tonal Bank, L. R.,
14 Eq. 507; 41 L. J., Ch. 823.
{(l) Talbot V. Frerc, 9 Ch. D. 5G8 ; 27 W. R. 148, not followiug In re
National Bank, S)ipra, on this point.
(r) In 7-c Bafcnt File Company, Fx parte Birminnhcm Banking Company,
L. R., 6 Ch. 83 ; 40 L. J., Ch. 190.
EXCHEQUER RILLS AXD PROMISSORY NOTES. 177
are not filled up, are negotiable instruments and pass by
delivery.
Where A. deposited an exchequer bill (with the payee's
name in blank) with B., in order that he might sell it, but
B., instead of doing so, placed it in the hands of his
bankers, who advanced him money to the amount of its
value ; B. having become bankrupt, a majority of the
Court of King's Bench held, that A. had no right of
action against the bankers to recover the bill, because
the property in exchequer bills passes by delivery (s).
Exchequer bonds, also, are negotiable instruments.
JBiUs of Exchange J Promissory Notes and other Securities. Bills of ex-
— Where bills indorsed in blank, or promissory notes, missm-y notes
are deposited merely by way of security, the property to ^^^ °.*V'^'"
them remains in the depositor, both as against the de-
positary and a third party with notice (/).
The payee of some promissory notes of the East India
Company, by power of attorney, authorized his agents at
Calcutta, a firm of bankers, to " sell, indorse and assign "
the notes, which were transferable by indorsement and
payable to bearer. The agents, in their character of
bankers, borrowed money of the Bank of Bengal, offering,
as a security, these promissory notes. The Bank of
Bengal made the advance, the agents indorsing the notes,
and purporting to make the indorsement as attorney
for their principal ; they deposited the notes with the
Bank of Bengal by way of collateral security for their
personal liability, at the same time authorizing the Bank
of Bengal, in default of payment, to sell the notes, in
reimbursement of their advance. The agents afterwards
became insolvent, and default having been made in pay-
ment, the Bank of Bengal sold the notes and realized the
amount of their loan. The indorsement of the notes by
the bank was considered to be within the scope of their
(s) JFooJcey v. Pole, 4 B. & A. 1 .
{() Goggerhj v. Cxthhert, 2 N. R. 170.
G. N
178 DEPOSIT OF SECURITIES AGAINST ADVANCES.
authority given tliem as agents of the payee by the
power of attorney ; and, consequently, the payee could not
recover in detinue against the Bank of Bengal («) .
A banker, having made advances to A., took his pro-
missory note for 400/., payable on demand, with lawful
interest, as a secmity for the advances. The banker subse-
quently indorsed the note to B., as a security for money
placed in his hands by B. Some time afterwards A. and
the banker settled their accounts, and A. paid the balance,
but neglected to ask for the note, which was not delivered
up to him. Then the note passed backwards and forwards
several times between the banker and B., during all which
time the former was indebted to the latter in more than
400/. ; the banker, on one of these occasions, telling B.
that it must not be negotiated, as he should want it when
he settled accounts with A. When this communication
took place did not appear exactly, but it was before the
last time the note was deposited with B. : and it was held
to be decisive to show that it was not negotiated to B.,
but only deposited with him as a pledge. And that,
therefore, B. (or his assignees on his bankruptcy) could
not, after the settlement of accounts between A. and the
banker without a re-delivery of the note to A., recover on
it against A. (v).
Bills of exchange are not, as a general rule, proper sub-
jects of mortgage, and are pn'md facie presumed to be
given in part payment as they become due (/r).
A deposit, by way of mortgage, of a land order of the
New Zealand Land Company is good, although no notice
was given to the company of the deposit (.r).
C. deposits, as security for an advance from the bank,
a bond given by B. to A. ; C. dies in embarrassed cir-
(k) J3a>ilc of Bengal v. Machod, o Moore, Indian Ajjp. 1 ; 7 Moore, P. C.
35 ; iS'. P., Bank of Bengal v. Fagan, 5 Moore, Indian App. 27; 7 Moore,
P. C. 61.
{v) Jiuherts V. Eden, 1 B. & P. 398.
(w) Hilh V. Parker, It L. T., N. S. 107.
{x) E.r parte Banietf, 1 De Gex, 203.
BILLS OF LADING. 179
cumstances, after having paid A. the amount, hut without
B.'s knowledge ; the hank may sue B. in A.'s name ( //).
If a trader has securities lent to him in order that hy
depositing them he may get credit with the hank of A., he
is not authorized, after having redeemed them from the
hank of A., again to deposit them in order to ohtain credit
with the hank of B., although the securities had heen in-
dorsed to him (~).
When a trader deposits securities in his possession for
the purpose of ohtaining credit, and does so without the
knowledge of the owner of the secm-ities, he is not to he
considered, if he redeems them, to have given a fraudulent
preference to the owner (;:).
Bills of Lading. — A hill of lading is a contract in writing, BlUsof lading,
signed and delivered hy the owner or master of a ship,
whereby he acknowledges the receipt of goods and under-
takes to convey them (unless prevented from so doing hy
the act of Grod, the queen's enemies, accidents of naviga-
tion or fire), and to deliver them, on payment of freight, to
the person mentioned therein, or his order or assigns. So
long as the goods are in transitu, the vendor has a right to
stop them as against the vendee, in the event of the latter's
insolvency {n) ; though the better opinion would seem to
be, that stoppage in transitu does not rescind the contract
of sale altogether [h). A vendee, however, can defeat the
vendor's right of stoppage in transitu by negotiating the
bill to a hond fide transferee for value ; but, as will be seen
from the next paragraph, the transferee's right to the goods
will only be co-extensive with the amount of his debts (c).
(y) Lucas v. WiUcinson, 2G L. J., Exch. 13 ; 1 H. & N. 420.
(s) Sinclair \. Wihon, 24 L. J., Chanc. 537.
(a) Liclcbarrow v. 3fason, 1 Sm. L. Ca. 810.
(i) TTent worth v. Outhicaite, 10 M. feW. 451 ; E.r parte StapMon, L. E,.,
10 Ch. D. 586. As to -svliose goods are in transitu, see Bolton v. Lancashire
and Yorkshire Ruihvay Co., L. R., 1 C. P. 431 ; Rodger v. Comptoir D^Es-
comptc de Paris, L. E.., 2 P. C. C. 398 ; Mo'chant Banhiny Co. v. Bhaenix
Bessemer Sted Co., L. R., 5 Ch. D. 205.
(e) Leash v. Scott, 2 Q. B. D. 376 ; 46 L. J., Q. B. 576 ; Ogrj v. Shxfer,
1 0. P. D. 47 ; 45 L. J., Cf. P. 44 ; Spalding v. Bnding, 6 Beav. 376.
n2 ■
180 DEPOSIT OF SECURITIES AGAINST ADVANCES.
A bill of lading may be deposited by the consignee
thereof as a security for an advance made to liim, and such
deposit will carry with it a right to the legal possession of
the goods ; but in the event of the insolvency of the con-
signee, the vendor's right of stoj)jXf[/e in trcumtu is not
wholly gone, for he may, in equity at least, resume his
interest in the goods, subject to the right of the depositee
to have his debt first satisfied ; and when, with the deposit
of the bill of lading, other goods belonging to the de-
positor are pledged, the vendor may insist upon the pro-
ceeds of such goods being appropriated, in the first instance,
to the payment of the debt.
This rule was laid down in Re Westzmihus {d), in which
the facts were as follows : — L. and Co. who had purchased
oil from W., paid for it by acceptance, and indorsed and
deposited the bill of lading with II. and Co. as seciu-ity for
a certain advance. L. and Co. having become bankrupt,
and their acceptance dishonoured, W. gave notice to the
master of the ship that he claimed to stop the oil i)i fraiisifii.
At the time of L. and Co.'s bankruptcy .they were indebted
to II. and Co. to the amount of 9,271/. on account of
various advances for which, in addition to the bill of lading,
they held as security other goods to the value of 9,961/.
It was held, that W. was entitled to insist upon the proceeds
of L.'s own goods being appropriated to satisfy II. and Co.'s
debt, and since they proved sufficient to do so, to have de-
livered over to him the whole proceeds of the oil.
" As Westzinthus," Lord Denman said, " would have
had a clear right at law to resume the possession of the
goods on the insolvency of the vendee had it not been for
the transfer of the property and right of possession by the
indorsement of the bill of lading for a valuable considera-
tion to llardman, it appears to us that in a Court of
Equity such transfer would be treated as a pledge or
mortgage only, and "Westzinthus would be considered as
[d) o B. 6L- Ad. 817.
FACTORS ACTS. 181
having resumed his former interest in the goods subject to
that pledge or mortgage, in analogy to the common case
of a mortgage of a real estate, which is considered as a
mere security, and the mortgagor as the owner of the
land. We therefore think that Westzinthus by his at-
tempted stoppage in transitu acquired a right to the goods
in equity (subject to Hardman's lien thereon) as against
Lapage and his assignees, who are bound by the same
equities that Lapage himself was. ... If, then, "Westzinthus
had an equitable right to the oil, subject to Hardman's lien
thereon for his debt, he would by means of his goods
have become a surety to Hardman for Lapage's debt, and
would then have a clear equity to oblige Hardman to
have recourse against Lapage's own goods deposited with
him to pay his debt in lieu of the surety ; and all the
goods, both of Lapage and Westzinthus having been sold,
he would have a right to insist upon the proceeds of
Lapage's goods being appropriated, in the first instance,
to the payment of the debt " (e).
Factors Acts. — Formerly a factor could not bind his Factors Acts.
principal by pledging a bill of lading, without his autho-
rity, though he might do so by selling it ; but now, by
5 & 6 Yict. c. 39 (/), an agent (^) intrusted with the
possession of goods, or of the documents of title to
goods (h) (and priuid facie an agent in possession is to be
taken "to be intrusted "), is to be deemed the owner
thereof, so far as to give validity to any contract or
agreement by way of j^Icdge, lien, or security bond fide
made by any person with such agent so intrusted as well
as for any original loan, advance, or payment made upon
(e) See also, as to this latter point, Ex parte Alston, L. K., 4 Ch. 1C8 ;
Coventrxj v. Gladstone, L. E,., 6 Eq. 44.
(/) See also 4 Geo. 4, c. 83 ; 6 Geo. 4, c. 94.
{g) In the two prior acts the words used -were "persons intrusted,"
but these words have been held to mean no more than * ' intrusted to a
factor or agent as such." See Johnson v. Credit Lyonnais, L. R., 3 C. P.
D. 32, 43, 48 ; 47 L. J., C. P. 241 ; 26 W. R. 195.
{h) Vickers v. Eertz, L. R., 2 Sc. Ap. 113, 118.
182 DEPOSIT OF SECURITIES AGAINST ADVANCES.
the security of such, goods or documents, as also for any
further or continuing advance in respect thereof, and such
contract or agreement shall be binding upon and good against
the owner of such goods, and all other persons interested
therein, notwithstanding the person claiming such pledge
or lien may have had notice that the person with whom such
contract or agreement is made is only an agent (/). A wine-
merchant's clerk is not an " agent " within the section,
but a mere servant of his principal (k) ; nor is a ware-
house-keeper who has goods deposited with him as
such (/) ; but the word is restricted to those who in the
ordinary course of business have power to sell or pledge
goods and receive payment or advances for their prin-
cipals (m) . It is on this ground that formerly a vendor or
vendee who retained possession of the documents of title
to goods sold was held not an agent within the act {n).
To remedy this, however, an act was passed, 40 & 41 Vict.
c. 39, by which now vendors and vendees in possession of
the documents of title to goods sold are to be deemed
" agents " or " persons intrusted " within the meaning of
the Factors Acts (o). By the same act it is enacted that
no revocation of agency or entrustment shall prejudice the
title of any person, who, without notice of such revocation,
purchases such goods or documents, or makes advances
upon the faith or security of such goods or documents (j)).
(j) A woolbrokcr gave to a bank a letter of hypothecation on certam
wools, to secure an advance, promising to lodge warehouse waiTants for
them next day. The bank made repeated application for the warrants,
but could not obtain them. A few days afterwards, the broker ha\-ing
left the house, the bankers, by pressure, obtained the keys of the ware-
house where the wool was stored and took possession. Part of the wool
had belonged to a customer of the broker, wlio was, liowevor, under ad-
vances and made no claim. Ileid, that the bank acquired a valid cliargo
on the wool under the Factors Act, 5 & G Vict. c. 39, Hm parte Mrth
JVcstem Bank, L. E,., 15 Eq. G9 ; 42 L. J., Bank. 6 ; 21 W. K. 69.
(/.) Lamb v. Attcnhnroiujh, 31 L. J., Q. B. 41.
(/) Cole V. N. W. Bank, L. R., IOC. P. 3.54 ; 44 L. J., C. P. 233.
{m) Ibid.
(ii) Johnson V. Lyonnais (Jompamj, ante ; Jaikyns v. Vsbornc, 5 Sc,
N. li. 40-3.
{o) Sect. 3.
(/?) Sect. 2.
DEPOSIT OF GOODS. 183
Formerly an agent, though, otherwise within the acts,
ceased to be so, if his authority had been revoked (q).
Deposit of Goods. — Glenerally, as to the deposit of goods Deposit of
by way of security, a banker is bound, at common law, to ^^o"^^-
take care that the person depositing is entitled to the
goods ; otherwise the banker may at any time be called
upon to surrender the goods, or the value of them, to their
real owner (r) ; and a person, though he comes into pos-
session of goods properly, nevertheless does not always
take or retain the right to dispose of them ; thus, if a per-
son is entrusted with jewels in a bag sealed, to be kept
safely for the use of the real owner, he becomes possessor
maid fide by breaking the seals ; he has no right to the
property, and he cannot transfer to the banker more right
than he has himself («) .
A person receiving goods by w^ay of security for an
advance has, it has been held, a lien on such goods for
advances made subsequently to, though not on, that
security [t) . Considerable doubt, however, exists as to the
correctness of this decision («), while it is clear no such right
•would exist as against the pledgor's creditors or subsequent
purchasers {v).
Where a time is fixed for repayment of the advance, and
default is made by the pledgor, the banker may sell the
goods (?r) ; and where no such time is named, the better
opinion would seem to be that he may also do so, provided
he first makes a formal demand on the pledgor to fulfil his
engagement, and gives him notice of his intention to sell,
{q) Fuentes v. Montis, L. R., 3 C. P. 268. By sect. 5 of this act,
moreover, where documents of title other than bills of lading have been
lawfully endorsed or transferred by a vendee to a bona fide transferee the
vendor's lien or right of stoppage in transitu wUl be defeated just as in
the case of a transfer of a bill of lading.
(r) Havtop v. Eoarc, 3 Atk. 44. As to the right of factors, &€., to bind
their principals by pledging goods, see ante, p. 181,
(«) Hartop V. Hoare, 3 Atk. 44.
{t) Demainbray v. Metcalfe, 2 Vem. 691.
(m) See Fisher on Mortgages, p. 616, and cases there quoted.
(r) Adams v. Claxton, 6 Ves. 229 ; Tanda-zce v. Willis, 3 Bro. C. C. 21 ;
Talbot V. Frere, 9 Ch. D. 568.
(m) Fotlwnier v. Dawson, Holt, 385. See Figot v. Chuhley, 15 C. B.,
N. S. 701.
184 DEPOSIT OF SECURITIES AGAINST ADVANCES.
in the event of his making default (.r) . So, when the
sale has taken place, any surplus that remains out of the
proceeds after the pledgee has repaid himself his debt,
interest and costs, must be handed over to the pledgor {>/) .
The pledgee is bound to exercise ordinary diligence and
care in keeping the subject-matter of the pledge, and, so
long as he does this, he is not liable for its loss or destruc-
tion, nor is he prevented from suing for the amount so
secured (;:).
Bills of sale. When goods are mortgaged by bill of sale as security
for an advance, the banker must be careful that all the
requisites of the Bills of Sale Act (41 & 42 Yict. c. 31),
have been complied with, or otherwise he may find that
his security is not worth " the paper it is writ on." What
these requisites are, and what is the result of not complying
with them, will be found fully stated in a subsequent
chapter {a) .
Neither must bankers secure themselves at the expense
of the creditors by a bill of sale which deprives the grantor
of all his property, as the execution of such an instrument
is an act of bankruptcy. As to when such an assignment
will amount to an act of bankruptcy, L. J. Mellish thus
summarizes the law, " The result of the authorities is, that
where a debtor assigns his whole property as a security for
a past debt only, it is an act of bankruptcy, whatever the
motives may be. If there is also a further advance it is
not a question whether the further advance is great or
small, but whether there was a bona fide intention of
carrying on the business "((6). And again, in Kr parte
King, James, L. J., says, " In each case, looking at all the
circumstances, you have to answer these questions. Does
the assignment include all the property, or is there a sub-
stantial exception ? Is it wholly to secure a pre-existing
(j) Martin v. Bead, 11 C. B., N. S. 730; 31 L. J., C. P. 12G.
[y) Wilson V. Tookcr, o Bro. V. C. 193. See also AUcnborongh v. St.
Katkcrine's Dock Co., 3 C. P. D. 464 ; 47 L. J., C. P. 763.
(;) Coytjn V. Bernard, 2 Ld. liaj'inoud, 909 ; 1 Sm. L. Ca. 227.
(a) I'ost, Chapter on Bills of Sale.
(*) Ex parte Ellis, 2 Ch. 1). 798 ; 4.5 L. J., Bank. 1.59.
sHirs. 185
debt, and if tliere is a further advance, is it a substantial
one, or only one intended to give colour to a security
wluch is in reality made only for the purpose of securing a
pre-existing debt ? These are questions of fact, and the
answers given depend on the circumstances" (c).
A document stating goods to have been deposited as a
security for the repayment of money lent, and containing
a power of sale in default of payment, does not require to
be stamped as a mortgage deed {d) .
S/iips. — By the Merchant Shipping Act, 1851 (e), a
registered ship, or any share therein, may be made security
for a loan by way of mortgage in two ways : (1) by a
direct mortgage with registration ; (2) by a mortgage
under a mortgage certificate.
(1.) The mortgage must be in the form marked I. in the
schedule to the act, or as near thereto as circumstances wUl
permit, and on its production the registrar of the port
where the ship is registered shall record the same in the
register books (/). The mortgages are registered in the
order of time of their production {g), and where there is
more than one mortgage registered of the same ship or
shares therein, the mortgagees shall, notwithstanding any
express, implied or constructive notice be entitled in priority
one over the other, according to the date at which each
instrument is recorded in the register books, and not
according to the date of each instrument itself {/i). It has
been held, however, that as against the mortgagor himself
registration is not necessary (/).
{c) Ex parte Ellis, 2 Ch. D. 798. See also Lomax v. Buxton, L. R.,
G C. P. 107; Jones v. Barber, L. R., 6 Q. B. 77; Fhilps v. Hornstedt,
1 Ex. D. 62 ; Ex parte Fisher, L. R., 7 Ch. 636; Harrison v. Cohen, 32 L.
T. 717 ; Ex parte Faijne, 11 Ch. D. 539 ; 40 L. T. 296 ; 27 W. R. 368.
(r/) Attenhorough v. Commissioners of Inland JRevenue, In re Wright, II
Exch. 461 ; 25 L. J., Exch. 22.
(c) 17 & 18 Vict. c. 104.
(/) Sect. 66.
{g) Sect. 67.
(h) Sect. 68.
(i) Lister v. Faijne, 11 Sim. 348.
186 DEPOSIT OF SECURITIES AGAINST ADVANCES.
And an unregistered mortgage will pass tlie ownership
of a ship to the mortgagee even as against an equitable
assignee of the freight, at all events in the absence of
fraud, or of such gross and wilful negligence as is equiva-
lent to fraud, and provided the mortgagee has taken
possession (/.•). The only effect of not registering the
mortgage is to postpone the claim of the mortgagee to that
of a subsequent mortgagee who has registered (/) . A
mortgagee who has taken possession becomes entitled to
the accruing freight {m), and to use or sell the ship {)i).
And upon taking possession he becomes an owner within
the Merchant Shipping Act (17 & 18 Vict. c. 104), and
subject to all the liabilities consequent thereon (o). The
rights of a registered mortgage are not affected by any act
of bankruptcy committed by the mortgagor after the date
of the record of the mortgage; and the mortgaged pro-
perty is not considered as being in the apparent ownership
of the bankrupt within the meaning of the Bankruptcy
Act, and the mortgagee will be preferred to the trustee in
bankruptcy (j)).
(2.) A mortgage certificate is a power given to the
owner of a ship or share therein by the registrar enabling
him to mortgage such ship or share (q).
Certificates of mortgage must be in the forms contained
in the schedule to the act, and contain a statement of the
several particulars mentioned in sect. 77, and in addition
thereto an enumeration of any registered mortgages or
certificates of mortgage affecting the ships or shares in
respect of which such certificates are given (>•).
Every mortgage whicli is so registered shall . have a
(/.) Keith V. Burrows, 1 C. V. J), "fl-l; 2 C. P. D. 160; 2 App. Cas.
63G; 46 L. J., C. P. 801.
(0 Ibid., 2 C. P. D. 163.
{»i) Wilson V. Wilson, L. R., 14 Eq. 32 ; Kcilli v. Burrows, supra ;
Brown V. Tanner, L. R., 5 Ch. 597.
(n) l)e Mattos v. Gibson, 1 Jo. & H. 79.
(o) Ibid.
\p) Sect. 72.
(//) Sect. 76.
(/•) Sect. 79.
SHIPS. 187
priority over all mortgages of tlie same sliip or share
created subsequently to the date of the entry of the certi-
ficate in the register book ; and if there be more mortgages
than are so indorsed, the respective mortgagees claiming
thereunder shall, notwithstanding any express, implied or
constructive notice be entitled one before the other accord-
ing to the date at which a record of each instrument is
indorsed on the certificate (.s).
By 25 & 26 Vict. c. 63, s. 3, equities may be enforced
against owners and mortgagees of ships in respect of their
interest therein in the same manner as equities may be
enforced against them in respect of any other personal
property (/).
So an owner of a ship executing an absolute transfer of
his interest therein is not precluded from showing that the
legal intention was to give the transferee only a" secmity
by way of mortgage {if). Equitable mortgages of ships
are, therefore, valid without registration, as against all
persons except registered transferees and mortgagees (r).
The deposit of a builder's certificate of an unfui'nished
ship by way of security creates an equitable mortgage [x],
as also does the deposit of a registered mortgage (y). In
the case of a mortgage of a ship or cargo notice should be
given to the master or consignee {z).
Mortgages of future freight or of cargo to be acquired
during a voyage may be made (a), but notice should be
sent to the master {b).
As there is no doubt that a person may give an effectual
security upon property of his at sea, before it has come to
(«) Sect. 80.
{t) Union Bank of Loudon v. Lenanton, 3 C. P. D. 243 ; 47 L. J., C. P.
409.
(«) WardY. Peel; 13 C. B., N. S. 668; 32 L. J., C. P. 113; see also
The Cathcart, L. R., 1 Eq. 314.
(i) Htuplcton V. Hayman, 2 H. & C. 918 ; 33 L. J., Ex. 17.
(;r) Ex parte Sodgkins, L. R., 20 Eq. 746.
(V) Lacon v. Liffcn, 32 L. J., Ch. 25.
(;) Langton v. Horton, 1 Hare, 549.
(a) Gardner v. Zachlan, 4 M. & C. 129 ; Leslie v. Guthrie, 1 Scott, 683. ,
[b] Layton v. Horton, 1 Hare, 549.
188 DEPOSIT OF SECURITIES AGAINST ADVANCES.
hand, so lie may also pledge a policy of marine insurance
with another person or with bankers, and they, if duo
notice has been given to the underwriters or insurance
company, will be entitled to receive the principal sum
insured, upon the event insured against happening.
On change of 0)1 Change of Firm. — The question may frequently arise,
in practical banking, as to the effect of a change of firm
upon a security deposited with the bank before the altera-
tion. The following case will tend to explain the position
of the bank in such circumstances : —
A. deposited with a bank, by way of security for ad-
vances, a joint and several promissory note, made payable
to order on demand with interest, whereby A. and B.
promised to pay on demand Pease and others and B. II.,
or order, 300/., with interest. A. paid interest regularly.
At one time he had a balance in the bankers' hands ex-
ceeding the amount of the note. After the note was
deposited the firm changed ; the Court held —
1. The note being a continuing security, inasmuch as it
was made payable to order, might be indorsed, notwith-
standing the change in the banking firm.
2. The note not having been indorsed, the original
payees, being a partnership, or the survivors of them, were
the proper parties to sue upon it.
3. The note was not discharged, by the fact of A.'s
having, at one time, since the deposit of it, in the bankers'
hands, a balance exceeding its amount (c).
Whenever, therefore, bankers take a security of this
kind, it is indispensable for their secmity, either that they
indorse the note within the six years from its date, or that
they put it in suit within that time, or that they take care
that the interest is regularly paid upon it, in order to make
it effectual as a security, and guard themselves against
loss.
• {c) Pease V. Uirst, 10 B. & C. 122. Sec Uartland y. Jtths, 1 II. & C.
667.
ON CHANGE OF FIRM. 189
A customer deposited the title deeds of a copyhold
estate with his bankers, the deposit being agreed to be as
a security, not only for a sum already advanced by the
bankers to him, but also for any other sums of money
which might be afterwards advanced by the firm. After-
wards, one of the firm died, and another person was after-
wards added to the firm, every thing else remaining the
same as before in the relations of the customer to the
firm. About six years elapsed, when iifiat in bankruptcy
issued against the depositor, and it became a question
whether the deposit enured to the benefit of the new
firm : — it was held that it did so ; for the circumstances
amounted to a tacit acknowledgment, that the deeds were
deposited with the new firm on the same terms as they had
been with the old one {d). It may, probably, now be laid
down with confidence, that the continuance of the same
modes of dealing with the new firm as with the old, and
the continuance of the deposit in the hands of the new
fimi, will be construed into a tacit recognition by the de-
positor, that the new hold the deeds for the like object and
purpose as the old one did, and stand in the same relation
to him. Nevertheless, in practice, it is desirable for bankers,
in order to avoid all questions, as to whether a sufficient
period has elapsed to enable the Court to say that the in-
tention of the depositor was clearly manifested, and to make
it quite certain that he was aware of the change, &c,, to '
have a fresh memorandum of deposit made, in order to
secure the new firm.
Two traders, in partnership, having had for many years
an account with a bank, deposited with them certain title
deeds of an estate belonging to one of the partners sepa-
rately, as a security for the balance which might be due to
the bank from the firm, from time to time, upon the ac-
count current. No written memorandum was at that time
[il) Ex parte Kensington, 2 Vcs. & B. 79, 83 ; Ex parte Oakes, 2 M., D.
& De G. 234 ; Ex parte Smith, 2 M., D. & De G. 314. Sec 19 & 20 Vict,
c. 97, s. 4.
190 DEPOSIT OF SECURITIES AGAINST ADVANCES.
made of the object of the deposit ; but afterwards, upon a
further advance by the bank, the owner of the title deeds
signed a letter or memorandum stating the deposit to be
for securing that as well as future advances. The banking
firm had undergone some changes in its members after the
deposit was made, and, in point of fact, all the advances
made by the banking firm with whom the deposit was
made had been paid off by the traders ; but fresh advances
were made by the new banking firm, who continued to
hold the deeds : it was, nevertheless, held that the security
was a continuing security, and that the banking firm was
equitable mortgagee of the estate to the amount of their
advances {e).
Release and Return of Securities. — Where a mortgage is
made to several persons jointly they are in equity con-
sidered as tenants in common of the mortgage money, and
in case of the death of any one of them before the debt is
paid off the survivors cannot give a good discharge for the
debt without the concurrence of the representative of the
deceased (/).
A banker holding securities, which have been deposited
with him by way of equitable mortgage, must deliver up
the securities upon being paid the amount covered by the
deposit (r/).
{<') Ex parte Smith, 2 M., D. & Du G. 311.
(/) VicJccrs V. Cowell, 1 Beav. 529 ; overruling Brdshr v. IFudHon, 9
Sim. 1.
{(/) Fj- parte Adair, In re Gross, 24 L. T., N. S. 198.
( 191 )
CHAPTEE XX.
DEPOSIT OF SECURITIES FOR SAFE CUSTODY.
It is the custom of bankers to receive and to keep for the
accommodation and convenience of their customers boxes
of plate, jewels, -wills, deeds and securities, and as no
charge is ever made for their custody, they are gratuitous
deposits; the bankers, therefore, are only bound to take
ordinary care of them, and if they are stolen by a clerk
or servant, employed about the bank, the bankers -will
not be responsible, unless they have knowingly hired or
retained in their service a dishonest servant. Securities
are also deposited with the bankers for the collection of
the dividends or interest payable upon them, for which
sometimes they charge a commission. But whether the
bankers receive any consideration or not, or whether they
are gratuitous bailees or bailees for reward, the test of
their liability in the case of the loss of securities entrusted
to their charge will be, have they exercised that degree
of ordinary diligence which men of common prudence
generally exercise about their affairs (ci).
The following decisions illustrate the extent and measure
of their liability : —
In an action for damages against bankers as bailees for
the negligent keeping of some railway debentures placed
(a) Addison on Contracts, p. 632, 7th edit. A gratuitous bailee, in
Coffgs V. Barnard, and othei? old cases, "was said to be liable only for gross
negligence. If gross negligence means " greater negligence than the ab-
sence of ordinary care implies, and is such a degree of negligence as
excludes the loosest degree of care, and which almost amounts to fraud, ' '
as defined by Erie, C. J., in ChashUl v. Wright (6 E. & B. 899), these
cases undoubtedly conflict mth the above statement of the law, and the
degree of care to be used by a gratuitous bailee, and one for reward
would not be the same. Whatever is meant by the word "gross," the
present editor submits that a less amount of care is due from a gratuitous
bailee, than from a bailee for hire.
192 DEPOSIT OF SECURITIES FOR SAFE CUSTODY.
in tlieir care by a customer, in the ordinary way of their
business as bankers, it appeared that the box containing
such securities (of which the customer retained the key)
was kept in a strong room in the bank, with the boxes of
other customers, and specie and other secm-ities belonging
to the bank. Access to this room was only obtained by
passing through a compartment where a cashier sat by
day, and a messenger slept at night. The strong room
had two iron doors, which were opened by separate keys,
which during the day were kept by the cashier who occu-
pied the compartment. One of the keys was kept at
• night by the cashier of the bank, and the other key by
another officer of the bank. Beyond this strong room
there were two other rooms, in the outer of the two un-
coined gold, and in the inner bullion and unsigned notes
were kept. The manager of the bank kept the key of the
outer of these rooms, and one of the directors of the bank
that of the inner. The owner of the box had free access
to the room where his box was deposited during banking
hours, in the presence of one of the bank clerks, when he
had occasion to take out coupons from his debentures, for
collection. While in such custody the cashier of the bank
abstracted the debentures from the box, and made away
with them. The Privy Council held, that the bankers, as
gratuitous bailees, were not bound to exercise more than
ordinary care of the deposits entrusted to them, and the
negligence for which alone they would be made liable
would have been, the want of that ordinary diligence
which a reasonably prudent man takes of his own property
of the like description. And that, consequently, there
was no negligence to render the bank liable for the loss of
the securities in question (b) .
In a subsequent case it appeared that the owner of
railway shares in two companies deposited the certificates
for safe custody with a banking company, who undertook
(A) Oiblhi V. M'MnUoi, L. E., 2 V. V. 317; 3S L. J., T. C. 25; and
see note (a) on p. 191.
DEPOSIT OF SECURITIES FOR SAFE CUSTODY. 193
to receive tlie dividends for a small commission. On re-
ceiving the certificates from the companies, he gave his
address in one instance at the office of the bank, and in the
other at a club. The manager of the bank, who had the
key of the safe where the certificates were kept, fraudu-
lently sold the shares, and forged the name of the owner
to the transfer. The companies wrote to him informing
him of the transfers, and receiving, in one instance, no
answer, and in another an answer in his name, forged by
the manager, registered the transfer. He afterwards, on
discovery of the fraud, instituted suits against the two
companies and the transferees of the shares, in which he
recovered the shares, but the Court gave him no costs.
On the banking company being wound up, he claimed to
prove against the company for the amount of his costs in
the suits which had been occasioned by their negligence ;
but the Court held, that the banking company was a bailee
for reward of the certificates, and that it had been guilty
of culpable negligence in keeping them by allowing the
manager uncontrolled access to the safe, but that the loss
of the costs was too remote a consequence of the negligence
of the company for them to be held liable for it (c),
A lady deposited with her bankers at Carlisle, for safe
custody, East India bills, specially indorsed to them by
(c) In re United Service Compmuj, E.c parte Johnston, L. R., 6 Ch. 212;
40 L. J., Chanc. 286, Lord Justice James, in delivering judgment, said :
"Now it is not every loss whicli follows the negligence of a bailee
which can be charged against the bailee. If these costs had been the
costs of a simple detinue, brought for the recovery of possession of these
documents, it may possibly be that the bank would have been liable for
them. But these smts are for the rectitication of the registers of the
railway companies, so as to restore the rightful o-mier to those registers,
and enable him to receive the dividends. Now the causa causans which
rendered these suits necessary was the forgcrj-. The possession of the
certificates no doubt facilitated the forgerj', and was one of the means by
which it was can-ied into effect ; but the consequence of the forgery was
hardly one against which the bailor could be held to have been warranted
by the bailee. The case may be tested by analogy. Suppose a key to be
in the possession of a bailee, and to be lost by him, so that a burglar
obtains possession of it, who steals property to which the key was the
means of access, it could hardly be said that the bailee would be respon-
sible for the whole loss thus sustained. So here it can hardly be said
that the chancery suits were the necessary consequence of the negligence
by which the certificates were lost.''
o. o
194 DEPOSIT OF SECURITIES FOR SAFE CUSTOnV.
her, with instructions to receive the amount when due.
These bills are not negotiable in the market, like common
bills of exchange, and would, therefore, in the ordinary
course, have been only deposited with her bankers for
greater security. The balance of her account, exclusive
of the amount of the bills, was in her favour, and con-
tinued so up to the bankruptcy of the bankers. They
charged discount on the bills in their account with her,
and she might have drawn on them for their amount ;
it being the custom of the bankers of Carlisle to con-
sider ordinary bills so deposited, as cash. The bankers
paid away the bills to a creditor, with whom the assignees
afterwards settled an account, charging him with the
amount of the bills, and receiving from him the balance
due to the estate. Held, that the bankers had acted in
violation of the directions under which the bills were
deposited, and that the customer was entitled to be reim-
bursed the whole amount of the bills from the assignees {d).
It would not have made any difference if the' account had
been overdrawn at the time the bankers disposed of the
bills, because when bills are remitted to a person for a
specific purpose, he is bound to perform that purpose, or
return the securities ; if he receives the amount contrary
to the directions of the remitter, he cannot apply it to the
payment of his o^vn debt ; consequently, if the account
had been overdrawn, it would not have been an excuse
for the bankers to say, they had sold or discounted the
bills, or paid them away, and carried the amount to the
customer's account, and applied it in reduction of her
debt to them (r).
The criminal liability attaching to bankers, disposing
of or misappropriating securities entrusted to their care,
is treated in a subsequent chapter (/).
{(I) Ex parte Bond, 1 M., D. & De G. 10.
(«) Ibid. ; Ex parte Brown, 3 Deac. 91, -which case also recog-ni/es the
principle that bills roniitted, clothed with a trust, do not pass to the
assignees on the bankruptcy of the recipients.
(/} I'ost, Chapter on Ckimixal Liability of Bankeks.
( 195 )
CHAPTER XXI.
THE customer's PASS BOOK AND ACCOUNT,
The course of banking business in London makes the Passbook,
only general mode of stating and adjusting accounts be-
tween bankers and tbeir customers, residing in or near the
metropolis, to be as follows : —
A book, called a pass book, is delivered by the bankers
to the customer, in which at the head of the first page, and
there only, the bankers by the name of their firm are de-
scribed as the debtor, and the customer as the creditor in
the account ; on the debtor side are entered all sums paid
to or received by the bankers on account of the customer,
and on the credit side all sums paid to him or on his ac-
count, and these entries being summed up at the bottom
of each page, the amount of each, or the balance between
them, is carried over to the next folio without further men-
tion of the names of the parties, until the book being full,
it becomes necessary to deliver a fresh one to the customer.
For the purpose of having the book made up by the bankers
from their own books of account, the customer returns it
to them from time to time ; and, the proper entries being
made by them up to the day on which it is left for that
purpose, they hand it again to the customer, who thereupon
may examine it, and if there appears any error or omission
it is his business to send it back to be rectified ; if he does
not, his silence is regarded as an admission that the entries
are correct : but no other settlement, statement or delivery
of accounts, or any other transaction which can be regarded
as the closing of an old, or the opening of a new, account,
or as varying, renewing or confirming (in respect of the
persons or the parties mutually dealing) the credit given on
either side, takes place in the ordinary course of business,
() 2
196 THE customer's pass book and account.
unless when the name or firm of one of the parties is
altered, and a new account thereupon opened in the new
name or firm.
The course of business is the same between such bankers
and their customers resident at a distance from the metro-
polis, except that, to avoid the inconveniences of sending
and returning the pass book, accounts are from time to
time made out by the bankers, and transmitted to the
customer in the country, when required by him, containing
the same entries as are made in the pass book, but with
the names of the parties debtor and creditor at the head,
and with the balance struck at the foot of each account,
and his silence is regarded as a tacit admission that the
entries are correct («).
H. and C, being partners in business, were indebted to
their banker in 979/. In 1851, the banker, with the
consent of H. (C. living at a distance), transferred his
business to the Midland Banking Company, including the
account in question. The partnership account of H. and
C. commenced with this item of 979/. in the Midland
Bank books, but whilst it was open H. paid in moneys to
an amount exceeding 979/. A pass book was regularly sent
to H. In 1852, the Midland Bank gave notice to the banker
that they would not take to this account, there being in
the deed transferring the business a proviso, that, at the
expiration of twelve months as to such accounts as should
not be taken to by the Midland Bank, they should, during
a period not exceeding ten years, either accept or compel
payment, or permit the same to remain due.
An action was afterwards brought by the Midland Bank
against H. and C. to recover the balance due. But the
Court held the debt of 979/. to bo extinguished by the
payment subsequently made by II. to the credit of the
partnership account, and the assent to the appropriation to
be infeiTcd from his not objecting to the pass book, and
((/) See the custom of ilcaliug, as found by tlie master in Bevaynea v.
Noble, 1 Meriv. 635, 63G.
THE customer's PASS BOOK A>:D ACCOUNT. 197
that after such extinguishment as between the Midland
Bank and the partnership this account could not be
treated as an existing debt remaining due (b) .
A change of the title of a firm in a pass book, and
entries therein to the credit of a new firm of the interest
of securities given by the customer to the original firm, is
notice of the assignment to the new firm of the securities
given bj the customer to the old firm (c).
The pass book between a bank and a joint stock com-
pany is a good source of evidence, to show that the bank
paid to the company calls due from A. ; one of the
plaintiffs (the banking partnership) being treasurer of the
company and A. a subscriber {d) .
Credit given in a pass book binds the bankers, if on the
faith of such credit the customer has altered his position, as
by drawing on the fund, &c. ; for, by entering the sums to
the customer's credit, they lead him to suppose that they
have received them on his account ; where, however, there
has been no such alteration the banker is allowed to show
that the entries were made by mistake (), for the pass
book is only prima facie evidence against him (/).
But this is subject to the proviso, that the entries in the
pass book are properly made on each side of it ; a pass
book, with entries on one side only, is not evidence of a
settled account between the banker and the customer,
although the book is kept by the customer, without ob-
jection to the entries {(j).
If an entry is alleged to have been made by mistake in
the wrong place in a pass book by the banker's clerk, but
{b) Bealc v. Caddicl; 2 H. & N. 326.
{€) Cavendish v. Geaves, 24 Beav. 163 ; 27 L. J., Clianc. 314.
{d) Alexander v. Barker, 2 C. & J. 135. Biit a pass book is not evi-
dence that a given person was a provisional director of an abandoned
company; 16 C. B. 671.
{e) Skawx. Picton, 4 B. & C. 715; Shaw v. Bartnall, 6 B. & C. 57;
Eeane\. Rogers, 9 B. & C. 586 ; Eume v. Holland, 1 C. & M. 130 ; Skyring
V. Greenicood, 4 B. & C. 281.
(/) Commercial Bank of Scotland \. Bhind, 1 Macq. H. L. Cas. 643.
{g) Ex parte Randleson, 2 Deac. & C. 534 ; see Boardman v. Jackson, 2
Ball & B. 382.
198
THE CUSTOjNIER's PASS BOOK AND ACCOUNT.
Mode of
keeping ac-
count.
Debiting ac-
count with
costs of ac-
tion.
by the customer denied to be any mistake, the question is
for the jury upon the evidence (/?).
Making a false entry in what purports to be a pass book,
with intent to defraud, is a forgery of an accountable
receipt (/).
When accounts between banker and customer have been
carried on for a series of years on a particular footing, it
will be presumed that there was originally an agreement
to that effect, but acqidescence will not amount to a settle-
ment of account {k) . When a banker discounts the bills
of his customer, his account being overdrawn, and the
amount of the discounts is simply carried to the credit of
his account, the banker is the holder for value, though no
money has actually passed (/).
Bankers cannot debit a customer's account with the
costs of actions brought by them on bills discounted for the
customer, unless at his request, or with his consent {m) .
(k) SneadY. Williams, 9 L. T., N. S., Exch. 115.
(i) Meg. v. Smith, L. & C. 168; Reg. v. Moody, ib. 173; 24 & 25 Vict.
0. 98, s. 23.
{k) 3Iosse V. Salt, 32 Eeav. 269 ; 32 L. J., Chanc. 756.
(/) In re Careiv, 31 Beav. 39.
{))i) This Ti-as decided by Baron Martin, in a case of JIoll v. The Mer-
cantile and Exchange Bank {Limited), tried before him and a special jury,
in the sittings after Michaelmas term, November 27, 1865. It was an
action to recover compensation in damages against the defendants for
not having paid the amount of one of the plaintiff's cheques. The
defendants admitted the usual contract between banker and customer,
but said they had not sufficient money belonging to the plaintiff in their
hands applicable to the payment of the cheque. The plaintiff, Mr. Wil-
liam Holl, who carried on business in Mincing-lane, had kept a drawing
account at the bank of the defendants, and in August, 1864, they
discounted for him a bill for 99/. 15s., of which he was the di-awer, and
Messrs. Robertson & Ward were the acceptors. This bill became due in
November following, and was dishonoured. Some negotiations then took
place between the plaintiff and the manager of the bank, the residt of
which was that the defendants' solicitors, Messrs. Cotterell, issued a
writ against the acceptors. Ultimately the plaintiff made provision for
the bill, but a dispute arose as to whether ho ought to pay 21. 3s. lOd.,
the costs of Messrs. Cotterell. The defendants claimed that sum, and
debited his account with it, and the question now was, whether they had
a right to do so. It was admitted that if they had they were justified in
refusing to honour the cheque. For the defence it was stated that the
plaiutitrs account with the bank v.as opened in April, ISCM, and closed
in November following ; that it was overdrawn as many as thirtj'-scvcn
times during that period ; that complaints had been frequently made to
him about the account, and that he had been repeatedly asked to with-
THE customer's PASS BOOK AND ACCOUNT. 199
Wben a banking company has branches in different Accounts at
localities, and a customer has an account at more than one t,ranches.
branch, there is no duty on the company to keep the
accounts distinct, so as to bind it to honour cheques at a
branch where the customer has a balance in his favour, if,
on a general settlement of account, the balance is against
him, although it is the custom of the company so far to
keep the accounts separately as to refuse to honour his
cheques, except at the particular branch where the cus-
tomer has a balance in his favour. And there is no legal
obligation on a banker to give notice to his customer
that he intends to transfer a balance against the customer
from an account at one branch to an account at another
branch {)i).
Where bankers have for a long course of time charged Charging ac-
their customer interest with annual rests he is by his I'nt^esTand
acquiescence taken to have consented to that mode of keep- commission.
ing his account (o) .
When the account between a banker and his customer
is kept at compound interest, and the customer dies, the
final balance at his death, in the absence of any agreement
to the contrary, carries no interest (/;). So when the
draw it. It -was also said that he called at the bank, and asked the
manager to sue the acceptors upon the bill in question ; and that on a
subsequent occasion he had been told that the solicitors' costs would be
debited to his account. Tlie manager, who was called, admitted that
when he gave this intimation to the plaintiff, the plaintiff did not say
he would consent to such a course ; but he (the manager) said it was the
usual practice amongst bankers to debit a customer's account with costs
incurred under similar circumstances. Baron Martin said it was a prac-
tice which ought to be stopped. A bank had no right to debit a man's
account with a charge of this kind against his will. The witness added
that the bank had not actually put the money in the hands of Messrs.
Cotterell, but had placed it to the credit of their account with the bank.
On the part of the defendants, it was submitted that the plaintiff had
sustained no real damage by the refusal to pay the cheque, and that a
farthing damages would be sufficient to meet the justice of the case. On
the other hand, it was contended that the credit of the plaintiff had been
seriously injured, and commented severely on the conduct of the defen-
dants in vindictively bringing before the public the state of his account
with them. The jury found a verdict for the plaintiff— damages, 51.
(w) Garnctt v. M'Xeivan, L. R., 8 Exch. 14 ; 42 L. J., Exch. 1; Frince
V. Oriental Bank, L. E,., 3 App. Ca. 325 ; 47 L. J., P. C. 42.
(o) Cross/del v. .Bourr, 32 Beav. 86 ; 32 L. J , Chanc. 540.
(p) Ibid.
200 THE customer's pass book and account.
"balance is in the favour of the customer, and the banker
dies, or ceases to carry on business, or becomes bank-
rupt (/;).
When a mortgage secuiity is given by a customer to his
bankers for a fixed sum, and not in respect of a running
balance, the banker is not entitled to include that sum in
the banking account, and charge compound interest (q).
Bankers having a mortgage security and a banking ac-
count with their customer, in ascertaining the amount due
between them, the accounts must in the first instance be
taken separately, and on different principles (q) .
A customer being indebted to his bankers upon an
account current, upon which compound interest had ac-
cording to custom been charged by the bankers, executed
a mortgage to them, to secure the amount of the current
account. The customer afterwards executed a creditors'
deed of w'hich the bankers were appointed the trustees,
and from that time he ceased to draw upon or pay money
into the account : it was held, that the bankers were only
entitled to simple interest from the date of the deed upon
the balance due (r).
A banking account which was largely overdrawn, was
for the half-year ending June, 18G7, charged with interest
at 51. per cent., and with a gross sum of 500/. for commis-
sion, in lieu of the charge of one-half per cent. pre\-iously
made. The pass book balanced on this footing was sent
to the customer, and the charges were explained to his
agent (the customer himself being in weak health, and
unable to attend to business matters) . The customer, who
died in December, 1867, had not raised any objection to
these charges. Now as the charge of 500/. for commission
(p) CrossUll V. Bower, 32 Beav. 8C ; 32 L. J., Chanc. 540.
(7) Mossc V. Salt, 32 Beav. 269; 32 L. J., Chanc. 756.
(;•) Cross/cill V. Bower, 32 Beav. 269; 32 L. J., Chanc. 640. It is the
custom amongst bankers, finance companies, and otliers who lend money
or stock for railway deposits, and execute treasury bonds, that in the case
of a deposit of stock an annual commission is charged, in addition to the
dividends accruing thereon ; and in the case of a bond, a premium is paid
to the bondsman, either in one sum, or in the form of an annual paj-ment.
Amn., 18 W. R. 996.
THE customer's PASS BOOK AND ACCOUNT. 201
had been acquiesced in, it was valid for the half-year end-
ing June, 1867, but acquiescence could not be inferred for
subsequent half-years, there being nothing in the entry for
the particular half-year that amounted to a contract to the
eanie effect in futui-o (s). The right of the bank to charge
compound interest terminated with the death of the cus-
tomer ; and from that period simple interest only at 5/. per
cent, was chargeable on the account («).
Though in discounting bills and making loans for short Deduction of
periods bankers do not usually deduct income tax, jet in ^^^come tax.
a mortgage transaction with theu' customers they are bound
to allow income tax (t).
The liability of bankers on dishonouring the cheques of
their customers is treated in a previous chapter (?/).
(*•) Williamson v. TTiUiamson , L. R., 7 Eq. .542.
\t) Mosi) Caton V. Caioii, L. 11., 2 II. L. 127.
{(■) Mossitcr V. Miller, L. R., 3 App. Cas. 1124.
{d) Harris v. Vmables, L. R., 7 Ex. 256 ; IFyniic v. Hughes, 21 W. E
628, E.x.
ON CHANGE OF FIRM. 203
upon any bills, &o., made j)ayable at the banking bouse of
the copartnership, does not bind the obligor, after the
death of one of the partners, nor cover future advances
made after such death and the taking in of another
partner ; and the customer, who, at the time of the death,
was indebted to the house, having afterwards paid off the
balance incurred previously to the death, the obligor was
wholly discharged (e ) .
There is no doubt, however, that a guarantie might
have been drawn in such terms as to serve as a continuing
indemnity to the house, whatever might be the change of
partners, if such intention appeared from the language
used(/). The Courts, both of equity (^) and common
law (Ii), appear to lean against increasing the liability of
a guarantor to a banking firm in this respect. This prin-
ciple of construction, narrowing the liability of a surety
when the advances to be secured are to be made to a
firm, arises quite as strongly from the nature of the
transaction itself; for it is obviously an assumption to
conclude that a party guarantees advances to A. and B.,
because he is willing to guarantee advances to A., B. and 0. .
And since the decisions, which established this principle,
the Legislature appears to have ratified and confirmed it,
by enacting as follows (/) : —
"No promise to answer for the debt, default or mis-
carriage of another made to a firm, consisting of two or
more persons, or to a single person trading under the name
of a firm, and no promise to answer for the debt, default,
or miscarriage of a firm, consisting of two or more persons,
or of a single person, trading under the name of a firm,
shall be binding on the person making such promise in
respect of anything done or omitted to be done, after a
change shall have taken place in any one or more of the
(e) Strange v. Lee, 3 East, 484; S. P., TFesion v. Barton, 4 Taunt. 67.
(/) See form in IJarIc v. O/lver, 2 Exch. 71, 72.
(ff) Pcnibcrtun v. Oakcs, 4 Euss. 154.
(h) Chapman v. Bcckinr/ton, 3 Q. B. 703.
(0 19 & 20 Vict. c. 07, s. 4.
204 GUARANTIES TO SECURE ADVANCES.
persons constituting the firm, or in the person trading
under the name of a firm, unless the intention of the
parties, that such promise shall continue to be binding
notwithstanding such change, shall appear either by express
stipulation, or by necessary implication, from the nature of
the firm or otherwise."
Since this statute, therefore, guaranties may either ex-
pressly stipulate for the continuance of the undertaking,
(when the intention is that it should continue,) notwith-
standing changes in the firm ; or if the parties choose to
take upon themselves the risk of determining that the firm
is of such a nature as necessarily to imply the continuance
of the guarantie, notwithstanding the change, they may
do so, and need not insert an express provision to that
effect ; and so they need not insert an express provision,
if they choose to incur the risk of proving aliunde this to
have been the intention ; but it is manifestly the safe and
most convenient course in all cases to insert an express
stipulation for the continuance of the instrument, notwith-
standing any change in the constitution of the firm.
Continuing Continuing Guarantee as to Amount a)id Time. — Whether
^araourTt^^ the liability of a surety is or is not a continuing one as to
and time. amount, (that is to say, whether it is limited to a particular
debt, or extending to a series of debts,) or time, or both,
is simply a question of construction, and is to be gathered
from the instrument containing the guarantie or the cir-
cumstances of each particular case. In Coles v. Pack («'),
the following words were held to constitute a continuing
guarantie as regards both amount and time. " Now I
do hereby, in consideration of your forbearing to take
immediate steps for the recovery of the said sum, gua-
rantee payment of and agree to become responsible for
any sum of money for the time being due from F. to you,
whether in addition to the said sum or not."
(t) L. R., 5 C. P. 65.
CONTINUING GUARANTEE AS TO AMOUNT AND TIME. 205
So, where a father gave his son a promissory note for
2,000/., which was indorsed by the son, and discounted by
a banking company, who took from the father an agree-
ment under seal, that in consideration of its discounting
the note, certain deeds of the father's deposited at the
same time should remain a security for all money due or
to become due from the son to the company on any
account whatsoever, and at the date of the agreement the
son owed the company 3,000/. upon a running account,
and the amount was subsequently increased to 5,000/., the
agreement was considered to be a continuing guarantie,
and the bank was held to be entitled to prove against the
father's estate, not only for the 2,000/., the amount of the
note, but for all sums due to them from the son (k) .
A debtor and his surety executed a joint and several
bond for 14,000/. conditioned for avoidance if they or
either of them should in satisfaction of the debt of 7,000/.
then due from the debtor to the obligee pay the 7,000/.,
with a proviso that the surety should not be liable under
the bond for a sum or sums exceeding altogether in debt
or damages 1,300/. The debtor having paid 1,000/., part
of the debt, and then filed a petition for liquidation, the
obligee proved for and received a dividend of 9s. 2d. in the
pound on 6,000/. under the liquidation. After deducting
from the 7,000/. the 1,000/. and the dividend, there re-
mained more than 1,300/. due. The obligee having
brought an action on the bond against the surety to recover
1,300/., the surety contended that he was entitled to deduct
from the 1,300/. a rateable proportion of the dividend,
viz., 9s. 2d. in the pound on 1,300/., and was only liable
for the balance : — Held, that the intention of the bond
was that the surety should guarantee the whole 7,000/.,
though his liability was limited to 1,300/. ; that he was,
therefore, not entitled to deduct a rateable proportion of
the dividend, but was liable for the whole 1,300/. And in
(A) Binyess v. Eve, 41 L. J., Chanc. 515 ; L. E., 13 Eq. 450.
206 GUARANTIES TO SECURE ADVANCES.
the same case it was laid down that when a surety gives
a continuing guarantie, limited in amount, to secure the
floating balance which may from time to time be due from
the principal to the creditor, the guarantie is, as between
the surety and the creditor, to be construed {prhnd fade at
least) as applicable to a part only of the debt co-extensive
with the amount of the guarantie. But a guarantie
limited in amount for a debt already ascertained, which
exceeds that limit, is not xirlma facie to be construed as a
security for part of the debt only {T) .
A surety bound himself jointly to a banking company
in 500/., the condition of the bond being that if the
obligors should from time to time pay all and every such
sum or sums of money as should become due to the bank
for money advanced to surety's co-obligor, and pay interest
at 51. per cent, per annum for such sum or sums of money
as aforesaid, to be computed as is usual with the banking
company in ordinary banking accounts with them, and also
the lawful commission, charges or expenses incident to, or
occasioned by, the transactions or matters between the
bank and the co-obligor, and shoidd indemnify and save
harmless the banking company from all actions, suits and
expenses, and all liability whatsoever, by reason of the
transactions and matters, then the bond was to be void ;
provided that the principal moneys to be ultimately re-
covered on the bond were thereby limited not to exceed
250/., and that the obligors or any of them should not be
liable to pay, by virtue thereof, any greater principal sum
than 250/. ; but that the bond should be a continuing
security to that amount, for the sums from time to time
owing as aforesaid, exclusive of interest (to be computed
as aforesaid), commission, cost, charges and expenses;
held, that the surety was liable on this bond only for
250/. principal moneys advanced, and interest accrued
(0 Ellis V. Emmamiel, 1 Ex. D. 157 ; 46 L. J., Ex. 25 ; 34 L. T. 553 ;
24 W. R. 832. See also Ex parte Midland Bankim/ Co., 38 L. T. 395 ;
Morrell v. Cou-an, 7 Ch. D. 151; HeJIidd v. Meadows', L. E., 3 C. P. 595;
Woody. Friesiner, L. R., 2 Ex. CG, 282.
CONTINUING GUARA^^TEE AS TO AMOUNT AND TIME. 207
upon that sum; but not for any further principal sum
advanced by the bank {m) .
It would appear that where there is a continuing Revocation,
guarantie for advances from time to time to be made
to another person, the guarantie can be determined by
the guarantor at any time, subject to the payment of
anything then due under it(«). Thus a guarantie for
the space of twelve months for the due payment of all
such bills as A. might discount for D. & Co., to the
extent of 600/., may be revoked and countermanded by
a notice given dui^iag the twelve months, although some
discount may have been made and repaid before the
notice (o). This right to revoke proceeds on the principle
that each advance constitutes a separate consideration, and
that under such a guarantie the advances are not made in
pursuance of a request made once and for aU by the party
who gives the guarantie, but in pursuance of a request sup-
posed to be made by him from time to time as the advances
are made, and that if before any particular advance is
made the person giving the guarantie informs the person
making the advance that he withdraws the guarantie, the
advance is not made at his request, and he, therefore, is not
liable for it [p]. Where, on the other hand, the considera-
tion is not fragmentary but entire, as in the case of a per-
son giving a guarantee to a firm that he will be responsible
for the fidelity of some third party in consideration of
their receiving him into their employ, there, inasmuch as
the consideration for the guarantie, is given once and for
all, it cannot be revoked at will, but must continue until
the services are ended ((/), — save only in the case where the .
(w) Meek v. jrallis, 27 L. T. 650.
(«) Burgess v. Eve, L. R., 13 Eq. 450.
(o) Offord V. Bavies, 31 L. J., C. P. 319 ; 12 C. B., N. S. 748 ; Bradlury
V. Morgan, 31 L. J., Ex. 462. Such a guarantie would, it seems, be
revoked by death; Harris v. Fawcctt, L. R., 8 Ch. 866; 42 L. J.,
Chanc. 502 ; Coulthart v. Chmentson, 5 Q. B. D. 44, 46 ; Lloyd's v.
Harper, 16 Ch. D. 290, 314.
{p) See judgment of Cotton, L. J., in Lloyd's v. Harper, supra, p. 318.
[q] Nor is such a guarantie revoked by notice of the death of the
guarantor ; Lloyd's v. Harper, supra ; Culvert v. Gordon, 3 Man. & Ry. 124.
208
GUARANTIES TO SECURE ADVANCES.
Appropria-
tion.
employe has been guilty of dishonesty, when the surety,
after giving notice to the employer, is entitled to withdraw
from his guarantie, and to relieve himself from any further
liability (/•).
Again, as may be seen from the following case, a con-
tinuing guarantie may be discharged by an appropriation
of funds of the surety in the hands of the creditor.
A. & Co., bankers, advanced 2,000/. to B., a customer,
by placing it to the credit of his general current account,
and took as security a series of ten promissory notes,
maturing at the rate of one per week during a period of
ten weeks. C, as security for B., gave a written under-
taking that, if the notes were not paid, he would secure
the debt by a mortgage upon property of his own. Moneys
were paid into B.'s account more than sufficient to meet
the notes if they had been so applied, but as the account
was at the same time largely drawn upon, it was at the
dates of the maturing of the notes constantly overdrawn : — •
Held, that A. & Co., having received moneys which they
might have applied to the satisfaction of the notes, were
bound so to have applied them to the relief of the surety
before apj^lying them to the liquidation of the current ac-
count, and that the surety was consequently discharged («).
Discharge of
surety.
SURETYSHIP GENERALLY.
Discharge of Suretij — By Variation of Agreement. — The
rule as to the effect of a variation of the original agreement
between the principals in discharging the surety has in a
recent case been stated to be as follows. If there is any
agreement between the principals with reference to the
contract guaranteed, the surety ought to be consulted, and
if he has not consented to the alteration, although in
cases where it is without inquiry evident that the alteration
(/•) Burgess v. Eve, supra; rhUllps v. Foxall, L. R., 7 Q. B. C66, 678;
Sanderson v. Aston, L. II., 8 Ex. 73.
(v) Kinnaird v. Wvhstcr, 10 Cli. D. 139 ; 48 L. J., Clianc. 348 ; 39 L. T.
494 ; 27 \V. R. 212. See also Browning v. Baldwin, 40 L. T. 248.
TIME OR INDULGENCE GIVEN TO PRINCIPAL. 209
is unsubstantial, or that it cannot be otherwise than bene-
ficial to the surety, the surety may not be discharged,
yet, if it is not self-evident that the alteration is unsub-
stantial, or one which cannot be prejudicial to the surety,
the court will not, in an action against the surety, go into
an inquiry as to the effect of the alteration, or allow the
question, whether the surety is discharged or not, to be
determined by the finding of a jury as to the materiality
of the alteration or on the question whether it is to the
prejudice of the surety, but will hold that in such a case
the surety himself must be the sole judge whether or not
he will consent to remain liable notwithstanding the alte-
ration, and that if he has not so consented he will be dis-
charged [f] .
Time or Indnlgcnce oiven to Principal. — Where the ere- Time or iu-
ditor has entered into a binding contract to give the prin- ^.J^fn to^
cipal debtor further time without the consent of the surety, principal,
the sm-ety is discharged, provided the creditor has not, as
he may do, expressly reserved his rights against him [n).
The following case will exemplify this : —
"W. Jones gave the follov/ing guarantie to a bank, on
behalf of Henry Bowers :
"HJENEY BowEEs' Mill AccottNT.
" Please to open an account with, and honour the cheques of, Mr. H,
Bowers on ' mill account ' for whom I will be responsible.
" Carmarthen, Jai/uari/ 4, 1825. " W. Jones."
{t) Per Cotton, L. J., in llohne v. Br'ms'kill, 3 Q. B. D. 49.j, iu which
case, however, Brett, L. J.., disagreed as to the effect of the non-
materiality of the alteration, saying — "The surety is discharged where
there has been a material alteration of some specific provision of the
agreement, but not otherwise." See also Sanderson v. Acton, L. R.,
8 Ex. 73; 42 L. J., Ei. 621 ; Wilson v. Lloyd, L. K., IG Eq. CO ; Folak
T. JEveritt, 1 Q. B. D. 669 ; 46 L. J., Q. B. 218.
{n) Davci/ v. Prendcrgrass, 5 B. & A. 187 ; Black v. Ottoman BanJc, 15
Moore, P. C. 472 ; Boulor v. Mayor, 19 C. B., N. S. 76 ; Overend, Gurney
% Co. y. Oriental Financial Corporation, L. R., 7 H. L. Cas. 348 ; Swire v.
Bedman, L. E., 1 Q. B. D. 536 ; Maingay y. Lewis, 5 Ir. R., C. L. 220,
Ex. To reserve a creditor's right against a surety there must be a dis-
tinct expression of intention to reserve it. Overend, Gurney ^- Co. v.
Oriental Financial Corporation, supra; Muir v. Craicford, L. R., 2 H. L.
Cas. Sc. 456 ; Ex parte Charlton, 36 L. T. 561.
G. P
210 GUARANTIES TO SECURE ADVANCES.
W. Jones was an attorney, and the professional adviser
of the bankers, and, at the time, had a hanking account
with them. The bankers, upon receiving the document,
opened an account with Bowers, and made various ad-
vances to him up to February, 1827, when they ceased to
advance to him. It was the course of business of the
banking-house occasionally to take the acceptance of their
customers for the balance appearing to be due on the face
of their accounts, which were termed corers ; and the same
was also shown to be the practice of a neighbouring bank.
Jones was proved to have sometimes been consulted by
the bankers, as their professional adviser, with respect to
these acceptances ; but it was not proved that he had per-
sonally any knowledge of the practice to require these bills
as covers for overdrawn accounts.
In February, 1828, without Jones's knovdedge or con-
sent, the bankers took Bowers's acceptance, at three
months, for the amount of their balance against him, and
this bill was carried to the credit of his account, but was
dishonoured at maturity.
In 1832, the bankers became bankrupt, and in an action
by their assignees against Jones, commenced in 1833, it
v/as adjudged that the bankers, by taking the acceptance,
had given time to Bowers, the principal, and thereby had
discharged Jones, the guarantor or surety (,r).
Where a surety guarantees a series of payments to be
made at stated periods, and time is given to the principal
debtor in respect of one payment by a binding agreement,
the surety is discharged from liability in respect of that
payment, but not in respect of future payments (/y) .
The acceptance by a bank of a fresh security without
any binding engagement by them to give time to A., does
not discharge the surety {z) .
{x) JTowcU V, Jones, 1 C. M. & R. 97. See also Uvans v. I}remridffC,
25 L. J., Chanc. 102.
{>/) Croydon Commercial Gas ^ Colce Company v. Dickinson S; FoUaril,
L. R, 2 C. P. D. 4G ; 4G L. J., C. P. 157.
(z) Bell V. Banlcs, 3 M. & U. 258. See 7 H. L. Cas. 348, infra; Sioire
V. Redman, 1 Q. B. D. 530.
NON-DISCLOSURE AND FRAUDULENT CONCEALMENT. 211
Again, if tliere are two co-sureties and a further loan is
made by the creditor to the principal, and the creditor
takes an additional security for that and the former loan,
and gives fuiiher time to the principal and one of the
sureties, the other is discharged {a). And if, after a right
of action has accrued to the creditor against two or more
persons, he is informed that one of them is a surety only,
and after that he gives times to the principal debtor with-
out the consent of the surety, the rule as to the release of
the surety equally applies {b)
An agreement with a third person to give further time
to the principal debtor will not discharge the surety (c).
In equity it was held that a surety was released in the
case of a debt due under seal by a mere verbal agreement
to give further time {d) ; and since the 17 & 18 Yict. c. 83,
such an agreement has been made capable of being set up
by way of equitable defence.
Non-disclosure and Fraudulent Conecahnent. — As to how By non-
far a person receiving a guarantie is bound to disclose the frauduieut^^'
v/hole previous dealings between himself and his principal concealment,
debtor, the law is found thus stated by Mr. Justice Fry in
Davies v. London and Provincial Marine Assurance Co. (e) :
"It has been argued here that the contract between
the surety and the creditor is one of those contracts which
I have spoken of as being iiherrinue fidci^ and it has been
said that such a contract can only be upheld in the case
of there being the fullest disclosure by the intending cre-
ditor. I do not think that that proposition is sound in
law. I think that, on the contrary, that contract is one
in which there is no universal obligation to make dis-
closure ; and therefore I shall not determine this case on
{a) Vyner v. ITophins, 6 Jur. 889, per Brace, V.-C.
{b) Per Lord Cairns, in Overend, Gimicy % Co. v. Orlcnlal Tlnanclid Cor'
poralion, L. 11., 7 H. L. Gas. 348, 360.
(c) Frascr v. Jordan, 8 E. & B. 303.
{d) See Davei/ v. Frendergrass, 5 B. & Aid. 187, 192.
[c) 8 Ch. D. 4G9, 475.
p2
212 GUARANTIES TO SECURE ADVANCES.
that view. But I do think that the contract of suretyship
is, as expressed by Lord "Westbury in Williams v. Bayley (d),
one which ' should be based upon the free and voluntary
agency of the individual who enters into it.' I think that
principle especially applicable here, because there is no
consideration in this case, as in many cases of suretyship,
for the contract so entered into ; and, therefore, I think,
to use the language of Lord Eldon, in Turner v. Harvey (e),
it is a contract in respect of which a very little is sufficient.
Very little said, which ought not to have been said, and
very little not said which ought to have been said, would
be sufficient to prevent the contract being valid. It is
one, furthermore, in which I think that everything like
pressure used by the intending creditor will have a very
serious effect on the validity of the contract ; and the case
is stronger where that pressure is the result of maintaining
a false conclusion in the mind of the person pressed." Tho
officers of a company, believing that the retention of money
by one of their agents amounted to felony, directed his
arrest. Certain friends of his came to the officers of the
company and proposed to deposit a sum of money by way
of security for any dej&ciency. On the same day the com-
pany was advised that the act of the agent did not amount
to felony, and the directions for the arrest were with-
drawn. Later in that day the friends of the agent had
a second interview with the officers of the company, and
agreed to deposit a sum of money as security for his de-
fault, no mention being made of the withdrawal of the
directions for the arrest. The sum of money was after-
wards deposited with trustees on an agreement for the
security of the company. And it was held that the change
of circumstances ought to have been stated to the intending
sureties, and that tho agreement was to bo rescinded, and
the monies returned to the sureties (/).
{d) L. R., 1 H. L. Cas. 200, 219.
{e) Jac. 169.
(/) 8 Cli. D. 469, 173. Sec also Xvrth Britkh Insurance Company V.
Zhyd, 10 Exch. 523.
RELEASE OF SURETY TO THE EXTENT OF SECURITIES. 213
Certain bankers advanced 2,600/. to A. upon the security
of an indenture of mortgage to tliem of certain property
of A., and also of a joint and several promissory note
of the same date as the deed, in which a third party
joined with A. as sm'cty. At the time of this advance A.,
who had long been a customer, owed them SOOi'., and it
was arranged between him and the bankers, that this sum
should be deducted from the 2,600/, but neither by the
recital in the mortgage deed or otherwise was the surety
apprised that such was the ease, and that recital moreover
expressly, but falsely, stated that the entire interest in a
1,500/. policy of assm-ance, ah-eady deposited with the
bankers, would, inasmuch as the 800/. had been repaid to
the bankers, be available as collateral security for the
2,600/. The mortgage deed was prepared by the bankers'
solicitor, and read over in his office to the surety and A.
previously to its execution and to the surety's signature
of the promissory note. The circumstances were held to
constitute such a fraud in law as released the surety,
although it was not suggested that any intentional fraud
was imputable to the bankers personally {g).
jBu the Creditor^ iahincj Securities. — Thus it is a rule By tliccrcdi-
that a sm-ety is entitled to the benefit of any security or^faiifng to'
which the creditor has received for the debt, though he make avail-
. able, securities
has received it after the contract of suretyship ; and there- to the benefit
fore, where the creditor has so dealt afterwards with such gf^j.^^^ 'Ig g^!
security, that on payment by the surety it cannot be given titled,
to him in the same condition as it was when the creditor
first acquired it, the surety is discharged to the extent of
that security (//).
The defendant was surety for the repayment of a sum
Ig) stone v. Compton, 5 Binsf. N. C. 142.
(/() Campbell v. BothwcU, 47 L. J., Q. B. 144; 38 L. T. 33. Sec also
Liqu'ulators of Overend, Gurnctj ij- Co. v. Liquidators of Oriental Financial
Corporation, L. K., 7 H. L. Oas. 348 ; Merchants Bank of London v. Maude,
18 AV. R. 312.
214 GUARANTIES TO SECURE ADVANCES.
of money advanced by the plaintiff to tlie principal debtor.
As a further security for the advance, the principal debtor
deposited with the plaintiff a policy of life insurance. The
principal debtor subsequently became bankrupt, the ad-
vance remaining unpaid, and the plaintiff proved against
his estate for the full amount of the advance without
valuing the policy of life insurance as a security, which
was in consequence claimed by the trustee in bankruptcy
as part of the bankrupt's estate. It was contended by the
defendant in an action against him as sm-ety, that by not
valuing the policy, and so depriving him of the benefit of
it, the plaintiff had discharged him from all liability as
surety. Held, that the omission to value the policy was
at most a mere neglect or omission on the part of the
plaintiff, and as such did not discharge the defendant from
all liability as surety, but only to the extent of the value
of the policy (/).
Richard Cox v/as a banker in copartnership with Messrs.
Morrell, under the firm of Cox & Morrell. He was also
engaged in collieries vv^ith one Davies, under the firm of
Cox & Davies.
Cox & Morrell were in advance to Cox & Davies.
Richard Cox having applied to his partners for a further
advance, it was agreed that they should advance a further
sum upon his brother, John Cox, becoming security for
the repayment of 3,000?.
John agreed, as surety for Eiehard, to execute a joint
and several bond to James and John Morrell for 3,000/.,
upon having a counter bond for the like sum from Cox &
Davies to indemnify him.
A joint and several bond was executed by John but not
by Eichard ; the counter bond was given by Cox and Davies,
and fiu'ther advances were made by the bank.
Some time after this, Eichard ceased to bo a partner in
the bank.
(i) Ralnhoiv v. Jt"j'ji)is, b Q. B. D. 13S ; 19 L. J., Q. 13. 353 ; 28 W. R.
423.
RELEASE OF SURETY TO THE EXTENT OF SECURITIES. 215
The bankers were considered to have released tlie surety
by neglecting to obtain the bond from the principal debtor
Richard Cos {J).
The acceptor of a bill of exchange knows that by his
acceptance he does an act which will make him liable to
indemnify any indorser of it who may afterwards pay it.
The indorser is a surety for the payment to the holder,
and having paid it, is entitled to the benefit of any
securities to cover it deposited with the holder by the
acceptor. He is so entitled, whether at the time of his
indorsement he knew, or did not know, of the deposit of
those securities. The sm-ety's right in this respect in no
way depends on contract, but is the result of the equity of
indemnification attendant on suretyship.
A., a member of a firm pledged his separate estate to a
bank to secm^e to the bank the balance for the time being
owing to the bank from the fi.rm. Afterwards the firm
accepted bills of exchange which were indorsed by B. to,
and discounted for him by, the bank. The firm became
bankrupt and the bills were dishonom-ed at maturity.
The bank having demanded of B. payment of the amount
due on the bills, B. claimed to be a surety for the firm in
respect of the bills, and to be entitled as such sm-ety to the
benefit of the securities held by the bank : — Held, that B.
was entitled to receive them (A-).
Again, a surety is released, to the extent of the value of
goods assigned by the x^rincipal debtor, by the creditor's
failing to register the assignment under the Bills of Sale
Act, and by his not taking possession when default was
made in payment of interest, and when bankruptcy was
to his knowledge impending (/).
Bi/ Release of Debtor. — As by giving time to the prin- By release of
{j) Bonscr v. Cox, 4 Eeav. 379 ; iS'. C, G Boav. 110.
{k) Duncan, Fox % Co. v. Kcw South Wahs Banh, 6 App. Cas. 1,
reversing' 11 Ch. D. 88.
(?) WuUfN. Jai/, L. E., 7 Q. B. 756 ; 41 L. J., Q. B. 322.
216 ■ GUARANTIES TO SECURE ADVANCES.
cipal debtor the creditor releases the surety unless he
expressly reserves his rights against him, so does he re-
lease him by giving the debtor an absolute release of the
debt, unless there is a reservation of the rights against the
surety. A surety is discharged by the principal creditor's
becoming a party to a composition deed releasing the prin-
cipal debtor (wj), unless there is an express reservation
made against him («), because the effect of his doing so is
to voluntarily discharge the principal debtor from any
further liability. The principal debtor's obtaining an order
of discharge in bankruptcy or liquidation, however, does
not discharge the siu-ety (o) .
A customer and another person as his surety signed a
joint and several promissory note, payable to the bankers,
to secure them, &o., and they afterwards executed a com-
position deed, whereby, in consideration of four shillings
in the pound, the bankers and other creditors released the
customer from the payment of the debts respectively set
opposite their names, the amount of the promissory note
being set opposite the bankers' names ; the deed contained
an express clause that it should not operate to invalidate,
prejudice or affect any bonds, bills, notes or other securi-
ties, joint or several, &c., as to the claim against any such
surety ; the deed was held clearly not to release the surety,
there being no fraud on the other creditors, since, the
clause appearing on the face of the deed, all who executed
it must be taken to have been aware of, and agreeable to,
the reservation of the rights against the surety (p) . It must
be remembered, as previously stated, that to reserve a credi-
tor's right against a surety there must be a distinct expres-
sion of intention to reserve it {q).
{m) Green v. JFi/nn, L. E., 4 Ch. 204 ; Lcathlcij v. Spijer, L. R., 5 C. P.
595 ; KcarsJey v. Cole, 16 M. & W. 128.
(/() BatcsoH V. Gosling, L. E., 7 C. P. 9; CragoeY. Jones, L. R., 8 Ex. 81.
(o) McGrath v. Gray, L. R., 9 C. P. 216 ; Breslaur v. Broun, 3 Ajip.
Cas. 672 ; Ex parte Jacobs, In re Jacobs, 10 Clianc. 211 ; Ellis v. Wihnol,
L. R., 10 Ex. 10 : Ex parte Aqra Bank, In re Barber, L. R., 9 Eq. 775.
{p) Xorth V. Wakefetd, 13 Q. B. 53G.
Iq) See aiite, p. 209.
BY RELEASE OF DEBTOR. 217
Cases of composition with creditors frequently occur in
wliicli tlie interests of bankers, upon guaranties, are deeply
concerned, and the form in which such guaranties are ex-
pressed ought always to be such that the bankers should be
secured of a priority of repayments of advances over the
creditors under the composition deed. For this purpose
it is necessary that the guarantie should be made not
conditional to pay on failure of the traders to repay, but
absolute. An illustration will be found in the following
case, in which the bankers sued the trustees under the
composition deed to recover the amount of their advances.
Carr & Co., being insolvent, compounded with their
creditors by agreeing to pay them a composition of seven
shillings and sixpence in the pound, in three instalments,
and execute a conveyance of their real and personal estate
to certain trustees, in trust to permit them, Carr & Co., to
carry on the business, subject to the control of the trustees,
and to pay thereout to the creditors the three instalments ;
and, in case of full payment, to reconvey and reassign the
estate to Carr & Co. ; but upon default of such payment
then in trust to sell, and, after deducting out of the pro-
ceeds interest, costs and amount of mortgages, to divide
the remainder amongst themselves and the other creditors.
Carr & Co. continued, accordingly, to carry on the
business, and opened an account with a banking company,
from whom they obtained large advances. The bank ap-
plied to, and obtained from, the trustees the following
guarantie : —
" Carr & Co., having assigned over all then' real and
personal estate to us in trust for securing a composition
of seven shillings and sixpence in the pound to their several
creditors executing such deed, and it being necessary to
open a banking account for the pm'pose of carrying on the
said trade, in order that the stock and goods on hand may
be wrought up and converted into money, for the purpose
of paying such dividends ; and you having, at om' request,
consented to open a banking account on the credit of the
218 GUARANTIES TO SECURE ADVANCES.
names of Carr & Co., or of any person or persons for the
time being carrying on that concern : we do hereby promise
and engage that any sum or sums of money to become due
to you or to the said banking company, in respect of such
account, shall, in the first instance, be paid to you out of
the net proceeds of the trust esta,te, so far as the same will
extend to pay."
Further advances were made by the bank to Carr &
Co. subsequently to this guarantie.
The trustees subsequently sold the property of Carr &
Co., under the provisions of the composition deed, and the
proceeds were insufficient to pay the creditors the compo-
sition of seven shillings and sixpence in the pound ; the
Court held, that the meaning of the guarantie was not
that the trustees should be liable to the bank out of the
proceeds realized from the estate of Carr & Co. only after
payment of the composition of seven shillings and sixpence
to the creditors, but that they were liable, in the first
instance, to repay, out of the proceeds, the whole amount
of the advances made by the bank to Carr & Co., as vv^ell
before as after the guarantie, and the guarantie was held
to extend to advances made before it was given, notwith-
standing the objection was pressed upon the Court, that
the recital, stating it to have become necessary to ojjeii an
account, &c., pointed only to future advances {>•),
A surety who guarantees the payment of an instalment
under a composition resolution, is not released by the
debtor's being subsequently adjudicated bankrupt at the
suit of creditors who arc not bound by the resolution (s).
By payment Fai/i)iC)it. — Payment by the principal debtor discharges
y pnucipd . ^1^^ surety and part payment does so pro tanto, but not a
payment that has to be regarded as being a fraudulent
preference {t) .
(?•) Wilson V. Craven, 8 M. & W. 584, 595.
(.s) Ghfjg V. Gilbci/, 2 Q. B. D. 209 ; 4G L. J., Q. B. 325.
[t) Sec rdtz V. Cooke, L. 11., G Q. B. 790; iralwyn v. St. Quentin,
2 Esp. 515.
PROMISSORY NOTES AS GUARANTIES. 219
ProDu'ssori/ Notes as Guaranties. — A guarantio is some- Promissory
times given in the form of a promissory note signed by the "uaTanties! ^^
guarantor ; but in such ease the instrument will often be
found to operate as an agreement, and must consequently
be stamped accordingly, in order to be made effectual.
Thus, where tAvo persons, as guarantors or sm^eties for
a customer of a bank, signed together with him an instru-
ment in the following form : —
" Wc jointli/ and sevcmUi/ promise to pay the sum of 1001.
to the Lincoln and Lindsoj Banhinrj Company, or their order^
on demand, with interest.^'
And on the back of the document signed this indorse-
ment.: —
" The within note is given for seeurinrj floating advances
from the said Jjanhng company to the customer, with interest
from the respective times when such advances have been or may
he made, together with commission, stamps, postages, and all
usual charges and disbursements, not exceeding in the whole,
at any time, the sum of 100/."
In an action by the bank against one of the two sureties
on the note, to which there was a plea of the Statute of
Limitations, and payments were shown to have been made
by the customer, in reduction of the balance due on the
banking account, within sis years before action, the Court
held, that it was essential to the plaintiff's ease to take
notice of the indorsement, in order to point the payments
to the note, and to show it to be a secmuty for the
floating balance, for which purpose it was an agreement, and
required to be stamped (?/).
If the secmity or guarantie taken was in the form of a
joint and severod promissory note, payable to the bankers
on demand, and signed by the customer and the guarantor
for a given sum, it was at law no defence to an action
against the guarantor on the note to allege that he made
the note as a surety, and for the accommodation of the
{/() Cholmdcy v. Darlcij, M M. & W. 344.
220 GUARANTIES TO SECURE ADVANCES.
customer, witli the knowledge of the bankers, and that
they, after the note became due and payment had been
demanded of the customer, being holders, agreed, without
the consent or leave of the guarantor, to give time to the
customer, unless he can show that there was a specific
agreement on the part of the bankers to take the note
from the guarantor as a surety only (r). In equity, how-
ever, such a defence was good ; and, consequently, in law
might be set up by Avay of equitahle i^Iea {x).
It is not uncommon for joint stock banks to take a joint
and several promissory note, signed by the customer and
other parties, the latter of whom are intended to be sure-
ties for the former, in order to secure any balance that
may become due to the bank on his account with them, or
to secure advances made by them to him.
It is very material that the persons having the manage-
ment of the business or of the accounts of the bank should
be satisfied that there is nothing in their deed of settle-
ment to prohibit any arrangement of this nature. Many
deeds of settlement contain stringent provisions to prevent
the funds of the company being advanced, or risked upon
merely personal security.
There is no invariable rule that all payments made sub-
sequently to giving a bond by a borrower and sureties to
a bank are to be applied in immediate and final liquidation
of the sum named in it, or of the first items in the bor-
rower's debit : or that if the borrower after the giving of
the bond, on a long course of transactions, be for a time in
advance to the bank, the bond is thereby satisfied (y) .
It may, in default of express stipulation, be inferred from
the language and conduct of the parties after execution of
the bond, that the intention was for the bond to stand as a
(v) ManUy v. Boycott, 1 El. & Bl. 16 ; Trice v. Edmunds, 10 B. & C.
578; Strong v. Foster, 17 C. B. 201. But see Jlall v. Wilcox, 1 M. &
Kob. 58.
[x) Davirs v. SlamhnHlc, G Dc G-., M. & G. 679; UoUicr v. Eijrc, 9 C. &
r. 45 ; Stron;i v. Foster, 25 L. J., C. P. 106.
(//) Hcnnikcr v. Wiyg, 4 Q. B. 792.
PROMISSORY NOTES AS GUARANTIES. 221
continuing security, in wliicli case tlie rule of application
of payments would not apply (z) .
A joint and several promissory note is given to a banker
by a customer and his surety to secure advances made by
the banker. The customer afterwards pays into the bank
generally sums exceeding the amount of the advances, but
also draws out to a still larger amount, and becomes bank-
rupt. In such case the siu-ety is liable, for he cannot
insist that the payments should be appropriated in dis-
charge of the sum secured by the note {a) .
A bank being in advance to a customer took a promis- Promissory
,. Ill- 1 T • '£ 111 i. notes bv mar-
sory note signed by him and his wiie, who had no separate j.-^^,^ women,
property. The husband died insolvent, and nine days
after his death a partner in the bank went to the house
of his widow, taking with him a proper stamp, and asked
her if she could pay any money on account, and on her
answering that she could not, obtained her signature to a
new note written by himself upon the stamped paper. It
being doubtful whether she knew that she was not liable
upon the original note, and nothing having been said at
the interview respecting her non-liability, the note so
obtained was considered in equity to be invalid and un-
available in the hands of the bankers for the advances
made to her husband {b). But when a married woman,
having a separate estate in property settled upon her,
joined with her husband in a promissory note, payable on
demand, to secui'e the balance against him at his bankers,
and a balance continued against him until after his death,
which happened about seven years afterwards, and after
this event she signed a new promissory note for the un-
secured balance, a Court of Common Law determined that
the latter note was binding upon her, as there was a good
consideration for it (c) .
(z) Ilenniher v. Wigg, supra.
{a) Ex parte Whitworth, 2 M,, D. & De G-. 16-i,
[b) Coward v. Hughes, 1 Kay & J. 443.
{c) La, Touche v. La Touchc, 3 H. & C. 57G ; 34 L. J., Exch, 85.
( 222 )
CHAPTEE XXIII.
GUARANTIES FOE, GOOD CONDUCT OF CLERKS.
With respect to guaranties for the good conduct of
clerks of bankers, a point wkicli lias already been ad-
verted to, namely, wlietlier tbe guarantie that is taken is
in such a shape as to stand good in case of a change in
the members of the banking house, arises more frequently
in cases of guaranties for the fidelity of clerks than in those
of guaranties for the repayment of advances to customers,
and therefore requires to be more fully developed.
In considering this subject the Courts are chiefly guided
by the intention of the parties. This is mostly discover-
able only from the expressions they have used in the
instrument of guarantie. In other words, it is most im-
portant for the secmity of bankers that the language
used should clearly and undeniably demonstrate the in-
tention that the guarantor, whether he undertakes for the
good conduct of the clerk during a limited or an undefined
period of time, should be bound to the hanJdng house, not
to the persons who are the members of the establishment
at the date of the guarantie ; because, in case the guaran-
tor is only bound in the latter way, upon any change in
the partnership, by death, by retirement or by taking in
fresh partners, the new partnership might find themselves
unable to enforce the obligation.
The following is an illustration of what has just been
said as to the effect of a change of partnership.
A guarantor executed a bond, whereby he undertook to
A. for the fidelity of a clerk, so long as he should continue
in A.'s service as clerk. A. took a partner, and brought an
GUARANTIES FOR GOOD CONDUCT OF CLERKS. • 223
action on the bond, and assigned as a breach that the clerk
had received money on account of the partnership, and had
not paid it over to the partners ; but A. was not permitted
to recover, the Court saying that when A. took a partner
there was an end of the obligation ; that the condition was
confined to A. alone, and the breach assigned was not
within the condition, and there was nothing to show the
guarantor to have intended to be bound for the clerk's
fidehty to any other person than A. (a).
This decision, it is true, has been questioned by some
judges (b) ; but the principles on which it is founded do
not appear, either expressly or impliedly, to have been
decided to be inapplicable to cases where the facts were
identical, and the terms of the guarantie equivalent (c).
In connexion with this class of cases may be here men-
tioned one which can, however, in general only be appli-
cable in instances where a banking-house is conducted by
a single person, without partners.
Where a bond was taken that a clerk should serve faith-
fully, and account for all money, bills, notes, &c., which he
should receive, &c., to the banker and his executors, ad-
ministrators and assigns, it was held that such bond did
not make the surety liable for money, &c,, received by the
clerk in the service of the executors, &c., who continued
the business and retained him in the same employment {d).
This case tm^ned upon the intention, which was held to be
to guarantee the service to the testator and no longer, and
(a) Wriffht v. BicsscU, 3 Wils. 530 ; 2 W. Bl. 934.
(i) In Barckn/ v. Zncas, 3 Dougl. 321 ; 1 T. R. 291, n. But Barcl(i>/ v.
Zucas has not escaped without much question ; see the note at the end of
the report in 3 Dougl. 321. However, Chapman v. Bccf:ir>gion, 3 Q. B. 722,
recognizes the principle of it, and the same seems to be the ground of de-
cision in Metcalfe v. Bruin, 12 East, 400, and Wilson v. Craven, 8M. &"W.
584 ; viz. that the bayik was the same all along.
{<•) Dry V. Lavetj, 10 A. & E. 30.
{d) Barler v. Barker, 1 T. E. 287; hut compare j;r>- Lord EUenborough,
C. J., Siranffe v. Zee, 3 East, 490. Lord JVIansfield, C. J., 1 T. R. 295,
distinguishes Barclay v. Zaeas, by observing that there the same trade was
carried on by the original masters in the same manner, and the only dif-
ference was the introduction of a new partner.
224 - GUARANTIES FOR GOOD CONDUCT OF CLERKS.
must be considered with reference to the statutory enact-
ment (passed since its date) mentioned above (e) .
In a case where a bond was given to guarantee to a
company not incorporated the faithful services of a clerk,
and the bond was made to and with trustees on behalf of
the body : the Court held, construing the instrument with
regard to the obvious intention of the parties, that it might
be sued upon by the trustees at any time during the con-
tinuance in the service of the actual body of persons car-
rying on the same business under the same name, notwith-
standing any intermediate change of the original holders
of the shares, either by death or transfer (/).
So where a joint- stock banking company had been esta-
blished under the 7 Gfeo. IV. c. 4G, and a guarantie was
given to it, and tlien, upon a considerable accession of pro-
prietors and capital, and an increase in the number of
directors, the company took another name, but was not
shown to differ in its constitution, but remained the same
bank, though with a different name : it was held, that its
public ofhcer might sue and recover upon the guarantie
given to the former establishment ( g) .
Another point to be considered is, that a guarantie for
the faithful services of a clerk, given at a time when his
employment comprises a certain routine of duties, will not
extend to cover other or additional duties that may be
imposed on or accepted by him ; thus if a clerk to a bank,
for whose good conduct as cleric a guarantie has been
given, is made manager, and it is shoicii conclusively that
lie ceased to he cleric ichen he became manager, so that no
breach of the bond could have happened after he became
manager, that will bo an answer to an action by the
bankers on the bond against the surety, founded on mis-
conduct as manager (//).
(e) See supra, p. 203.
(/) Metcalfe v. lirui)/, 12 East, 400,
Iff) Wilson V. Craven, 8 M. & W. 584.
(A) Anderson v. Thornton, 3 Q. B. 271 ; and see SkUhtt v, Tktchcr, L.
R., 1 C. P. 217; 2C. V. 400.
GUARANTIES FOR GOOD (X)NDUCT OF CLERKS. 225
It is scarcely necessary to observe tliat tlie conduct,
whicli amounts to a default on the part of tlie clerk, and
which renders the surety liable upon his undertaking,
must be some act or omission, some malfeasance or non-
feasance, within the scope of the duties appertaining to
the situation he fills.
A clerk of a provincial bank (in Devonshire), who was
sent by the manager, at the request of a customer, to his
residence, about eleven miles from the bank, in order to
receive a large sum of money, to be placed to the cus-
tomer's account with the bank, and who, casually, on his
way back, lost the money out of his pocket, was held to
have received the money in the course of his employment
as clerk; and although the jury found it not to be the
custom of bankers in that part of the country, to send for
their customers' money as above stated, a surety, who had
guaranteed the bank that the clerk " should well and
faithfully serve them as a clerk, and should not cancel,
obliterate, spoil, destroy, waste, embezzle, spend or make
away with any of the books, papers, writings, stamps,
cash, bills of exchange, promissory notes or other property
of the bank, or of any of the customers, which should be
deposited in his hands, or intrusted to his custody or
possession, or come to his care, custody or possession," was
responsible to the extent of the moneys lost (e).
The same would be the decision in case of the pajonent
of a cheque, or the receipt of money, after hanking hourSy
or of sending the clerk to London on a sudden emergency,
to obtain funds, or the like (/.•) .
The fact of a clerk's having received into his personal
possession a sum of money, and having lost it, is strong
evidence of negligence ; but it would have been an answer
to the action above referred to, to have shown that the
loss had been occasioned by robbery before the clerk
(i) mivllle V. Boidfje, G C. B. 450.
\k) See 6 C. B. 454.
O. Q
223 GUAllANTIES FOR GOOD CONDUCT OF CLEUKS.
could liave got back to tlie bank, and -witliout bis de-
fault (/).
The reason for taking sueb security is not only the
obvious one, tbat, in case of any embezzlement by the
clerk, the banker may have the means of protecting him-
self against the loss thereby caused, but also that he may
have the same protection, in case of any loss arising from
the merely careless or thoughtless inattention to his duty
of the clerk, in Vv'hich case, without such seem'ity, the loss
must ultimately fall on the banker, assuming the clerk to
be unable to make it good {m) .
Evidence. — In cases of guaranties or securities of any
kind, taken for the good behaviour of clerks, it is material
to bear in mind that whatever is evidence available against
the principal, is available against the surety.
Thus, where bankers sued the obligor of a bond given
for the fidelity of a clerk, entries of receipts of money by
the clerk in the books kept by him in discharge of his
duty as clerk to them were held to be, after his death,
evidence against the surety of the fact of his having re-
ceived the moneys therein mentioned, it being part of his
guaranteed duty to keep those books (;?).
Discharge of Guarantor. — As has been already stated (see
p. 207), a person giving a guarantee to a firm that he will
be responsible for the faithful services of a servant, cannot
revoke it after once the consideration for that guarantee
has been performed : that is to say, when once the service
has commenced ; nor will his death act as a revocation
of the guarantee, or discharge the guarantor. Thus, in
May, 1863, a father, on the occasion of the admission of
his son as an underwriting member of Lloyd's, addressed
to the managing committee of that body a letter, by which
{I) See Walker v. British Guarantee Association, 21 L. J., Q. B. 257;
18 Q. B. 277.
(>«) liogcrs V. Kelly ^ 2 Camp. 123.
(«) Whitnash v. George^ 8 B. & C. 55G.
DISCHARGE OF GUARANTOR.
he held himself responsible for all his son's engagements in
that capacity. Lloyd's was then a voluntary association,
governed by certain bye-laws, under which a person once
admitted a member could not be excluded from member-
ship, except in the event of his bankruptcy or insolvency.
The association consisted of underwiitiug members, non-
underwriting members, and subscribers. The practice of
the underwriting members was to underwrite policies of
marine insurance for the benefit of various owners of
property, both members of the association and outsiders ;
but the policies with outsiders could only be effected
through the agency of insurance brokers, who were either
members of, or subscribers to, the association. The associa-
tion as such incurred no liability on the policies under-
written by its members.
In 1871 the society was incorporated by Act of Parlia-
ment, all the rights of the committee on behalf of the
members being vested by the act in the corporation. In
1876 the father died, and notice of his death was shortly
afterwards given to Lloyd's. In 1878 the son became
bankrupt, and thereupon ceased to be a member of Lloyd's :
— Held, by the Court of Appeal (affirming the decision of
Fry, J.), that the guarantee was not determined by the
death of the father, or by the notice of it, but that his
estate was liable in respect of engagements contracted
by the son after his death (o).
Employer's Neglect. — If, however, in the case of a con-
tinuing guarantie for the honesty of a servant, the master
discovers that the servant has been guilty of acts of dis-
honesty in the course of the service to which the guarantie
relates ; and if, instead of dismissing the servant as he may
do at once and without notice, he chooses to continue him
in his employ without the knowledge and consent of the
surety, express or implied, he cannot afterwards have
ip Lloyd's V. Harper, IG Ch. Dir. 290.
q2
228 GUARANTIES FOR GOOD CONDUCT OF 'CLERKS.
recourse to tlie surety to make good any loss wliicli may
arise from dislionesty of tlie servant during the subsequent
Service (o). Similarly, the surety, after the servant has
been guilty of dishonesty, may give notice thereof to the
master and withdraw from his guarantie and relieve him^
self from any further liability (p).
Non-disclosure. — What has been said in the previous
chapter as to the duty of the employer to disclose any
material fact likely to make the surety abstain from enter-
ing into the guarantie applies equally to the form of
guaranties now under discussion, and to which, therefore,
the reader must be referred for information (q).
Alteration. — Again, any variation in the agreement to
which the surety has subscribed, that is made without his
knowledge or consent, and which may prejudice him, or
which may amount to a substitution of a new agreement
for a former agreement, even though the original agree-
ment may, notwithstanding such variation, be substan-
tially performed, will discharge the surety.
This may be illustrated by the following example :
where a surety guaranteed the faithful and honest conduct
of a clerk, who was paid by salary, and his employers,
some time afterwards, changed this part of their arrange-
ment with him, and paid him by means of a commission,
which amounted to more than his former salary : it was
held, that the surety was discharged by reason of the
alteration (r). Again, A. became guarantor of the good
conduct of a clerk in a bank ; and the clerk was subse-
(o) Phillips V. Foxhall, L. R., 7 Q. B. G66 ; 41 L. J., Q. B. 293 ; 27
L. T. 231 ; Sanderson v. Aslon, L. R., 8 Ex. 73.
(;;) Burgess v. Eve, L. R., 13 Eq. 450.
{q) Seep. 211.
(r) North Western liaihvaij Compaui/ V. Whlnraii, 10 Exch. 77. Wlieti
the condition of the bond did not contain any stipulation, that the same
sahiiy should bo continued, either express or implied, the guarantor
•would not be discharged by a reduction of the salary. Frank v. Edwards,
8 Exch. 214; explained, 10 Exch. 81, 82.
CIIAKGE OF FIRM.
220
quently appointed to a better situation in a brancli of the
bank, and A. extended bis guarantie to tbe conduct in
this new situation. The clerk afterwards undertook, on
having his salary raised, to become liable to one-fourth of
the losses on discounts, and then allowed a customer to
overdraw, whereby the bank suffered loss. A. was held
not to be liable for this loss to the bank, though it was
within the terms of his original guarantie, because the
fresh arrangement made icithout his knowledge was a dis-
charge (s).
Change of Firm. — Lastly, as has been stated, unless from
the terms of the guarantie it can be seen that the inten-
tion was to secure the good conduct of the clerk while
serving the banking-house, whether the same persons who
constituted the partnership remained in it or not, a change
in the firm releases the surety (/).
(,s) lionnr v. Macdonald, 3 H. L. Cas. 226.
\t) See ante, p. 222.
( 230 )
CHAPTER XXIV.
CRIMINAL ACTS OF SERVANTS, ETC.
Larceny and Emhezzlcment by Clerhs or Servants. — By
24 & 25 Vict. c. 96, s. 67, it is enacted, tliat wliosoever,
being a clerk or servant, or being employed in the capacity
of clerk or servant, sball steal any chattel, money or
valuable security, belonging to or in the possession or
power of his master or employer, shall be guilty of felony;
and, being convicted thereof, shall be liable, at the dis-
cretion of the court, to be kept in penal servitude for any
term not exceeding fourteen years and not less than three
(now by 27 & 28 Vict. c. 47, five) years ; or he may bo
imprisoned with or without hard labour or solitary confine-
ment for a term not exceeding two years ; and, if a male
under the age of sixteen, may be whipped if the court
think fit in addition to the imprisonment. And as regards
embezzlement it is enacted by sect. 68, whoever being a
clerk or servant shall fraudulently embezzle any chattel,
money or valuable security which shall be delivered to or
receive or taken into possession by him for or in the name
or on the account of his master, shall be deemed to have
feloniously stolen the same, and punished accordingly {x) .
The crime of embezzlement differs from larceny in that it
is committed in respect of property which is not at the
time in the actual or legal possession of the owner (y).
On an indictment for embezzlement a prisoner may bo
found guilty of larceny, and vice versa {z). By the
Summary Jurisdiction Act, 1879 (42 & 43 Vict. c. 49),
(x) Seo Ri'g. v. Xegus, L. R., 2 C. C. R. 3i ; iiVy. v. Foidkcs, ibid. 150.
(y) Seo BlackBtone, bk, iv. p. 135.
(r) Sect. 70.
CRIMINAL ACTS OF SERVANTS, ETC. 231
a person between the ages of twelve and sixteen, cliarged
with larceny or embezzlement (or an attempt) as a clerk
or servant may with his consent be dealt with summarily,
and if found guilty may be fined to the extent of ten
pounds, or be imprisoned with or without hard labour to
the extent of three months, &c., &c. And by the same
act an adult, i. c. a person of the age of sixteen or up-
wards charged with larceny or embezzlement (or an
attempt) as a clerk or servant, may, provided in the
opinion of the court the value of the property in respect of
which the offence is alleged to have been committed does
not exceed 40s., and the court thinks proper and he him-
self consents to be summarily dealt with, be so dealt with ;
and if found guilty be fined up to the sum of 20/., or be
imprisoned with or without hard labour for any term not
exceeding three months («). As regards this section,
however, it is provided that if the offence is one which
by reason of a previous conviction on an indictment of the
person charged is punishable with penal servitude the
court shall not deal summarily with the act.
If a clerk commits an embezzlement on the bank, and
his father, in order to cover his defalcations, transfers stock
into the name of the banker, this is a composition of a
felony to prevent a prosecution, and it seems that the value
of the stock cannot be recovered, nor will the stock be
ordered to be retransferred (5). But where a clerk in a
banking company embezzled a large sum of money of his
employers, and before his conviction he deposited the
deeds of some real estates with the company, and directed
a transfer of certain policies of assm-ance on his life to be
made to the company, as a security, so far as they would
extend, for the money taken, and the company afterwards
successfully prosecuted him for the embezzlement to con-
viction : it was held, that the money taken was a debt due
from the felon to the company, and a good consideration
(rt) See sect. 4.
{b) Glaridfje v. Eoare, U Vcs. 59.
232 CRIMINAL ACTS OF SERVANTS, ETC.
for the securities given by him to the company, and that
the company was entitled to realize them {b) .
Ciml Remedy. — "Where an injmy amounts to an infiinge-
ment of the civil rights of an individual, and at the same
time to a felonious wrong, a cause of action arises imme-
diately upon the commission of the offence, but it was said
could not be enforced till the injured party had fulfilled
his public duty and brought the felon to justice, that is to
say, if he were able to do so (c) . This rule, however, seems
to be much doubted, and in a recent case it has been held
that an action for a felony, if otherwise maintainable,
would be maintainable wdthout showing that the felon had
been prosecuted {d) .
[h) Choxcne v. Baylis, 31 L. J., Chanc. 757; 31 Beav. 351.
(f) See cases diacussed in Wells v. Abrahams, L. E., 7 Q. B. 557.
{d) Midland Ins. Co. v. Smith, 6 Q. B. D. 561. See also Ex parte BalL
He Shejjherd, 10 Ch. D. G73.
( 233 )
CHAPTER XXV.
BANKERS GIVING SURETIES AS TREASURERS.
We will in tMs chapter advert to the cases in which bankers
may be required to find sureties upon their appointment as
treasurers to public bodies.
A., B. & Co., entered into a joint and several bond, for
the faithful performance by A., of his duties as treasm-er
of a poor law union, in receiving, &c. moneys, &c. A. and
another person were bankers, and A. had, in fact, never
been in the exclusive receipt of the moneys of the union,
which were paid into the bank, the overseers of the
parishes constituting the union having been directed by
the board of guardians, in their x^^i^^^^ contribution
warrants, " to pay to Messrs. Brodie & Co.," and the
cheques drawn by the board requiring A. and his partner
to pay, &c.
The Court held it to be an established principle, that for
moneys paid to two or more parties the surety for one is
not liable; and therefore, that if a person is surety for
another, for the due accoimting for moneys received by
him, the receipt of moneys by that person and his partner
is not the same as the receipt by him alone, because the
surety may be willing to be accountable for one individual,
but not for bim and his partner, and a payment to one
partner is a payment to both. Here the board drew
cheques on the banking firm, treating them as their joint
treasurers, and from that it was inferred that they agreed
to the moneys being paid into the bank, to their credit,
just as any other customer. Hence, when the bank failed,
with a balance due to the imion in its hands, the sureties
were held not to be liable, and a sum equal to the above
234 BANKERS GIVING SURETIES.
balance, having "been paid to the board of guardians by one
of them under a mistake of facts, was held to be recover-
able {a) .
If the guarantie had been for the good behaviour of the
partners, and that they and the survivor and survivors of
them should account for, &c. all moneys paid to them, or
either of them, or any person thereafter in partnership with
them, &c,, the retirement of one of the partners would
not have released the surety (b).
"Where the guardians of a poor law union took a bond
with sureties for the honest and faithful performance of his
duties by a banker appointed the treasurer of the union,
one of which duties was, according to the regulations of the
poor law board, to pay out of any moneys of the guardians
in his hands all orders drawn by them on him; and the
guardians took the amount of several orders partly in
money, partly in bank notes of the banker himself, and
partly in a draft upon the banker's correspondents in '
London, and then the bank stopped payment, the guar-
dians having the notes in their hands, either having never
parted with them or holding them on their being returned
after the stoppage by persons to whom they had been paid
away, the Court held, that the sureties were not liable : for
the guardians had conclusively elected to treat the orders
as paid, and the notes were taken at their peril ; and the
di-afts had been given merely for their convenience (c).
A person became surety to the guardians of a poor law
union by a bond, conditioned that the treasurer of their
union should discharge the duties of his office " by re-
ceiving all moneys tendered to be paid to the board of
guardians, by paying out of the moneys in his hands
of the guardians all orders di'awn on him on their behalf,"
and by paying over to the guardians all balances, moneys,
{a) Mills V. AkJcrbunj Uinoii, 3 Exch. 500.
{/>) University of Cambridge v. JSaldwin, 5 M. Sc W. 580.
{c) Lichfield Union v. Greene, 26 L. J., Exch. 140; 1 H. & N. 88i. lu
such case tlio guardianH are left to prove against the estate of the bank-
rupt banker on the notes and draft. S. C.
BANKERS GIVING SURETIES. 235
&c. duo to the union, &c. The treasurer, who was a corn
factor, had extensive dealings in corn, and open accounts
in trade with the overseers of several of the townships who
were farmers. No money was received from these town-
ships, but it was the practice of the treasurer to debit the
overseers in his trade account with the amount of the poor
rate ordered by the guardians to be paid, and then to
debit himself with the amount as paid to him as treasurer.
His accounts were audited half-yearly, and the credits in
corn were allowed by the auditors as payments in money.
At the last audit, the auditors found that the sum of
239/. Is. lOd. was due to the guardians, and the Exchequer
Chamber held that the surety was liable, inasmuch as
between the treasurer and the overseers money had in
effect passed (d).
As regards evidence of the liability of the guarantor in
these cases, we may point out —
1. That an account, delivered by a clerk, cashier, &c.,
charging himself, is evidence against his surety.
2, That, in case such account is made out by the clerk,
and he continues to receive paj^ments on account of the
banker, and subsequently pays in moneys or takes credit
for salary or disbursements, those payments are not neces-
sarily to be first applied to extinguish the previous balance,
when the subsequent receipts are equal in amount to the
payments (e).
[d] Fattison v. Bedford Union, 1 H. & N. 523.
\e) Zi/sa,jht v. JFaUcr, 5 Biigh, N. S. 1.
( 236 )
CHAPTER XXVI.
APPROPRIATION OF PAYMENTS.
Where a customer has a running account with a bank,
the balance of which is sometimes for him and at other
times against him, the question often arises, how are the
payments by the bankers to be applied ?
Thus, in the case of a banking partnership, where one
partner dies, and the customer goes on dealing with the
bank as before, there being no new account nor any settle-
ment made, and then the banking-house becomes bankrupt,
the account at the death of the partner being about 1,700/.
in the customer's favour, but being afterwards and before
the bankruptcy reduced by payments made by the bankers,
on his account, to about 450/. in his favour; but agaia
showing a balance for him exceeding the former amount
of 1,700/., at the time of the bankruptcy; — are the pay-
ments made, subsequently to the partner's death, by the
survivors to be applied in reduction of the balance due to
the customer at that period, so as to discharge the estate
of the deceased partner pro tanto^ or are they to be consi-
dered as exclusively parts of the dealings between the
survivors and the customer ?
Now this question has been settled, once for all, by Sir
William Grant, Master of the Rolls, in a decision which
has been universally followed and acted upon ; and in the
case of a banking account where all the sums paid in form
one blended fund, the parts of which have no longer any
distinct existence, the rule may be stated to be as follows :
— presumably, it is the sum first paid in that is first paid
out, and it is the first item on the debit side of the account
that is discharged or reduced by the first item on the credit
side.
ArPROPRTATION OF PAYMENTS. 237
Indeed, tHs is the principle on which all accounts cur-
rent, and especially cash accounts, are settled; and any
other mode (as the Master of the Rolls shows) would lead
to extravagantly unreasonable results (a).
If the customer intended that this usual mode of dealing
should he altered or departed from in any way, it is in-
cumbent on him to signify his intention to that effect to the
bankers, for the rule in Claijton^s case is not applicable
when it can be gathered, either from the course of dealings
between the parties or from the debtor when making the
payment, that such rule is not intended to be applicable {a) .
There is no difference between the Courts of Law and
the Courts of Equity on this question of appropriation:
both adopt the same i)rinciple as the ground of their de-
cisions {])) . The same rule applies, moreover, as against a
surety : for even in that case, the earlier items of the ac-
count will be those to which the earlier payments are to be
regarded as appropriated {c) . So, in the case of a trustee
paying trust money into his banker's account, thereby
mixing this money with his own, subsequent sums drawn
out by him will be attributed to the earliest items on the
credit side of his account for the time being, and the trust
money will, in this v.'ay, in its turn be considered as drawn
out, whether or not the result be that a balance remains of
his own monies (r/). The same principle being applicable
to dealings between a company and its bankers, it follows
that a former shareholder, who has transferred his shares, is
(a) Clayto)i's case, 1 ller. 608—610, 611 ; Citt/ Discount Co. v. M'Lcan,
L. R., 9 C. P. 692 ; 43 L. J., C. P. 344 ; 30 L. T. 883 ; Ex parte Smith,
25 "W. R. 760. The customer has a right to resort for paj-ment of what
is due to him out of the estate of a deceased partner to that estate, -nith-
out reo-ard to the state of the account, as between the deceased and the
surviAing partners. Bevayncs v. Xobic, 2 Russ. & M. 495.
(b) Bodenhani v. Purchas, 2 B. & A. 45. See Simson v. Ingham, 2 B. &
C. 72 ; Williams v. Griffith, 5 M. & "W. 300 ; Laiiig v. Campbell, 36 Beav.
3 ; Hooper v. Eeay, 1 Q. B. D. 178 ; 34 L. T. 574 ; Ex parte Smith, In re
Hamilton, 25 W. R. 760.
(c) IViUiams v. liawUnson, 3 Bing. 71 ; see also Kinnaird v. Webster, 10
Ch. D. 139 ; 48 L. J., Ch. 348.
(rfl Brcu-n v. Adams, 39 L. J., Ch. 67; L. E., 4 Ch. App. 764; Fennell
V. iJefTcU, 4 De G., M. & G. 372.
238 APPROPRIATION OF PAYMENTS.
exonerated from contributing to the company's debt to its
bankers, if before the winding-up sufficient money has been
paid to the bank to cancel what was due to the bank when
such shareholder ceased to be a member (e).
Distinct ac- Distinct Accounts. — It is necessary, however, to keep
coun s. -^ mind that where there are distinct accounts kept, and
the customer is overdrawn and makes a general payment,
without specifically appropriating it at the time, and there
is no course of dealing, or other circumstances, showing
clearly how he must have intended to appropriate the pay-
ment (/), this is not a case within the rule we have been
stating, which applies only in case of a running unbroken
account, but one in which the banker may apply the pay-
ment to which accoimt he pleases ( g) ; and he is not bound
to do it instantly, but may take a reasonable time (A) . On
the other hand, if the customer is indebted to the banker
on several accounts and pays in money, he, the customer,
has a right to say at the time to which debt the payment
shall be applied [h).
A municipal corporation kept an account at a banking
house. Afterwards, becoming invested with the functions
of a local board of health, the corporation opened a second
and separate account with the bankers. The bankers
stopped payment, there being then due from the corpora-
tion, on account of its municipal affairs, a large sum of
money, and a similar amount from the bank to the cor-
poration, in respect of the local board of health account :
it was held, that the corporation was entitled to set off
these claims one against the other, for although the ac-
counts were separate, the corporation was a debtor in the
((') Devonport and South Devon Steam Flour iEUl Co., In re Batcman''s case,
42 L. J., Ch. 577.
(/) See Wilson v. Hirst, 4 B. & Ad. 7G6 ; Stoveld v. Bade, 4 Biiig. 1.54;
Lysaght v. Walker, 5 Bligh, N. S. 1 : Broun v. Anderson, 2 Moore, P. C.
245.
{g) Simson v. Ingham, 2 B. & C. 72, 75. Entiy in the customer's
books is not evidence of the approi)riatiou by him. Manning v. Westerne,
2 Vem. C06.
(/,) Ibid.
APrROPRIATION OP PAYMENTS. 239
first account and a creditor in the second and in the same
right (/).
When a customer has opened with his bankers separate
accounts specially headed with the names of the trusts to
which the moneys paid into those accounts belong, the
bankers are not at liberty upon the bankruptcy of the cus-
tomer to apply those moneys in payment of the balance
due to them upon the customer's overdrawn private ac-
count (k) .
Thus, a county treasurer used to pay the county
moneys into Bacon's Bank, but kept his private account
at the National and Provincial Bank, and carried over
the police rates to this account by cheques drawn on
Bacon's Bank : in 1869 he opened a separate account with
the National and Provincial Bank, headed " Police Ac-
count," and some of the items to his credit in this account
could be traced as having come from county funds, but
most of them could not : the cheques which he drew upon
it were all headed " Police Account," and drawn only for
county purposes : for the purposes of interest the National
and Provincial Bank treated the accounts as one account,
the interest on the balance in his favour being carried to
the credit of his private account : at the time when the
police account was opened, the manager of the bank knew
that he was county treasurer and understood that he had
been in the habit of paying county moneys into the bank :
in April, 1870, he absconded, his private account being
overdrawn, and the police account being in credit : — the
court held, that the bank was not entitled to set oS. the one
account against the other, but that the county magistrates
were entitled to recover the balance standing to his credit
on the police account (/).
When a partnership has been dissolved and one or more
of the partners continue the business, and a creditor of the
(i) redder v. Preston {Mat/or, ^-c), 9 Jui-., N". S. 49G; 11 C. B., N, S.
535; 31 L. J., C. P. 291.
(A-) Si- parte Kingdon, In re Gross, L. R., 6 Cli. 632 ; 40 L. J., Ch. 91.
(/) Jbid.
240 APrROPRIATION OF PAYMENTS.
firm continues the credit, and blends together his accounts
with the old firm and the new, payments made by the new
firm on account must be aj)plied in the first instance to the
satisfaction of the old firm (m) .
This rule holds good not only with respect to payment
actually entered in the blended account but also with re-
spect to any sum of money paid without specific appropria-
tion after the blended account has been sent in.
The plaintiffs supplied goods to K. & D., who were in
partnership, and they gave the plaintiffs their acceptance
for 132/., the amount. Before the bill was due K. & B.
dissolved partnership, and gave notice to the plaintiffs with
the intimation that K. would carry on the business, and
would receive and pay the accounts due to and from the old
firm. The plaintiffs continued to supply Iv. with goods,
and he gave them his acceptance for the amount, and also
paid them several sums on account, but without any specific
appropriation. After some months the plaintiffs sent in
their account to K., beginning on the debit side with the ac-
ceptance for 132/., and, after giving him credit for the
sums paid, showing a balance against K. of 92/. After
this K. paid the plaintiffs two other sums, which, with the
sums already paid, amounted to more than 132/. The
plaintiffs having sued K. and D. on their acceptance for
132/., D. pleaded payment : — Held, that, the plaintiffs
having sent in the statement to K. treating the whole as
one account, the subsequent payments must be appropriated
to the earlier items of the account ; and consequently that
the plea was proved [m) .
The same principle applies when the partnership expires :
thus, Brooke, a lieutenant-colonel in the army, employed
one Gilpin, as army agent and banker, to receive his pay
and allowances, and also dividends on his stock, and other
moneys on his account, and from time to time to make
payments to him, or his order, for which purpose he was
(«/) Hoopei- V. Keaij, 1 Q. B. D. 178 ; 01 L. T. 574 ; 2-1 W. R. 485.
APPROPRIATION OF PAYMENTS. 241
in the liabit of drawing on Gilpin, wlio, from time to time,
sent in his account to the employer. Brooke continued to
employ Grilpin in this way from some time before the
year 1807 down to the year 1819, when Gilpin became
bankrupt ; no rest was made or balance struck in the
account after the 1st of July, 1816, and during the
whole period of the account there was always a con-
siderable balance due to Brooke. On the 24th of Sep-
tember, 1807, Gilpin had entered into partnership, for a
licriod of ten years, with one Enderby, but the business
continued to be transacted in the namQ of Gilpin alone,
and Brooke had no notice or knowledge of the partnership
until after the bankruptcy of Gilpin ; and the receipts
and payments prior and subsequent to the 24th of Sep-
tember, 1817, when the partnership expired, formed part
of one general account. Then, on Brooke bringing an
action against Enderby and Gilpin, to recover the balance
due to him at the expiration of the partnership, the Court
held that Enderby (Gilpin having pleaded his bankruptcy)
was entitled to consider any sums paid by Gilpin after the
expiration of the partnership, as being paid in reduction of
the balance then due to Brooke, and might take credit for
them, without giving credit to Brooke for any sums re-
ceived after the expiration of the partnership by Gilpin
on account of Brooke {n).
The acting member of a partnership has an implied au-
thority to assent to the transfer of their account from one
bank to another, without an express assent of the other
partners. Upon such transfer, however, the actual amount
due is alone transferred. Where the balance due from the
firm at the time of the transfer has been overtopped by
subsequent payments to their credit, as to which there has
been nothing to take the case out of the ordinary principle
of appropriation of payments to the earlier items, the
banker has no right of action in respect of the balance
(«) Brooke V. Emlcrhu, 2 B. & B. 70.
G. R
242 APPROPRIATION OF PAYMENTS.
existing at tlie time of transfer, whidi lias tlius become
extinguished, but only in respect of the balance subse-
quently become due (o).
Legal items. Legal Items. — If there is a running account between
the customer and the bankers, and the bankers make large
advances to him, part of these advances arising out of
illegal and part out of legal transactions, and the customer
from time to time deposits bills and makes payments,
without any specific appropriation or any settlement of
the account : it will be held, that the payments must be
applied to the reduction of the earlier items of the ac-
count, and to the legal, and not the illegal, part of the
demand (j;). So bankers may apply subsequent unap-
■ propriated payments to debts barred by the Statute of
Limitations {q).
Specific ap- Specific Appropriafioii. — When money is paid in on a
propriation of gp^Q^^Q account by the customer, and accepted by the
banker, the money cannot be appropriated to any other
account or debt (r) . Therefore, where a customer paid a
sum of money to a country banker, with instructions to
remit 500/., part of the sum, to a London banker, to meet
the acceptances of the customer, and the banker on the
same day sent several bills to a bill broker, and directed
the London banker to meet the acceptances, and on the
next day the country banker stopped payment; it was
heldj that the sum of 500/. was specifically appropriated,
and that the customer was entitled to recover it back in
full (r).
(o) Beal V. CadcUch, 2 H. & N. 32(5 ; 2G L. J., Exch. 356.
{p) Ex parte Randlcson, 2 Dcac. & C. 53i ; JFric/ht v. Laing, 3 B. & 0.
165.
[q) Williams v. GriffUh, 5 M. & W. 300 ; A^ihhj v. James, 11 M. & W.
542.
(r) Farley v. Turner, 26 L. J., Chanc. 710. See also Hill v. Smith, 12
M. <& W. G18; Barned^s Banking Co., In re, Ex parte Masseg, 39 L. J.,
Ch. 035 ; 22 L. T. 853 ; Johnson v. Itobarts, L. R., 10 Ch. 585 ; 44 L. J.,
Ch. 678. Sec ante, p. 138.
APPROrRIATION OF PAYMENTS. 213
But when a person pays money into a tank to bo
applied in a specific manner, and the hanker stops pay-
ment before taking any step towards applying it to the
purpose, the payer cannot recover the money paid, but
has merely a right of proof as a general creditor on tho
banker's estate (s).
A solicitor in the country received from a client a large
sum of money, which was to be paid by him into the
Comi of Chancery on the client's account. The solicitor
obtained a bill for the sum from a country banker, and
remitted it to his bankers in London, without stating the
reason for which the amount had been paid to him. At
the same time he was indebted to his bankers in 450/., for
which they held securities, and as to which they kept an
accoimt separately from his general account. The soli-
citor died, and a few days afterwards the bill became due
and was paid, and the bankers carried the amount to his
general account. The bankers, for some time after they
had received notice from the client of the circumstances
under which the amount of the bill had been paid to the
solicitor, continued to keep the accounts separately, but
ultimately deducted the 450/. from the proceeds of the
bill, and paid the balance to his executrix. The Yice-
Chancellor held, that as there was no agreement binding
the bankers to keep separate accounts as to the 450/. and
the amount of the bill, and as they had no notice till after
the amount was received of the purpose for v/hich it was
intended to be applied, the client was not entitled to re-
cover from them any part of the proceeds of the bill (;').
(.s) In re BarnecVs Banking Comj/amj, Masse)/ s case, 39 L. J., Chanc.
635.
(0 Grigg v. Cockcij, 1 Sim. 439.
2 R
( 244 )
CHAPTEE XXYII.
LIEN.
The general lion of bankers is part of the law mercliant,
to be judicially noticed like other parts of that law {a).
Unless there he an express contract, or circumstances
showing an implied contract inconsistent with the principle
of lien, bankers have a general lien on all securities de-
posited with them, as hanhcrs, by their customers {h).
Securities for Special Purposes. — A banker's lien does
not attach on securities placed in his hands for a special
purpose, e. g., where exchequer bills are deposited, in order
that he may receive the interest on them and get them
exchanged for fresh bills ; for such special purpose is in-
consistent with the notion of a general lien. It is on this
ground, that if a customer goes to his banker requesting
him to get a bank post 'bill for the purpose of transmitting
into the country the sum of 1,000/., which sum he hands
over to him in bank notes, the banker, unless he expressly
states that he receives the notes only subject to his lien,
has no right to retain or apply them to any other purpose
than that for which he received them {c).
Where a customer deposited with his bankers a deed of
conveyance, comprising two distinct j)roperties, giving to
(«) BranclaoY. Harnett, infra; lioclc v. Gorrisscii, 30 L. J., Chaiic. 39;
2 De G., F. & J. 434; Jones v. rcppcrcorne, Johns. 430 ; 28 L. J., Chanc.
153.
{b) Brandaow. Barnett, 12 C. & F. 787; London Chartered Bank of Aus-
tralia V. White, I^. R., 4 Apj^. Ca. 413 ; 3Iisa v. Carrie, 1 App. Ca. 544 ;
45 L. J., Ex. 414 ; Lcesc v. ^fartin, L. R., 17 Eq. 23G ; 43 L. J., Chauc.
193 ; Kinnaird v. IVebster, L. 11., 10 Ch. D. 139 ; 48 L. J., Chanc. 348 ;
Ex parte Manchester and Count tj Bank, L. E,., 3 Ch. D. 481 ; 45 L. J.,
Bank. 149 ; Bx parte Adam, L. E., 2 Ch. A^^p. G3 ; In re Williams,
3 Ir. Eop., Eq. 346.
(e) Brandao v. Barnett, supra. For "liens" (so-called) arising by
speoial agreement or equitable mortgages by dci^osit, sec further, post.
SECURITIES FOR SPECIAL PURPOSES. 245
them at the same time a memorandum pledging one of the
properties as a security for a specific sum advanced, and
also for his general balance, it was decided that, as the
deposit of the deed of conveyance was for a special piu'-
pose of giving a security upon one property only, tho
bankers could not claim a general lien, by virtue of the
custom of bankers, on the other property (d).
If a customer deposits securities with his bankers, to
indemnify them to the extent of 1,000/., then advanced
by them, and afterwards becomes indebted to them in an
additional sum of 500/., on his running account, it would
seem that they have no lien on these securities beyond the
1,000/. and interest {e).
A customer kept three accounts with his banker, called
the general account, the loan account, and the discoimt
account. The loan account was from time to time fed by
the deposit of securities, which were ordinarily expressly
deposited to secure the general balance. The customer
wrote a letter to the banker, advising him that he had
charged his account with 10,500/., and stating that as by
this time his credit with the banker would no longer afford
a margin to that extent, he hastened to hand him by way
of collateral security certain bills of exchange, which he
specified; the Court held, that this did not exclude the
banker's right to a general lien on the bills in respect of
the balance due on the general account ; for, as between
banker and customer, whatever number of accounts are
kept in the books, the whole is really but one account, and
it is not open to the customer, in the absence of some
special contract, to say that secmities which he deposits are
only applicable to one accoimt (./'). So even, if there are
several accounts kept at several branches, such accounts
can be treated as one, and if on the general balance the
(d) Wylde v. Radford, 33 L. J., Chanc. 51.
\e) Vandcrzee v. Willis, 3 Bro. C. C. 21 ; Zinck v. Wdher, 2 W. Bl.
1154 ; see Ashton v. Dalton, 2 Collyer, 565. See p. 183.
(/) In re European Sank, L. E., 8 Ch. 41 ; 27 L. T., N. S. 732.
246 LIEN.
customer is sliown to be indebted tbereon, the banker's lien
will apply (/),
Plate. — Bankers have no lien for the balance of their
account against a customer, on his plate deposited in his
chest with them for safe custody {g).
Trust or Property of Third Persons. — Nor can bankers
carry into effect any lien which they may prima facie have
upon securities deposited with them, which are, in fact,
trust deeds. Thus, if a customer deposits title deeds, as a
security for advances, and the property comprised in the
deeds is subject to a trust, in breach of tvhich the deposit is
made, then, although the bankers have no notice of the
trust, it must prevail against their lien (h), unless there is
negligence of such a character, on the part of the cestui que
trust, as to deprive him of his right to the trust fund (i).
One of the trustees of a fund held certain shares in a
banking company, in his own right, and dealt with and
purchased shares therein to a considerable extent. A
portion of the trust fund v/as invested in shares in his
name. There was no distinguishing mark by which the
individual shares could be traced, the whole being in the
nature of capital, expressed by terms of quantity. The
trustee then agreed to assign a certain number of the shares
standing in his name to the banking company, as security
for repayment of advances which had been made to him
by them; but no formal transfer was ever made. He
then became bankrupt, not having in his ownership at the
time a sufficient number of shares to satisfy the trust and
(/) Garnctt v. IfcKcwan, L. R., 8 Ex. 10, See also Prince v. Oriental
Banking Company, 3 App. Cas. 325.
{g) Sec Kc parte Eyre, 1 Ph. 235; 12 C. & F. G94, 797; ;;n- Lord
Campbell, Brandao v. Harnett, 12 C. & F. 809; and O'Connor v. Major i'
banks, 4 M. & a. 435 ; Zecsc v. Martin, L. R., 17 Eq. 224.
(h) Ifanningford v. Tolcman, 1 Collyer, G70.
(;■) S/ark/iOKse v. T/w Countess of Jersey, 30 L. J., Chanc. 421. Sec as to
what notice -will afiect lieu, IJcrry v. Gibbons, L. R., 8 Cli. 747 ; Maxfield
V. Burton, L. R., 17 l-'q. 15 ; Cavandcrv. Bullcel, L. R., 9 Cli. 79 ; Farhall
V, Farhall, L. R., 7 Eq. 28G ; sco also ]>. 174.
TRUST OR PROPERTY OF THIRD PERSONS. 247
also to enable him to execute the agreed assignment to the
banking company.
Here the banking company was held to have no lien on
any of the shares which A. had held in trust ; for though
the shares so held, being originally purcliased with trust
money, possibly might have been dealt with by sale and
repurchase, the trustee must still be considered as holding
for the purposes of the trust the same number of shares,.
out of a larger number which stood in his name at the
time of the bankruptcy : and of the tv/o equities, that of
the ccstuis que trust, and that of the banking company —
no actual assignment of the shares having been made, pur-
suant to the agreement — the former must prevail {j).
Bankers have no lien upon railway stock deposited or
pledged with them by a customer, after they receive notice
that the stock is the property of another person [k) .
The trustees of a trust fund had an account with a
banking company, as such trustees. One of the ccstuis
que trust had a private account with them, which was
much overdrawn ; upon their agreeing not to press for the
reduction of the balance against him, he offered to give
them a lien on the moneys coming to him in respect of
his share of the trust fund: and to this they agreed.
Accordingly, he addressed a letter to one of the trustees,
authorizing and requesting him to pay to the credit of his
(the cestui que trtisfs) account with the bank such sums
as might be awarded to him out of the trust fund. It was
held that this letter gave the bankers a valid lien upon the
proceeds of the fund, and, being intended by both parties,
at the time it was given and received, to be irrevocable,
must be considered in equity to be so to all intents and
purposes (/) .
(i) mtrray v. FmJcett, 12 C. & F. 764,
(k) lockcY. Frescoff, 32 Beav. 2C1.
(l) Fx parte Steward, 3 M., D. & De G. 265. Sec Paiuicll v. TIarki/, 2
CoUyer, 241 ; Somerset v. Cox, 10 Jur., N. S. 351.
248 LIEN.
Bills of Exchange, 8^c. — If a customer lodges undue bills
of excliange in the hands of his hanker and draws upon
them for any money he wants in advance, the hanker
charging no interest on these advances, but selecting out
of the bills such as were nearest in amount to the sum
advanced, and discounting them, and debiting the cus-
tomer with the amount of such discount in his account,
but without any special agreement to that effect, then
there is nothing, in these circumstances, to invalidate the
banker's right of lien for his balance, on all other bills
placed in his hands by the customer besides those that he
discounts {m). It seems to be universally true, that a
customer cannot get back paper securities in 'his banker's
hands, without paying the balance against him, unless
there is some special contract between the banker and the
customer inconsistent with the general lien {n).
S. discounted with a bank bills of exchange drawn
against goods consigned to India, handing over the bills
of lading as security. The bank carried a part of the
discount value of the bills to a suspense account till advice
of the payment of the bills, to form a margin or an addi-
tional security against a fall in the price of the goods, and
gave accountable receipts for such margins. S. deposited
these receipts with A,, who gave notice to the bank. The
bills having been dishonoured, the bank was held entitled
to a lien on the marginal receipts for such sums as were
actually due and payable to the bank by S. at the times
when the marginal receipts respectively became payable,
in respect of liabilities contracted before notice of the
deposit was received, but not to a lien for sums not
actually due (o).
(w) Davis V. Bowshcr, 5 T, E.. 488. See as to lien on undue bills, ante,
p. 146.
(«) Per Lord Campbell, in Branclao v. Bariictt, 12 C. & F. 787; and
Wood, V.-C, in Jones v. I'epjKrcornc, 5 Jur., N. S. 140 ; 28 L. J., Chanc.
153.
{") Jcjfrues V. The Afjra and Masterman''s Banl;, 3.j L. J., Chanc. G8G.
PARTNERSHIPS. 249
A banker, who has discoimted bills for a customer, has
no implied lien on that customer's cash balance duiiug the
currency of the bills (7;).
The rule is so strong as regards the lien on securities,
■which come into the banker's hands icitJiout being appro-
pnated to any special pioposc, or entrusted to them for safe
custody or the like, that it attaches on bills and notes
payable to beaver, or other negotiable instruments which
pass by delivery, although the customer depositing them
was not the real owner, and had no authority to saddle the
property in them with a lien, provided the bankers, at the
time of the deposit, have no notice of any equitable trust
or title attaching to these securities {q).
Securities left by Mistahe. — Nor has a banker any lien on
securities left by mistake or casually at the bank, upon the
occasion of an application to him to advance money on
them, which he had refused to do (r) .
Partners/lips. — Bankers have no lien on the deposit of
a partner, on his separate account, for a balance due to
the bank from the firm («). A firm had an account with
a bank and one of the firm had a separate account with
the same bank. Upon the bank discounting a promissory
note of such partner, he deposited with the bank certain
shares as a security for the same, or for any sums of money
in which he might then be or might thereafter become
indebted to them. The shares afterwards became the
property of the firm, which became bankrupt largely in-
debted to the bank; the bank was held not entitled to
hold the shares as a security for the joint debt, but for the
separate debt only of the partner depositing the shares (/).
At the commencement of the bankruptcy of the firm of
(p) Botves V. Foreign and Colonial Gas Company, 22 "W. R. 740.
[q) Barnett v. Brandao, 6 ]M. & Gr. 630. See also Misa v. Cnrrie, 1 App.
Cas. 544; 45 L. J., Ex. 414; linmball v. Metropolitan Bank, L. E... 2
Q. B. D. 194 ; 46 L. J., Q. B. 346.
(»•) Lucas V. Borrcin, 7 Taimt. 279.
(4) Watts V. Christie, 11 Beav. 546.
(t) Ex parte M'Kenna, 30 L. J., Bank. 20. See also Ex parte Manchester
and County Bank, L. R., 3 Cli. D. 481.
250 LIEN.
A. and W. there were standing registered in the name of
A. shares in a bank, whose articles of association provided
that all the shares of every shareholder should be subject
to a lien in favour of the bank for any debt due to the
bank for him alone, or jointly with any other person.
The shares in question, which were originally the private
property of A., became partnership assets when he entered
into partnership with W., but the bank had no notice that
anyone but A. was interested in the shares. The bank
sought to prove against the joint estate of the firm for a
large debt contracted after the shares became partnership
assets : — Held, that the lien of the bank on the shares was
a secmity on the joint estate, and that the bank could
prove for the amount of their debt without deducting the
value of their shares.
Realizing Lien. — Little has been decided to illustrate
how the law provides that the banker is to realize, and
make productive, his lien on securities.
In case of any negotiable secmity which comes to his
hands on account of a customer, to whom the banker is in
advance, he has, as has been said, a lien or power of de-
tention ; and in order to make such power productive, he
may put the negotiable instrument in suit (?/), and recover
upon it so much as will cover the balance due to him from
the customer (.r). With respect to other securities it is
submitted that, in the case of a mere lien (as distinguished
from an equitable mortgage), a banker has no right of
sale (y).
But, instead of advancing their remedy, bankers will
destroy their right of lien, if after a lien has been established
they take a security, which is payable at a didant day, for
the debt (s).
(}i) BoUandv. Bygrave, R. & M. 271 ; Bosanqnet v. Budman, 1 Stark. 1.
\x) Scott T. Franklin, IT) East, '128. The lien is ouly, at most, co-
extensive with the balance duo ; per Eyre, C. J., Bolton v. Bidler, 1 B. &
P. 546.
(y) See Donald v. SucJclin//, L. E.., 1 Q. B. 5S.5.
(;) CowcU \. Simpson, 16 Vcs. 278; Jfcwison v. Guthrie, 3 Scott, 311;
2 Bing. N. C. 755.
( 251 )
CHAPTER XXVIII.
PARTNERSHIPS AT COMMON LAW.
Many questions arise in banking transactions "wliicli are
governed by the rules applicable to partnerships at com-
mon law. For this purpose it will be well to consider
shortly what is the law relating to such partnerships.
Cases respecting copartnerships in banking, under the
7 Geo. IV. c. 46, as they stand upon different and special
grounds, will be treated apart ; and the same will be done
with respect to joint-stock banking companies and char-
tered and limited banking companies.
LiahUity of Firm for Parfjwr^s Contracts. — Every part-
ner, acting on behalf of the firm, can bind his co-partners
by contracts entered into by him, though without the
authority of such co-partners, provided the contract comes
within the scope of the ordinary business of the firm, and
that notice of such want of authority was not brought to
the knowledge of the party with whom the contract was
made. When the contract is one which the partner is
authorized to make by the others, it need hardly be said
they will be bound thereby.
An acting partner has implied authority to assent to the
transfer of their account from one banker to another,
without the express assent of the rest of the firm, but it is
doubtful whether the acting partner has such authority to
borrow a sum from the transferee of the account, in order
to pay off the bank from which the transfer was made, or
those who constituted it {a). But one partner has no
authority, in the absence of evidence of custom, to bind
(«) Bcal V. Caddick, 26 L. J., Exch. 35C.
PARTNERSHIPS AT COMMON LAW.
his co-partner by opening a banking account in his own
separate name, instead of the name of the partnership,
although the account may be for partnership purposes, and
consequently the bankers will not be entitled to recover
against both partners the overdrawn account (c).
So, again, supposing the partnership is a trading part-
nership, a partner can bind his co-partners by accepting,
drawing or indorsing bills of exchange, though he be
expressly forbidden by the firm to enter into such con-
tracts {d). But where the firm is not a trading one, as in
the case of a firm of solicitors, there is no implied authority
for one of the partners to bind the others by drawing,
accepting or indorsing such instruments (c).
A partner has no implied authority to bind his co-part-
ners by a submission to arbitration (/), nor, as a ride, by
executing a deed (g) , nor by giving a guarantie (A) .
Partners cannot effectually pledge partnership property,
so as to make it available for their own private debts (/).
LiabUiti/ of Co-partners for Partner'' s Wrong. — A firm is
liable for injuries or loss resulting from the wrongful act
or negligence of one of their number, provided he was
acting within the ordinary course of the business of the
firm. In the same way, a firm is responsible for the mis-
application by a partner of money or property received by
him, if in so receiving it he was acting within the ordi-
nary apparent authority of his firm ; or, again, if money
or property has been actually received in the custody of
the firm, they are responsible should one of the partners
misapply it.
(c) Alliance Bank v. KearsUij, 40 L. J., C. P. 219 ; L. E., G C. P. 433 :
24 L. T. 552.
{d) Kirk V. Blurton, 9 M. & W. 284 ; Forbes v. Marshall, 11 Ex. 16G ;
and see ante, p. 30.
(e) Garland \. Jacomb, L. R., 8 Ex. 216.
(/) Adams v. Bankart, 1 Cr., M. & 11. C81 ; Thomas v. Alhcrlon, 10
Ch. D. 185 ; 48 L. J., Clianc. 370.
(.--/) Jhrri/ V. Jackson, 4 T. & li. 51G.
(h) ])ancan v. Lowndes, 3 Camp. 481.
[i) Ex parte Snoivball, la re JJotiylas, L. R., 7 Ch. 534 ; 2G L. T. 894.
LIABILITY OF CO-PARTNERS FOR PARTNER'S WRONG. 253
A lady having an account with a hanking house, con-
sisting of several partners, was ad\ised by one of them to
dispose of certain Dutch bonds of which she was possessed,
and to place the proceeds on better security ; the partner
also suggesting that the money should be lent to his son.
In this plan the lady acquiesced, in consequence of the
great confidence she had in the firm, and gave the partner
a cheque upon the bank for the money, payable to a third
person named, or bearer, and received a promissory note
for repayment with a guarantie from the partner, who
afterwards absconded. The security subsequently proved
worthless.
On the lady filing a bill in equity against the remaining
partners, it was held that they were not liable for the loss,
because the transaction was not within the scope of a
banker's business, and was not recommended or sanctioned
by the other partners (./).
The owner of certain exchequer bills deposited them
with a firm of bankers, and subsequently one of the part-
ners sold them without the knowledge of their owmer or of
the other partners. The proceeds were innocently applied
by the bank to its own use : — Held, that the bank was
Hable(A-).
One of the partners in a bank caused stock, belonging
to a customer of the bank, to be sold out, by means of a
power of attorney, which he forged. The proceeds of the
stock were paid to the account of the banking firm, at the
house of the bank's agents, and were appropriated by the
partner, who was afterwards found guilty of other forgeries
and hanged. His partners were, in fact, ignorant of the
fraud, but might have known it by the exertion of common
diligence. The customer was held entitled to maintain an
action against the partners for the amount (/) .
(y) Bisho}) V. Countess of Jersey, 2 Drew. 143 ; 23 L. J., Chanc. 483.
(k) Clayfon''s case, 1 Mer. 575.
{I) Marsh V. Keating, 2 CI. & F. 250. In tliis case the judgment went
more or less on the ground that the partners might have known of the
fraud, but, had it been otherwise, they would still have been liable,
inasmuch as the selling, through their broker, stock belonging to their
PARTNERSHIPS AT COMMON LAW.
So, it has been laid down, that if one partner in a bank-
ing house colludes with a member of a trading firm in a
transaction connected with the business of the bank, the
banking firm is liable to the trading firm for any damages
which the latter may have suffered by reason of such a
transaction. Longman & Co., booksellers, banked with
Pole & Co. On a certain day, Hurst, a partner in Long-
man's house, sent cash to the bank in order to take up
three bills of exchange accepted by him in the name of
the firm and coming due next day. The bills were taken
up, but by Hurst's order were not entered in the books of
Longman & Co. About the same period, it appeared in
evidence, Dov/nes, a partner in the bank, told one of the
clerks that a bill of Longman's would come in on such a
day, which was to be paid and given over to him (Downes),
and that he was to debit Hurst with it in the note hoolc, in
which private transactions were entered, so that it might
hot go into the ledger. Downes soon afterwards gave a
similar direction respecting another bill of the same kind ;
and these bills were entered into the note book accord-
ingly, and the cash payments were entered in the same
book to Hurst's credit, and consequently no trace of these
transactions appeared, either in the pass book of the
bankers or in the cheque book of Longman & Co. Hurst
afterwards retired from the partnership, receiving the full
amount of his capital, and became bankrupt. Longman
& Co. were subsequently obliged to pay bills accepted by
him, in the name of the firm, to a very large amoimt. An
action was considered to be clearly maintainable by Long-
man & Co. against Pole & Co., in respect of the damages
arising to the former out of the collusion of one of the
latter firm with Hurst (1).
customers and receiving and remitting the proceeds was within the scope
of the firm's business. See also £lair v. Bromley, 2 Ph. 354 ; St. A/ibi/n v.
iSmart, L. R., 3 Ch. G4G ; Tliimcr v. Gregory, L. R., 18 Eq. C21 ; Thomas
V. Atherton, 10 Ch. D. 185; 48 L. J., Ch. 370; Eced v. Baihy, 3 App.
Cas. 94; 47 L. J., Ch. IGl ; Lacey v. mil, 4 Ch. D, 537; Tliimcr v.
Gregory, 31 L. T. 7.
(Z) Longman v. Folo, Danson & L. 12G ; M. & M. 223.
JOINT AND SEVEHAL LIABILITY OF PARTNER. 255
Defence in Actions by Partners. — So, -where there is a
good defence against one partner that defence is equally
available against the others; thus, where one of several
partners in a hanking house drew a bill in his own
name upon a third party, who accepted it, upon condition
that the drawer should provide for it when due, the firm
was adjudged to be bound by this act of the partner, and
they were not allowed to sue the acceptor ; for the partner,
not having performed the condition on which the acceptor
accepted, could not have done so, and they could not be in
a better position than he was [m) .
Where a customer gave a promissory note to his bankers
on account of a supposed balance due to them (there being,
however, a mistake as to this), and the bankers indorsed
the note to another firm, consisting of some of the partners
of the banking house, he was held at liberty to set off the
debt due to him from his bankers, in an action brought
against him on the note by the firm who held it, the
knowledge of one of the partners in such firm being
deemed equivalent to notice to all, and, therefore, that they
were affected by the state of the accounts between him and
his bankers («).
Joint and several LiahiUty of Partners. — A partnership
contract, being inform joint, was held in law to create only
a joint obligation, which consequently attached exclusively
■ upon the sm'vivors (o). But it is now held in equity, that
partnership debts are joint and several {p) ; and in a suit
by a creditor of a firm against] the representatives of a
deceased partner and the surviving partner, the creditor is
entitled to satisfaction out of the assets of the deceased part-
ner, whether the surviving partner is or is not insolvent (^j).
{m) Brandon r. Scott, 7 E. & B. 234 ; Astkt/ v. Johnson, 5 H. & N. 137 ;
JLiehmond v. Heapy, 1 Stark. 202.
(«) Fuller V. Eoe, Peake, 197.
(o) Sleech's case, 1 Mer. 564 ; Story on Partnership, 361 ; Jiichards V.
Heather, 1 B. & A. 29.
[p) Wilkinson v. Henderson, 1 M. & K. 581 ; Bishop v. Church, 2 Vcs.
sen. 371 ; Burn v. Burn, 3 Ves. 573 ; Beresford v. Broivning, 1 Ch. D. 30 ;
45 L. J., Ch. 36 ; Kendall v. Hamilton, 3 C. P. D. 403 ; 4 App. Cas. 504.
256 PARTNERSHIPS AT COMMON LAW.
Bcath of Fartner. — So in equity partners are looked
upon not as being joint owners of the partnership pro-
perty, but as owners or tenants in common ; and, conse-
quently, on the death of one of them his share does not
survive to the others, but forms part of his personal
Goodwill. estate (y). In the same way on the death of one of the
partners, there is no survivorship of the goodwill of the
business, but it is looked upon merely as an asset ; and, if
it is saleable, must be sold (r) . Where a partnership, at
the time of the death of one of the partners, is unsaleable,
and the surviving partner carries on and improves the
business, and subsequently sells it, in administering the
estate of the deceased partner the surviving partner is
only chargeable in respect of the value of the business at
the date of the other partner's death (s). In the case
of bankers one year's average net profits has been con-
sidered a fair assessment of the goodwill of the business [t) .
Partnerships in other Firms. — The rule as to partner-
ships in other firms is thus stated by Mr. Justice Lindley,
in his work on Partnership, p. 341, " If there are two
firms with one name, a person who is member of both
firms is liable to be sued on all bills bearing that name,
and binding on either firm. But if a member of only one
of the two firms is sued on the bills his liability will de-
pend first on the authority of the person giving the bill
to use the name of the firm of which the defendant is a
member ; and, secondly, on whether the name of that firm
has in fact been used. If both these questions are answered
in the affirmative he will be liable, but not otherwise."
Thus, A., B. and C. traded under the firm of A. and C.
{q) Barber, Ex parte, L. E., 5 Ch. CS7; Daviesv. Games, 12 Oh. D. 813 ;
Ih-oughtnn v. Broxqldon, 44 L. J., Ch. 520; In re Simpson, L. R., 9 Ch.
572; 31' Clean v. Kennard, L. R., 9 Ch. 33G ; 43 L. J., Ch. 323.
(r) Bradbury v. Dickens, 27 Beav. 446 ; Wedderbiirn v. Wedderhurn, 22
Bcav. 104.
(.?) Brunqhton v. Broughion, supra. Sec further Simpson v. Chapman,
4 Dc G., Mac. & G. 154 ; Smith v. Everitt, 27 Beav. 44G.
(0 MvUvrsh V. Kean, 28 Beav. 453.
CHANGE OF FIRM AND SUBSTITUTION OF LIABILITY. 257
in the cotton business, and A. and B. traded as partners
alone under the same name in the business of grocers, in
which latter business they became indebted to D., and
gave him their acceptance, which they were unable to take
up when due. In order to provide for it, they indorsed
to D. in the common firm of A. and B. a bill of exchange,
which they had received in the cotton business in which C.
v/as interested, but such indorsement was unknown to 0. :
— Held, that such indorsement in the firm common to both
partnerships of a bill received by A. and B. in the cotton
business bound C. (u).
Change of Finn and Substitution of Liahility. — In the
event of a change of firm, the old firm still remain liable
for debts contracted before the change, imless their creditor
agrees to discharge the old and to look to the new firm
for payment, or at least does some act equivalent to such
an agreement (,r). Such an agreement does not require a
consideration {y).
The mere fact of a creditor's receiving interest from the
new firm, for a debt due from the old one, is not neces-
sarily an adoption by him of the new firm as his sole
debtors.
Thus, if the change is occasioned by death, and the
creditor of the old firm receives interest for his debt from
the new firm, it is quite clear this fact by itself will not
discharge the estate of the deceased partner (:;).
If the change is occasioned by the retii'ement of a
partner, the same holds good {a).
{u) Su-aii V. Steele, 7 East, 210. See also Hall v. TTest, cited in Lindley,
343. Bafcery. Charlton, Peake, 111, maynowbe considered no longer law.
{x) See remarks by Buller, J., in Tatlock v. Harris, 3 T. E. 180 ; £il-
horough v. Holmes, 6 Ch. Div. 255, ante, p. 127.
(y) Thompson v. Pcrcival, 5 B. & Ad. 925 ; overruling Lodge v. Bicas,
3 B. & A. 611. See Bank of Scotland v. Christie, 8 C. & F. 214 ; see also
Lyth v. Ault, 7 Ex. 669.
(c) Daniel v. Cross, 3 Ves. 277 ; Bleiv v. Wyatt, 5 Car. & P. 397; Gough
V. JJavies, supra.
{a) Gough v. Davies, 4 Price, 200. See also Kincan v. Kiruan, 2 Cr. &:
M. 617 ; Crawford v. Cocks, 6 Ex. 287.
G. S
268 rAllTNERSHIPS AT COMMON LAW.
The mere fact of the creditor's treating the contimiing
partners as his debtors does not, of itself, show that he
therefore means to surrender his rights against the retiring
partners {b).
The fact of the creditor's receiving a new security from
the continuing partner affords strong evidence of his
consent to a substitution of liability {<■). So, if he agrees
to look to the new firm, and for a long period makes no
demand on the old firm {d).
If, upon a cliange of the members, the balances of the
customers of the old partnership be transferred from the
books of the old firm to those of the new firm, without any
special agreement as to the manner in which payments
made by the customers were to be applied, but under a
general understanding amongst themselves that the new
house was to be responsible for the debts due from the
old : the new house cannot appropriate payments made by
customers, since the change, in their own favour, but will
be bound to apply them in liquidation of the balances duo
from the old firm (e) .
A., a partner in a banking house, and also in business
separately as a trader, died, and in a suit by his sej)arate
creditors against his executors the bankers claimed to
prove the balance due to them from A. ; and they were
held to be entitled to do so, although, as the partnership
included A. they could not have sued him at law in his
separate capacity; and the reason is, because, when an
account is decreed the equitable creditors have a right to
be satisfied, and no distribution of assets can take place
until the accounts of all the creditors of every description
have been gone into (./').
Incoming Farincrs. — An incoming partner who has not
{b) Heath v. Tercival, 1 P. Wms. 682.
(c) Evans v. Druinmo/id, 4 Esp. 89.
(d) Hart \. Alexander, 2M.. &W. 481; Bilhorourihv. Holmen, 5 Ch. D. 255.
(f) Toulmin v. Copland, 3 Y. & C. G25, thus applyiup: the princii^le of
Clayton's case, 1 Mcr. COS — GIO, Gil, to cash accounts between partners
tlumsolvea; S.C, 7 C. & F. .'575.
(/) I'ai/ntcr v. Homt'm, 8 Mer. 302.
INCOMING PARTNERS.
agreed with the person suing him to be liable, is not liable
for debts contracted by the old firm before his entering
into it. Such an agreement may, however, be implied
from circumstances.
Ashby and Eowland carried on business as partners*
having an account with a bank in their own names. They
then took one Shaw into partnership, without, however,
giving- notice to the bank, or altering the title of their
account, and without making any rest in the account.
The transactions at the banking house were with Rowland
personally. The bankers never had notice that Shaw had
been or was a partner until the dissolution of the partner-
ship, when notice, signed by Ashby and Shav>^, was sent
them, that Rowland having withdrawn from the firm, no
transaction to which he was a party could be recognized
by them. Before Shaw became partner, Rowland had
indorsed a bill of exchange in the partnership name of
Ashby and Rowland to the bankers, who discounted it and
placed the proceeds to the credit of the account. After
Shaw became partner, and before the dissolution, Rowland
indorsed two other bills in a similar manner, which were
discounted as before. The balance of the account, at tho
time of the dissolution, was 60/. 5s. 3d., against the part-
nership. The proceeds of all the three bills were intended
to bo devoted by Rowland to other than partnership pur-
poses, but of this the bankers had no knowledge, and
nothiug appeared that could have raised their suspicions
of it. The question was, how far Shaw was liable to the
bankers on these bills, and it was decided that he was not
liable on the bill, which was indorsed and discounted
before he came into the firm, but he was liable on tho two
other bills ; for it was said that each partner might have
limited the authority of his co-partners to bind him, by
giving notice to the bankers ; he was also held liable upon
so much of the cash balance, as became due, after the day
on which he became a partner {(/) .
[ff) Vcre V. JsJiii/, 10 B. & C. 288. Sec also Re prrr/e Pcde, 6 Ves. G02.
s2
259
PARTNERSHIPS AT COMMON LAW.
A firm agreed tliat one of the partners should retire,
the assets being transferred to the continuing partners,
who should take upon themselves the liabilities, and that
the bankers of the finn (whose account was overdi'awn) ,
should release the retiring partner. The bankers signed
a memorandum acceding to this arrangement. They
could not afterwards make the retiring partner a bankrupt,
on the ground of this debt ; for the partner having, by
the agreement to which the bankers were paities, been
induced to give up his share in the partnership property,
and to denude himself of the means of payment of the
debt, it was contrary to equity that they should be allowed
to proceed as if they had never caused him so to act;
and they were restrained by injunction from so proceed-
ing (A).
Partnership Account uith Banlicr. — As has been said a
partner has no implied authority to open an account in his
own name on behalf of the partnership (?) ; but he may,
if an acting partner, consent to the partnership account
being transferred from one bank to another (A-).
Where a partnership keeps an account with a banker,
and a new partner comes into the firm, he cannot transfer
a part of the assets of the old firm to his separate account,
without the authority of the firm, so as to discharge the
banker (/) .
The fact of one of two partners having opened an ac-
count with a bank, in his own name, is not conclusive to
show the account to be opened in his own behalf merely.
The banker may prove that the customer was acting as
agent of the partnership and that the account was a part-
nership account. On the other hand, the mere circum-
stance of the money deposited being partnership money,
(/() Attwoodv. Banks, 2 Beav. 192.
(0 Alliance Bank v. Kcardcij, L. 11., 6 0. P. 433, ante, p. 252.
(k) Beale v. Caddock, 26 L. J., Exch. 35G.
(0 Ex parte Hanson, 18 Vc9. 231.
PARTNERSHIP ACCOUNT WITH BANKER. 261
is not sufficient to prove the account to be a partnership
account {»i).
The fact of one of many co-adventurers in a mining con-
cern, who has assumed the management of the adventure,
opening an account with a bank in the name of the ad-
venturers does not show that he is expressly authorized
by them to do so ; and, as there is in general no implied
authority, in the case of mining adventui-es by which any
one of the party may pledge the credit of the rest for
money borrowed, even though for the purposes of the
mine, if the account is overdra^vn, the bankers have no
remedy for the balance by action against the co-adven-
turers {)}) .
(w) Coole V. Seelei/, 2 Exch. 7-16.
(«) Hic/i-ett V. Bennett, 4 C. B. 686.
( 2G2 )
CHAPTER XXIX.
SAVINGS BANKS.
A savings' bank is defined to bo an institution, in the
nature of a bank, formed or established for the pui^poso of
receiving deposits of money for the benefit of the persons
depositing to accumuLate the produce of so much thereof
as shall not be required by the depositors their executors
or administrators at compound interest, and to return the
whole or any part of such deposit, and the produce
thereof, to the depositors their executors or administrators
■ — deducting out of such produce so much as shall be re-
quired for the necessary expenses attending the manage-
ment of such institution — bu.t deriving no benefit what-
ever from any such deposit or the produce thereof (r/).
A savings' bank company is not necessarily a banking
company {b) .
In 1863, the previous acts relating to savings' banks in
England and Ireland were repealed, and ncAV provisions
were made for their management and establishm.ont, which
are consolidated into one act {c) .
Since the 28th of July, 1863, savings' banks cannot be
formed under the provisions of the now statute, unless thoy
have received the previous sanction and approval of the
Commissioners for tlie Reduction of tho National Debt, or
the Comptroller- G-eneral or Assistant-Comptroller acting
(a) 9 Geo. 4, c. 92, s. 2 ; 26 & 27 Vict. c. 87, s. 2.
(/>) Coe, Hx parte, 10 W. R. 138 ; 31 L. J., Bank. 8.
(r) 2G & 27 Vict. c. 87. This act repe;ils the 9 Geo. 4, c. 92 ; 3 Will. 4,
c. 14, ss. 21, 22, 25, 28, 29—35 ; 5 & G AVill. 4, c. 57 ; 7 & 8 Vict. c. 83 ;
11 & 12 Vict. c. 133 ; 17 & IS Vict. c. 50, s. 2 ; 22 & 23 Vict. c. 53 ; aTid
23 & 21 Vict. c. 137. Sec also 40 Vict. cc. 13, 14 ; 37 & 38 Vict. c. 73.
The 59 Geo. 3, c. 62, as to Scotland, remains in force until the Scotch
Savinf^s' Banks adopt the Act of 18G3. By 2G Vict. c. 25, and 32 & 33
Vict. c. 59, tho National ]3ebt Commissioners may invest the savings of
banks under 9 Geo. 4, c. 92,
DEPOSITS. 263
under the Commissiouers {d). The rules and regulations
for the management of savings' hanks must he entered in
hooks kept for the purpose, and open for the inspection of
depositors, or the managers and trustees will not he en-
titled to avail themselves of the pri\aleges or powers con-
ferred hy the enactment {e).
Banks established under the provisions either of the
repealed statutes, or of the Act of 1883, are to he certified
hy the title of '^ Savings' Bank certified under the Act of
1863," and the members of any other hank, association or
company, or any other person, using or adopting such title
as their designation for carrying on business, will he guilty
of a misdemeanor, and on conviction will be punishable
accordingly (/).
Deposits. — No person can become a depositor for the
fii'st time, without disclosing his name, profession, business,
occupation, calling and residence {g).
Every person at the time of his fh'st deposit must, and
afterwards as often as required by the trustees or managers,
make and sign a declaration of not being entitled to any
deposit in or benefit from any other savings' bank : and
this under pain of forfeiting the deposit or benefit, if in
the opinion of the barrister (Ji) the deposit was made with
a fraudulent intention : such declaration is to be filed and
kept by the trustees ; a printed notice of this regulation
being affixed in the bank ; and a copy of the declaration,
with notice of the penalty, annexed to or printed at the
beginning of the deposit book (/).
No one can deposit more than 30/. in any one year, ex-
clusive of compound interest {j).
{(?) 26 & 27 Vict. c. 87, s. 2.
{c) Id. s. 3.
(/) Id. 3. 6.
Iff) Id. s. 36.
(A) Sec now 30 & 40 Vict. c. 52, for powers and duties of tho cci-tifying'
barrister.
(t) 26 & 27 Vict. c. 87, s. 38.
(./) Id. 8. 39. Depositors may transfer theii" deposits to any othci.'
gaviugs' banks, s. 40,
264 savings' banks.
Moreover, deposits cannot be received from any depo-
sitor, so as to make the sum to which he shall he entitled
exceed 150/. in the whole, exclusive of interest (k).
Although a depositor's money may go on increasing, at
compound interest, until it reaches 200/. in the whole, yet,
thenceforth, no interest will be payable on such deposit, so
long as it remains at that amount {Jc).
Attempts at evasion of the statute, in this respect, by
taking advantage of the clauses enabling persons to deposit
money in trust for others have been treated as follows : —
A person after depositing in his own name in a savings'
bank to the full extent allowed, made further deposits to
another account in the name of himself and his sister, but
nominally as a trustee for her, in this form : — " Henry
Field, in trust for Ann Field," making a declaration ac-
cordingly. It appeared, on examination, that the statute,
•whilst allowing one person to deposit money in trust for
another person, in their joint names, still left him at liberty
to withdraw it without any communication with that
person.
A Court of Equity, considering that the second account
had been opened only with a view of evading the statute,
and not with the intention of creating a trust in favour of
the sister, refused to declare her to be entitled to the sum
deposited to the second account (/).
By the Married Women's Property Act, 1870, it is
enacted, " that notwithstanding any provision to the con-
trary in the act of the tenth year of George the Fourth,
chapter twenty- four, enabling the Commissioners for the
Reduction of the National Debt to grant life annuities
and annuities for terms of years, or in the acts relating to
savings' banks and post office savings' banks, any deposit
hereafter made and any annuity granted by the said Com-
(k) 2G & 27 Vict. c. 87, a. 39. Depositors dying haviug 50^., or over
that sum, how payable to representatives, ss. 41, 42, 43. See Marsdoi,
In re, 1 S. & T. 542.
(/) Field V. Lonsdale, 13 Bcav. 78.
DEPOSIT BOOK. 265
missioners under any of the said acts in the name of a
married woman, or in the name of a woman who may
marry after such deposit or grant, shall be deemed to he
the separate property of such woman, and the same shall
he accounted for and paid to her as if she were an un-
married woman ; provided that if any such deposit is made
by, or such annuity granted to, a man-ied woman by
means of moneys of her husband -i^ithout his consent, the
Court may, upon an application under section nine of this
act, order such deposit or annuity or any part thereof to
be paid to the husband " (m).
Deposits may be received from the trustees or treasurers
of any friendly society legally em^olled or certified in the
manner required by the acts in force relating to friendly
societies, without restriction as to amoimt (u), and from
the trustees or treasurers of any charitable or provident
institution or society, or charitable donation or bequest,
for the maintenance, education or benefit of the poor, or of
any penny savings' bank ^^-ithiu the United Kingdom, to
the amount of 1001. per annum, and of 300/. in the whole,
exclusive of interest (o) ; but funds of benefit building
societies are not allowed to be invested in savings'
banks (|j).
Annuities. — ^Depositors in savings' banks are enabled to
purchase annuities of not less than one nor more than
thirty pounds each {q).
Deposit Booh. — By the rules of a savings' bank, entries
of deposits were to be made in a book kept by the bank for
the purpose, and also in a duplicate account book to be
kept by the depositor, which duplicate was to be a voucher
for the pai-ty producing it, and a receipt for the bank,
when it was handed over to them. A. deposited in the
{m) 33 & 34 Vict. c. 93, s. 2.
(») 26 & 27 Vict. c. 87, s. 33.
(c) Id. s. 32.
\p) 6 & 7 WiU. 4, 0. 32, s. 6.
{q) 16 & 17 Vict. 0. 45.
SAVINGS BANKS.
name of B. a sum with tlie bank, and afterwards, wltliout
liis authority, got hack the money, and delivered up to
the bank the duplicate account book : — It was held that
B. nevertheless still continued a depositor, and the bank ,
was liable for having allowed B.'s money to be drawn out
without his licence (r).
Provision must be made in the rules of all savings'
banks for every depositor, once a year at least, causing his
deposit book to be produced at the bank for the purpose
of being examined (s).
JRemcdics of Depositors. — By the same act it was enacted,
that any dispute arising between the trustees and managers
and an individual depositor, or his executor, administrator,
next of kin or creditor or assignee, or a person claiming to
be entitled to any deposit, was to be referred in writing to
the barrister appointed under the Savings' Banks Acts,
who had power to proceed ex parte on a notice in writing
to the trustees or managers being left or sent through the
Post Office to the office of the bank ; and whatever award,
order or determination he might have made, would have
been binding and conclusive on all parties, and final to all
intents and purposes, without any appeal (?"). The sub-
mission and award are exempt from stamp duty {k). Now,
however, the dispute must be referred to the registrar under
the Friendly Societies Act, 1875, s. 22 (r).
An action is not maintainable by depositors aga-inst the
trustees or managers to recover their deposits ; they must
have recoui'se to the mode of reference pointed out by the
statute (.r) .
(r) Hex V. Cheadle Saving.'i' Banl; 1 A. & E. 323.
(») 26 & 27 Vict. c. 87, s. 6.
(t) Id. s. 48. He may inspect books and administer oaths, Id. s. 19 ;
see Lynch v. Fitzgerald, 15 Law Times, 372.
(«) Id. s. 50.
(r) 38 & 39 Vict. c. CO, s. 22, rind see 39 & 40 Vict. c. 52, s. 2, subs. 1.
{x) See, under the fonncr acts, Crisp v. Bioihurif, 8 Bing. 394 ; It. v.
Witham Sfiriugs^ Bank, 1 A. & E. 320 ; B. v. Mildenhall iSariiigs^ Bank,
6 A. & E. 952 ; R. v. Korivich ^aviugs' Bai/k, 9 A. & E. 729, and seg
ptatutes cited in previous note,
WEEKLY AXD ANNUAL ACCOUNTS. 267
. Investments. — The trustees must pay Into tho Bank of
England or the Bank of Ireland, as the case may require,
aU sums to be invested in the names of the Commissioners
for the Reduction of the National Debt, that is to say, all
the deposits they receive, except such sums as from time
to time may necessarily remain in the hands of the trea-
surers to answer the exigencies of the savings' bank ; and
they are not to invest in any other manner or upon any
other security (?/) ; and all moneys so paid into the Bank
of England or Ireland must be invested by the commis-
sioners from time to time in the purchase of Bank Annuities
or Exchequer Bills or parliamentary secmities of whatso-
ever kind, created or issued under the authority of any Act
or Acts of Parliament for tho interest on v/hich provision
is made by Parliament, or any stock or debenture or other
securities expressly guaranteed by authority of Parliament,
and the interest, as it becomes due thereon, is in like
manner to be invested in these Government Annuities,
Exchequer Bills or securities {z).
Weekly and Annual Aeeounts. — The trustees and mana-
gers are to transmit weekly returns to the Commissioners
for the Eeduction of the National Debt, showing tho
amounts of tho week's transactions and the amount of the
cash balances in the hands of the treasurer or other person
on account of the bank {a). The trustees and managers
are annually to prepare a general statement of the funds
of the savings' bank invested in the Bank of England or
the Bank of Ireland, showing the balance or principal sum
due to all the depositors collectively, the expenses incurred,
and stating in whose hands the balance shall be {b). If
the trustees neglect to make out and transmit this state-
ment to the commissioners, the commissioners may close
(y) 2G & 27 Vict. c. 87, s. 15. By 43 & 44 Vict. c. 36, investments are
now allowed in Government Stock.
[z) 26 & 27 Vict. c. 87, s. 19.
(«) Id. s. 7.
{b) Id. s. 00. As to computation and rate of interest, Zd, ss. 21, 22, 23,
268. savings' banks.
the account of the trustees {h). Every depositor is entitled
to a printed copy of the annual statement on payment of
a penny {c).
Office )'s. — Every treasurer, actuary or cashier, being
intrusted with the receipt or custody of money subscribed
or deposited for the purpose of the bank, or any interest
or dividend from time to time accruing therefrom, and
every officer receiving any salary or allowance for his
services from the funds of the savings' bank, must give
security by bond, with one or more sureties, to the Comp-
troller-General of the National Debt Office for the time
without fee or reward {d), and the bond when executed is
to be deposited with the Commissioners for the Eeduction
of the National Debt {d).
With the view of securing savings' bank depositors
against loss by the acts or misconduct of the officers em-
ployed, the legislature has given a prior or precedent
claim over their estate or goods in the event of their bank-
ruptcy or death.
The provision is, that if any person appointed to any
office in a savings' bank, and being intrusted with the
keeping of the accounts, or having in his hands or posses-
sion, by virtue of his office or employment, any moneys or
effects belonging to the bank, or any deeds or securities
relating to the same, dies or becomes bankrupt or insol-
vent, or has any execution or attachment or other process
issued against his lands, goods, chattels or effects, or makes
any assignment for the benefit of his creditors, — then his
executors, administrators or assignees, or other persons
having legal right, according to the case, or the sheriff or
other officer executing such process, must, within forty
days after demand, made by two of the trustees, deliver
(/>) 26 & 27 Vict. c. 87, s. 55. As to computation and rate of interest,
Ibid. ss. 21, 22, 23.
(c) lb. 8. 59.
{d) lb. a. 8.
OFFICERS.
269
and pay over all moneys and other things belonging to the
bank to such person as the trustees may appoint, and pay
out of his estate, assets or effects, all money remaining due
which such officer received by virtue of his office or em-
plo;yTnent, before any other of his debts are paid or satis-
fied, or before the money directed to be levied by the
process is paid over to the pai-ty issuing it, and all his
assets, lands, goods, chattels, estates and effects shall be
bound to the pa;y'ment and discharge thereof accord-
ingly (e).
A draper was appointed actuary and cashier of a savings'
bank, a rule of which was, that one or more members of
the committee should attend at the cashier's shop to receive
the deposits ; this rule, however, was not attended to, and
the cashier was permitted to receive the deposits. He
became bankrupt, and the deposits were held not to be
" moneys in his hands by virtue of his office," so as to be
claimable in full by the bank.
The duty of the office of actuary did not include the
receipt of money, which duty, by the rule, was imposed on
one or more members of the committee ; nor did the duty
of cashier include the receipt of money for the same reason,
for the duty of a cashier is to pay money ; consequently
the moneys were not in his hands, at the time of his bank-
ruptcy, by virtue of his office (/).
In the case of the bankruptcy of any person in office in
a savings' bank, the savings' bank can only be paid in
full his debt to them, when they have conformed in all
respects to the statute, and there has been no negligence
or laches on the part of the manager or trustees of the
institution.
Where a person on his appointment as treasurer of a
savings' bank entered into the usual bond, but did not
actually receive any money, the deposits being paid by the
{e) 26 & 27 Vict. c. 87, s. 14.
(/) Ex parte Fleet, 4 De G. & S. 52 ; The Lartfml Savingn'' Banlc, see
1 Fonb. Bank. R. 137.
270 savings' banks.
managers directly into a bank, of whicli he was a partner,
to the credit of the trustees of the savings' bank, who were
allowed interest on it, but he signed the monthly return to
the National Debt Office, thereby acknowledging the ba-
lance to be in his hands as treasurer, on the bankruptcy
of the bank, the savings' bank recovered in full (g) .
An officer, being robbed of the moneys of the bank
before the time for paying them over has arrived, would
not be personally liable for the amount (//).
If an actuary, cashier, secretary or officer receives any
sum or sums of money fi*om or on account of a depositor
or on account of the bank, and does not forthmth, or in
the case of local receivers within the time specified in the
rules, duly accoimt for and pay over the same to the
trustees or managers or to such persons as may be directed
by the rules, he will on conviction be guilty of a misde-
meanor (/).
All officers upon demand are bound to account for and
deliver up all monej^s, effects, funds or securities, books,
papers or property, belonging to the bank in their hands,
by order of not less than two trustees and three managers,
or at any general meeting of the trustees or managers : on
default, the trustees may exhibit a petition to the Quarter
Sessions, who may proceed in a smnmary way, and make
such order upon hearing all parties concerned, as they may
think just, and such order will be final {J).
Trustees. — All moneys, goods, chattels and effects what-
ever, and all rights or claims, belonging to a savings' bank
are vested in the trustees for the time being, without a
fresh assignment or conveyance being necessary on the
death or removal of any one or more of them (/.) ; and in
all criminal or ci^il proceedings shall be stated to be the
if/) Ux parte Hidden, 3 M., T>. & De G. SO.
(/() Walker v. Guarantee Association, 18 Q. B. 277.
(0 26' & 27 Vict. c. 87, s. 9.
U) Id. B. 13.
(/.) Id. a. 10.
TRUSTEES.
property of the person or persous appointed trustee or trus-
tees for the time being- in his or their proper name mthout
further description (/).
No trustee or manager is personally liable, except for
his o-N\'n acts and deeds : he is not personally liable for
anything done by him in \drtue of his office, except in cases
where he is guilty of ^^ilful neglect or default {»i).
A trustee or a manager of a savings' bank in Ireland,
having declared in -^Titing under his hand deposited with
the Commissioners for the Eeduction of the National Debt,
that he is willing to be answerable for a specific amount
only, such amount being in no case less than 100/., will
not be liable to make good any deficiency arising in the
fimd-s beyond the amount specified (//). This provision is
not applicable to managers or trustees of sa^sings' banks in
England.
Nevertheless, every tmsteee and manager is personally
responsible and liable for all moneys actually received by
him on account of or for the use of the bank, and not paid
over or disposed of according to the rules (m).
But a trustee or a manager who is robbed of moneys
before the time for paying them over, according to the rules,
has elapsed, would not be personally liable to replace or
restore the amount (o).
A trustee of a savings' bank may be indicted under the
24 & 25 Yict. c. 96, s. 80, as a fraudulent trustee for the
misappropriation of moneys deposited with him {]>).
For other points of minor importance the reader is re-
ferred to the statutes respecting savings' banks (q).
Military, Naval and Post Office Banks. — The legislature
has provided by special measui'es for the establishment
(/) 26 & 27 Vict. c. 87, s. 10.
(;«) Id. s. 11.
(«) Id. s. 12.
{o) Walker v. Guarantee Association, IS Q. B. 277.
[p] Fuy. V. Fletcher, 31 L. J., M. C. 206.
{q) Exemptions from stamp and other duties iu favour of savings'
banks, 26 & 27 Vict. c. 87, s. 50 ; 3 •& 4 Will. 4, c. 14, s. 19 ; from in-
come tax, 5 & 6 Vict. c. 3o, s. 88.
271
272 savings' banks.
of military savings' banks, wliich aro exempted from the
operation of the enactments respecting savings' banks in
general (r) : of savings' banks for seamen (s), of savings'
banks for the Royal Navy and Marines {t), and of Post
OfSco savings' banks having the direct secmity of the
State for repayment of the deposits («).
{>•) 22 & 23 Vict. c. 20.
(s) 17 Sc 18 Vict. c. 101, s. 180 ; 19 & 20 Vict. c. 41 ; 25 & 20 Vict.
c. 63.
(0 29 & 30 Vict. c. 43 ; 32 & 33 Vict. c. 59.
{/i) 2i Vict. c. 14 ; 26 Vict. c. 14 ; 29 & 30 Vict. c. 5 ; 82 & 23 Vict.
c. 69.
( ^73 )
CHAPTER XXX.
THE RELATIONS OF PUBLIC BODIES, COMPANIES, AND OF
PERSONS FILLING REPRESENTATIVE CHARACTERS TO
BANKERS.
Trustees and Commissioners of Public Bodies. — Trustees
and commissioners of public bodies, provided they act in
accordance mth tbeii- statutory powers, are, as a rule,
exempt from personal liability {a). They may, however,
make themselves personally liable by pledging their own
individual credit, and not that of the funds at their
disposal ; or, if they have acted beyond their authority, as,
for instance, by borrowing money not in conformity with
their borrowing powers, on an implied warranty that they
possessed the authority they held themselves out as pos-
sessing {!)).
Companies. — In dealing with joint stock companies it is
material for bankers, before they make advances, to ascer-
tain whether the directors^ who represent the company, have
power to borrow money ; if they have not, such advances
will not, in law, be recoverable from the company as a
debt (c). In equity, however, a company may be com-
pelled to refund money improperly borrowed by its direc-
tors, if such monies have been applied to paying debts
previously contracted by the company [d). "Whether the
directors of a company can bind the company by borrow-
ing money depends upon the nature of its business, and
upon its charter, act of parliament, deed of settlement or
(a) See 10 & 11 Vict. c. 16, s. CO.
(b) See Parrot v. Eyre, 3 M. & Sc. 857 ; 10 Bing. 283 ; Eaton V. Bellj
5 B. & Aid. 41 ; Higgins v. Livingstone, 4 Dowl. 355.
(c) Ex parte Chippendale, 4 De G., Mac. & G. 19 ; Bimnester v. Norris,
6 Exch. 796 ; National Permanent Beneft Building Societij, supra.
{d) National Permanent Benefit Society, L. R, 5 Ch. 309; Cork and YoughaU
JRailway Company, L. R., 4 Ch. 7-lS.
274 RELATIONS OF TUBLIC BODIES, ETC. TO BANKERS.
regulation (^). It is important to remember tliat the
directors of a company forbidden, or not possessing tbe
power, to borrow may nevertheless bind the company by
overdrawing its banMng account; and, provided such
overdraft is made in the ordinary course of business, the
bankers may recover from the company (./'). An overdraft
is distinguishable from a loan. Where directors borrow in
excess of the limited power of borrowing conferred upon
them by the articles of association, the act is ultra vires the
articles only, and may nevertheless be ratified by the com-
pany, and so become binding upon it. Alifer, if the com-
panifs power to borrow is exceeded {g).
Liability of Liahility of D?Vw/or.s.— Directors who boiTOW money
directors. ^^^^^.^ ^,^y^^ ^^^^^ l^g rendered Kable in damages for breach of
an implied warranty that they possessed the authority to
borrow they represented themselves as possessing (A) ; but
where these powers are readily ascertainable, and the other
contracting party chooses to deal with them without
inquiry, it would seem, in the absence of fraud, that the
directors could not be held responsible, nor are they liable
for a bond fide mistake as to the legal extent of the autho-
rity ii).
Three directors of a railway company opened, on behalf
of the company, an account with a banlc, and sent a letter
signed by the three as directors, requesting the bank to
honour cheques signed by two of the directors and counter-
signed by the secretary. The accoimt ha\ing been largely
overdrawn by means of such cheques, the bank sued the
company, recovered judgment, and issued an elegit. The
proceeds being insufficient to satisfy the debt, the bank
{e) Lindley on Partnership, p. 269. As to trading companies, see JTamil'
ton Windsor Iron JForks, In re, ntnian ^- Edwardu, Ex parte, 12 Ch. D. 707.
(/) Watcrlow v. Sharp, L. E.., 8 Eq. 501; In re Cefn Cilcen Mining
■Compam/, L. R., 7 Eq. 90; Beattic v. Lord Ebunj, L. R., 7 Ch. 777;
L. R., 1 H. L. 102 ; 41 L. J., Chanc. 804.
{(j) Irvine v. Union Bank of Australia, L. R., 2 App. Ca. 3G6, 380. See
also on this subject, Rotjal British Bank v, Tnrquand, 5 E. & B. 248 ; 6 E:
& B. 327.
(/<) Itivhardson v. Williamson, L. R., 6 Q. B. 296.
(') 8oe Lindley, p. 367.
TRUSTEES, EXECUTORS AND OTHERS. 275
filed a bill iu eqiiity to make the directors personally
liable. It was determined that the letter did not make the
directors personally responsible for the debt, for that,
assuming the letter to contain a representation that the
directors had power to overdraw the account, and such
representation to be erroneous, this was not a misrepre-
sentation of fact which the persons making it were boimd
to make good, but only a mistaken representation of the
law ; and, moreover, that even if it had been such a false
representation as the directors were bound to make good,
the bank would have had no claim against them, since it
had been able to enforce the same remedies against the
company as if the representation had been true (i).
Two of the directors of a joint stock company, by a letter
to the company's bankers, notified that their manager had
authority to di-aw cheques on acceount of the company.
Such two directors did not form a majority of the directors
of the company, as required by their act of incorporation, so
as to bind the company. Although the company's accoimt
was at the time overdrawn, and that fact was known to
the two directors, the bankers honoured the manager's
cheques on the authority so given to them. In an action
by the bank against the two directors for advances made
on account of the company upon the faith of their letter : —
Held, that there was an implied warranty on their part,
and that they were personally liable to the bank to the
extent of the smns overdrawn by the manager subsequently
to the date of their letter {j) .
Trustees, Executors and others. — For the guidance of Trustees,
trustees, executors and other persons filling representative others,
characters, in dealing with bankers, and vice versa, it will
be useful to state some principles, with brief illustrations.
(0 Beattiev. Lord Ebimj, L. E., 7 Ch. 777; L. R., 7 H. L. 102; 41
L. J., Chanc. 804.
(y) Cherry v. Colonial Banh of Australasia, L. E.., 3 P. C. 24; 6
Moore, P. C. C, N. S. 235. See also Weeks v. Bropcrt, L. R., 8 C. P.
427 ; JiicJiardso?i v. WiUiamson, L. R., 6 Q. B. 276.
t2
276 KELATIOXS OF PUBLIC BODIES, ETC. TO BANKERS.
A trustee or executor wlio lias deposited trust money in
a bank pending investment, and not for an undue and
unnecessary period, will not te liable on failure of the
bank. But if a trustee or executor lias unnecessarily left
trust monies in the bands of a banker wbicb be ougbt to
have invested, and bas paid funds into a bank for tlie
purpose of investment, and neglected for some time to
make inquiries as to sucb investment, be will be liable in the
event of the bank's failing, and this notwithstanding the
usual clause of indemnity against tbe acts and defaults of
others [k). The following cases will illustrate these rules.
The executors and trustees under a will, having con-
tracted to purchase land, sold out stock just before the
time at which the purchase was to be completed, and de-
posited the proceeds, intending merely a temporary deposit,
in the banking house mth which the testator for many
years had kept an account, and the principal clerk in
which had been his confidential adviser in pecuniary affairs.
The bank failed -svith the deposit in its possession : — Held,
that the executors were not responsible (/).
A., at his death, had about 2,000/. in the hands of his
bankers, and his executors paid some monies which they
had received on account of the estate, to their account at
the same bankers, and drew out such sums as they re-
quired from time to time. About nine months after his
death the bankers became bankrupt, having, at that time,
a balance of about 2,000/. belonging to the estate in their
hands, and of which the smn of 1,000/. was ultimately lost
by their bankruptcy. The Master, on a reference, found
that there were not any purposes of their trust which ren-
dered it necessary for the executors to retain the balance
with the bankers, but the Court was of opinion that the
executors were not answerable for the loss (w).
(A) Ftinvick V. Clarke, 31 L. J., Chanc. 728 ; Challen v. Shippam, 4 Hare,
655; JicJidcn v. Wesley, 29 Boav. 213; Matthews v. £rise, G Beav. 23'J.
{I) France v. Woods, Taral. R. 172.
(m) Johnson v. Newton, 11 Hare, ICO.
TRUSTEES, EXECUTORS AND OTHERS. 277
Executors of a testator, who died in 1862, had, in
March, 1865, a balance of nearly 3,000/. at their bankers,
who had been his bankers for twenty years. The estate
realized more than 30,000/., and considerable sums were
from time to time required to be paid into and out of the
account, and the balance was larger than it would other-
wise have been in expectation of a mortgage having to be
paid off. A loss having resulted from the failure of the
bank, the executors were held not justified in keeping a
balance of more than 1,000/., and the loss upon the excess
above that sum had to be borne by them (w).
An administrator who had deposited trust monies in a
private bank on a separate account current, using ordi-
nary prudence, was held not to be liable for the loss of
the monies tlirough the failure of the bank, although the
monies had been suffered to remain so deposited for three
and a-half years after the death of the intestate, and for
nearly a year and a-half after the administrator had carried
into chambers, in the suit, his accounts showing a large
balance against himself (o).
A sole executor and trustee of personal estate of a tes-
tator, in trust for his widow for her life, and after her
death, to pay or otherwise divide it in equal shares
amongst his children, paid 300/., part of the assets, into
an old-established bank at Chichester, who had for many
years been his own bankers, with a direction in writing to
invest the money in Consols in his name for the pm'poses
of the trust. Instead of doing so, the bankers, without
his knowledge, opened a new account with him, in which
they gave him credit for 300/., the executor and another
person, his partner, having a joint account with the bank
in which no notice of the 300/. appeared. The executor,
relying that the investment had been duly made, never
called for the transfer note, or made any other inquiry,
and remained in ignorance that the investment had not
(«) Asthury v. Bcaslcy, 17 W. R. 038.
(o) Finch v. Marcon, 40 L. J., Chauc. 537.
278 RELATIONS OF PUBLIC BODIES, ETC. TO BANKERS.
been made until tlie bankers became bankrupt, a period of
nearly five months. The executor proved for the 300/.
imder the flat^ and insisted that he was not bound to
account for more than the dividend received, alleging that
the employment of bankers was the necessary and only
course available to a person resident in the country, to
invest money in the government funds ; but he was decreed
to pay the whole 300/. with interest at 4 per cent. {p).
By a decree made in an administration suit, a contract
for the sale of property belonging to an estate was to be
carried out by a trustee, but there were no directions given
as to the payment or receipt of the purchase-money. The
trustee, with the acquiescence of the solicitor of the tes-
tator, and others interested under his will, deposited the
purchase-money in a private bank, at interest. The bank
afterwards failed : it was held, that the trustee was not
liable for the money so lost ; and he would not have been
liable even if the money had been deposited so as not to be
repayable on demand {q).
So if a trustee, or other person standing in a fiduciary
position, mixes trust money with his own so that it cannot
be separated with perfect accm'acy from the latter, the cestui
que trust has a right to resort to the whole of the trustee's
property for what is due to him (r).
On the same principle an attorney paying in his client's
money to his bankers to his own accomit, mixing it with
his own, is liable on the faihu'e of the bank to pay the
whole to the client (s) .
So when a trustee pays trust money into his banker's
accoimt, thereby mixing his money with his OAvn, subsequent
sums drawn out by him will bo attributed to the earliest
items on the credit side of liis account for the time being,
and the trust money will in this way in its turn be con-
(;j) C'haUcn v. Shippam, 4 Hare, 5.55.
('/) li'ilkcs V. Groomc, 3 Drew. 584.
{)■) Sec CooJc V. Addison, L. R., 7 Eq. 471.
(v) Robbmn v. Ward, R. & M. 274 ; 2 C. & P. 59.
PAYMENT BY BANKERS. 279
sidered as di-awn out, wlietlier or not tlie result "be tliat
a balance remains of Kis O'svn monies {I).
H. having a balance of 3,961/. lO.s;, 3(/. at liis bank paid
in 5,000/. trust money. Between the time of doing so and
his death he paid in various simis together amoimting to
12,847/. 4.S. 4f/; No part of the sum was devoted to the
purposes of the trust, and he was stiU liable for the 5,000/.
at the date of his death :— Held, that the balance remaining
at his bank foi-med pai-t of his general estate, and could not
be appropriated by the beneficial owner of the 5,000/. {t).
But when a customer has opened with his bankers sepa-
rate accounts specially headed with the name of the trusts
to which the monies paid into those accoimts belong, the
bankers are not at liberty, upon the bankruptcy of the cus-
tomer, to apply those monies in pajanent of the balance
due to them upon the customer's overdra^vn private
account (?^?).
So if an aecoimt is opened as an executorship aecoimt, the
bank is affected with notice of all such equities as may be
attaching thereto (r).
Payment hy Bankers. — One of several trustees cannot, Payment by
Tinless expressly authorized to do so, give a good receipt tmstees o?
by himself, and his .co-trustees must join {y). executors.
So payment by bankers to one of several trustees, of the
proceeds of stock, sold out under a joint power of attorney
from the trustees, does not discharge the bankers as against
the other trustees, unless the trustee is authorized by the
others (;:).
Formerly at law the signature of a trustee was con-
clusive evidence that he had received the money ; but in
equity he was and of com-se still is permitted to show that
{t) Broicn v. Adams, L. R., 4 Ch. 764 ; 39 L. J., Chanc. G7. See also
Ve)inelly.Bcffdl,4.-D.,M.ScG^.^n. ^ . ^ , „,
iw) Exiyarie Kingston, L. R., 6 Ch. 632 ; 40 L. J., Bank. 91.
[x) Bailey V. Finch, L. E., 7 Q. B. 34 ; 41 L. J., Q. B. 83 ; 20 W. E.
294. _
\y) Walker v. Symonds, 3 Sw. 63 ; Lee v. Sankey, L. R., lo Eq. 204.
(s) Stone V. Marsh, R. & M. 3G4.
280 RELATIONS OF PUBLIC BODIES, ETC. TO BANKERS.
he merely joined in the receipt for the sake of conformity,
and that he never in fact received the money (b). A
trustee, therefore, may safely permit his co-trustee to
receive or collect trust monies (c). In the case of executors,
inasmuch as one executor can alone give a good discharge,
it was formerly thought this privilege did not attach, but
the rule seems now to he as follows : "If the receipt be
given for the purpose of mere form, the signing will not
charge the person not receiving ; but if it be given under
circumstances purporting that the money, though not
actually received by both executors was loido' the control
of both, such a receipt shall charge ; and the true question
in these cases seems to be whether the money was under
the control of both executors" {d). A trustee is, more-
over, liable if he permit his co-trustee to retain trust funds
for a longer period than necessary (e).
Where a married woman and A. were appointed exe-
cutrix and executor of a "^dll, but the husband dissented
from his wife's administering, and probate was refused to
her, and the bank owed a balance to the testator and had
securities of his in their hands, and paid the balance and
delivered the securities to the wife ^\ithout knowledge of
the husband's dissent, or the refusal of probate, the bank
was held to have a good defence to an action by A. to
recover the same (/).
So payments by an executor cle son tort to a bank in
satisfaction of debts owing to the bank by the deceased, in
respect of an overdrawn account, the executor cle son tort
really acting at the time as executor, so that the bank
might reasonably suppose him to be rightful representative,
are good, and the bank may retain them against the repre-
sentative of the deceased (g).
{b) Brice v. Stolces, 2 "W. & T. L. Ca. 865 ; Fdlous v. MitcIicU, 1 P. &
W. 81 ; and see now Jud. Act, 1873, s. 25, subs. 11.
(f) Toivnlcij V. Sherbourne, 2 W. & T. L. Ca. 858.
{d) Per Lord Redesdale, in Joy v. Campbell, 1 Sch. & L. 341.
[c) Brice v. Stokes, supra.
(/) Femberton v. Chapman, 26 L. J., Q. B. 117; 7 EI. & Bl. 210.
(V) Thompson v. Kardinj, 2 El. & Bl. C30.
PAYMENT BY BANKERS. 281
If a banker, employed to receive and to pay over the
assets of a testator, pays them over, so that they may be
applied for the purposes of the will, he is not responsible
for the executor's misapplication, but if, in dealing with
the executor, he pays the assets for the private purposes of
the executor, he is particeps criminis in a breach of trust,
and he is equally a party to the breach of trust, whether
he applies the money to the debt or to the trade of the
executor (h) .
If the bankers of trustees WTongfully sell out stock of the
trustees, and apply it to their own purposes, the measure
of their liability is the sum paid in replacing the stock (i).
If one of the banking firm sells the stock unkno^vTi to
the partners, but under circumstances such that they
might, by the exercise of proper diligence and attention
have discovered it, equity will impute knowledge, and hold
them all liable (J), even though the selling of stock did not
come Avithin the scope of the fii-m's business. Where it
does so, knowledge is not necessary as previously stated (k).
If one executor places the testator's money in the hands
of the other, who happens to be a banker, so that the act
is not an improvident act, the executor depositing is not
chargeable in case of a loss, inasmuch as if he had been
sole executor, and had under the same circimistances de-
posited at a bankers, he would not have been liable (/).
If three executors have an account in their names with
a banker, and one draws a cheque, it seems the bankers
may refuse to cash it, if they have received notice from one
of the others, not to part ^^ith the money (;«) .
As has been already suggested an executor placing
money which he ought to have invested in his banker's
(A) See pe7' Sir J. Leach, in Keane v. Robarfs, 4 Mad. 332, 358. See
Davis V. Spurling, 1 Russ. & M. 64.
(i) Sadler v. Lee, 6 Beav. 324.
[j) Ex parte Heaton, Buck, 386 ; Sadler v. Zee, 6 Beav. 324.
{k) Ante, p. 252.
(l) Chambers v. Minchin, 7 Ves. 198 ; 2 Wms. Exors. 1552.
{m) Gaunt v. Taylor, 2 Hare, 413.
282 RELATIONS OF PUBLIC BODIES, ETC. TO BANKERS.
hands, mixed with his own account, is liable for the amoimt
on the failure of the hanker (w).
The mere fact that an executor has opened an account
with a banker as executor, does not entitle the banker to
rank as a creditor upon the testator's estate in respect of an
overdrawn balance of the account (o).
Receiver. Receiver. — A receiver under an order in Chancery is
not hable for sums deposited ydih a banker in good credit,
provided there is nothing to attach fraud, and no laches,
(as if he has left the money an miwarrantable time in the
banker's hands,) on the failui'e of the banker. In such a
case a receiver will be liable, if he leaves money in the
hands of his bankers, and receives interest upon the simas
so deposited, and the bankers fail {p).
{») Fletcher v. IFalker, 3 Mad. 73.
(o) Farhallx. Farhall, L. E,., 7 Cli. 123 ; 41 L. J., Chanc. 146.
{p) Drevcr v. Matideslei/, 8 Jiir. 547.
( 283 )
CHAPTER XXXI.
LIBEL ON BANKERS.
Bankers, in partnersliip, could always join in maintaining
an action for a libel against tliem in respect of tlieir busi-
ness and touching their credit, without disclosing the ratios
or shares in which each of them was interested in the con-
cern {a) ; but imtil recently only joint damages could have
been given in such an action, and any separate damage for
injury caused to any individual partner was not recoverable
by him. But now, by Ord. XVII. r. 6 of the Judicatm-o
Acts, claims by plaintiffs jointly may be joined with claims
by them or any of them separately against the same
defendant. Consequently in a case like that under con-
sideration, where one partner has suffered some especial
injury, he may now recover damages in respect thereof as
well as joint damages with the firm {b).
The firm itself, however, cannot recover damages for any
private iujmy caused to one of its partners, nor, on the other
hand, where one partner has been Hbelled qua his private
capacity, can he recover damages caused to the fmn.
To say of a banker that he has suspended pajTiient is
actionable : for it is saying that he cannot pay his debts ;
and a temporary inability to pay debts is insolvency ; and
such action is maintainable, without alleging or showing
special damage {c) ; and it has been held, that where such
an imputation has been made against one partner, the credit
of the firm is also reflected upon, and that the partner, the
firm, or both, may sue for damages (d) .
(«) Ward V. Smith, G Bing. 749 ; 4 C. & P. 302 ; Ze Fami v. Maleolmson,
1 H. L. Cas. 637; Forstcr v. Zctivson, 3 Bing. 452 ; 11 Moore, 360 ; Robiu'
son V. Marchant, 7 Q. B. 918 ; Eaythorn v. Lawson, 3 C. & P. 196.
ih) See Booth v. Briscoe, 2 Q. B. D. 496 ; 2.5 W. R. 838.
Ic) Forstcr v. Zatcson, supra.
(d) Harrison v. Bcvington, 8 C. & P. 708.
( 284 )
CHAPTER XXXII.
CRIMINAL LIABILITY OF BANKERS.
A CLEAR opinion was expressed by two judges in a case
already referred to (a), that a banker who negotiated bills
intrusted to his care, knowing himself to be on the eve
of bankruptcy, would (notwithstanding that it was the
usage of the county of Lancaster amongst bankers) run
great hazard of incurring the penalties enacted in 52 Geo.
III. c. 63, a statute passed to prevent the embezzlement
of securities for money deposited for safe custody or for
any special purpose with bankers. That statute is now
repealed ; but similar provisions were first substituted by
the 7 & 8 Geo. lY. c. 29, ss. 49, 50, and by the 20 & 21
Vict. c. 54, which were subsequently consolidated in 1861
in one statute.
The consolidating enactment, 24 & 25 Vict. c. 96, s. 75,
is as follows : —
As io Frattds hj Agents, Banlcers, or Factors. — Whoso-
ever, having been intrusted, either solely or jointly with
any other person, as a hanher, merchant, broker, attorney
or other agent, with any money or security for the pay-
ment of money, with any direction in writing, to apply, pay
or deliver such money or security, or any part thereof
respectively, or the proceeds or any part of the proceeds of
such secmity for any purpose, or to any person specified
in such direction, shall, in violation of good faith and con-
trary to the terms of such direction, in anywise convert to
his own use or benefit, or the use or benefit of any person
other than the person by whom he shall have been so
(rt) Thompson v. Giles, 2 B. & C. 427, 434, ante, p. 141.
MISAPPROPRIATING SECURITIES. 285
intrusted, such, money, security, or proceeds, or any part
thereof respectively ; and whosoever, having been intrusted
either solely or jointly with any other person, as a banker,
merchant, broker, attorney or other agent, with any chattel
or valuable security {h), or any power of attorney for the
sale or transfer of any share or interest in any public stock
or fund, whether of the united kingdom or any part
thereof, or of any foreign state, or in any stock or fund of
any body corporate, company or society, for safe custody,
or for any special purpose, without any authority to sell,
negotiate, transfer or pledge, shall, in violation of good
faith, and contrary to the object or purpose for which such
chattel, security or power of attorney shall have been in-
trusted to hun, sell, negotiate, transfer, pledge, or in any
manner convert to his own use or benefit, or the use or
benefit of any person other than the person by whom he
shall have been so intrusted, such chattel or security, or
the proceeds of the same, or any part thereof, or the share
or interest in the stock or fund to which such power of
attorney shall relate, or any part thereof, shall be guilty
of a misdemeanor, and, being convicted thereof, shall be
liable to be kept in penal servitude for any term not ex-
ceeding seven years, and not less than five years (by 27 &
28 Yict. c. 47, s. 2), or to be imprisoned for any term not
exceeding two years, with or without hard labour, and
with or without solitary confinement.
But nothing in this section contained, relating to agents,
shall affect any trustee in or under any instrument whatso-
ever, or any mortgagee of any property, real or personal,
(b) By sect. 1, the term "valuable security" is defined to include any
order, Exchequer acquittance, or other secm-ity whatsoever, entitling or
evidencing the title of any person or body corporate to any share or
interest in any public stock or fund, -whether of the United Kingdom, or
of Great Britain, or of Ireland, or of any foreign state ; or in any fund
of any body corporate, company or society, whether within the United
Kingdom or in any foreign state or country ; or to any deposit in any
bank, and also any debenture, deed, bond, bill, note, warrant, order or
other security whatsoever, for money or for payment of money, whether
of the United Kingdom, or of Great Britain, or of Ireland, or of any
foreign state ; and any document of title to lands or goods.
CRIMINAL LIABILITY OF BANKERS.
in respect of any act clone by such trustee or mortgagee,
in relation to tlie propei-ty comprised in or affected by any
sucb trust or moi-tgage ; nor shall restrain any hanker,
merchant, broker, attorney or other agent from receiving
any money which shaU be or become actually due and pay-
able upon or by virtue of any valuable secui'ity, according
to the tenor and effect thereof, in such manner as he might
have done if this act had not been passed ; nor from selling,
transferring, or otherwise disposing of any securities or
effects in his possession, upon which he shall have any lien,
claim or demand, entitling him by law so to do, unless such
sale, transfer, or other disposal shall extend to a greater
number or part of such secm^ities or effects than shall be
requisite for satisfying such lien, claun or demand.
By sect. 76, whosoever, being a hnuker, merchant, broker,
attorney or agent, and being intrusted, either solely or
Jointly with any other person, with the property {c) of any
other person for safe custody, shall, with intent to defraud,
sell, negotiate, transfer, pledge, or in any manner convert
or appropriate the same or any part thereof to or for his
own use or beneiit, or the use or benefit of any person
other than the person by whom he was so intrusted, shall
be guilty of a misdemeanor.
But by sect. 85, nothing in these sections shall enable
or entitle any person to refuse to make a full and complete
discovery by answer to any bill in equity, or to answer any
question or interrogatory in any civil proceeding in any
Court, or upon the hearing of any matter in bankruptcy or
insolvency, and no person shall be liable to be con\ieted
by any evidence whatever in respect of any act done by
him, if he shall at any time previously to his being charged
(c) By sect. 1, the term " property" includes every description of real
and personal property, money, debts, lepacies, and all deeds and mstm-
ments relating,' to or evidencing the title or right to any property, or
giving a right to recover or receive any money or goods, and not only
such property as shall have been originally in the person or under the
control of any party, but also any property into or for which the same
may have been converted or exchanged, and any acquired by such con-
version or exchange, -whether immediately or otherwise.
DISCLOSURE OF CIRCUMSTANCES. 287
witli such offence have first disclosed such act on oath, in
consequence of any compidsory process of any Coiu't of
Law or Equity, in any action, suit or proceeding, which
shall have been bond fide instituted by any party aggrieved,
or if he shall have first disclosed the same in any compul-
sory exammation or deposition before any Com-t upon the
hearing of any matter in bankruptcy or insolvency.
And by sect. 86, nothing in these sections contained,
nor any proceeding, conviction or judgment, to be had or
taken thereon against any person imder any of the said
sections, shall prevent, lessen or impeach any remedy at
law or in equity, which any party aggrieved by any offence
against any of the said sections might have had if the act
had not been passed ; but no conviction of any such offender
shall be received in e\idence in any action at law or suit
in equity against him ; nor affect or prejudice any agree-
ment entered into or secm-ity given by any trustee, having
for its object the restoration or repayment of any trust
property misappropriated.
In a case of great importance and notoriety, in which
certain bankers, Strahan, Paul and Bates, had fraudulently
disposed of a number of Danish bonds, which had been
deposited mth them for safe custody, and for the pm-pose
of receiving the dividends upon them for the use of their
customer, who had deposited them, it was attempted to
take advantage of the proviso contained in the 52nd
sect, of the 7 & 8 Geo. IV. c. 29 (now repealed by the
24 & 25 Vict. c. 95, and sunilar to sect. 85 of the 24 & 25
Vict. c. 96, above referred to), by the bankers becoming
bankrupts, and, after they had been arrested and im-
prisoned on the criminal charge, making a voluntary
declaration in the Court of Bankruptcy as to the misappro-
priation of the securities : but the attempt failed.
They were indicted at the Central Criminal Court {d),
(d) The trial took place October 2G, 27, 1855, coram Alderson, B.,
Martin, B., and Willes, J. Sessions Paper, 18o4 — 1855, p. 695 ; 7 Cox,
C. C. 85.
288 CRIMINAL LIABILITY OF BANKERS.
for that, being "bankers and agents to John Griffith, clerk,
and being intrusted by him with certain bonds for safe
custody without any authority to pledge or make away
with them, in violation of good faith, did sell and convert
the same to their o^vni use and benefit.
Having pleaded not guilty, an application was made on
their behalf for permission to plead double by adding a
plea, alleging the fact of their having made the disclosm-e
above mentioned, with a view of avaihng themselves of the
52nd section of 7 & 8 Geo. IV. c. 29 ; but the application
being considered as resting on no authority, and made only
to the discretion of the Court, was refused ; and, as evi-
dence was afterwards admitted for the purpose of bringing
before the Court the steps which had been taken by the
prisoners in this matter, it may perhaps be regarded as
settled that, in future, any banker in like cii'cumstances
may avail himself of a defence similar to this to the cri-
minal charge, under the plea of not guilty, if at all ; and
that it is not necessary to plead it specially.
It was proved that the bankers had sold certain Danish
bonds, and transferred others belonging to Dr. Griffith, a
customer, who had deposited them with the prisoners, as
his bankers and agents, for safe custody, and in order that
they might obtain for him the dividends as they fell due,
and that he had never given them any authority to pawn
or seU the same or any part of them, and that he had never
overdi-awn his account mth them.
For the defence, it was proved, that on the 17th of June,
1855, one Montague John Tatham filed a petition for ad-
judication in bankruptcy against the bankers ; that they
were adjudged bankrupts on the same day, and afterwards
surrendered ; that they made a statement concerning the
disposal of the securities in question, without examination,
and not in pursuance of any order of the sitting commis-
sioner; that they made this declaration for the general
purpose of assisting the creditors, and for the special pur-
pose of making a disclosure under the 7 & 8 Geo. lY. c. 29,
DISCLOSURE OF CIRCUMSTANCES. 289
and that they were then questioned by the solicitor for the
fiat as to the truth of the statement, and each answered
(affirming its truth) " Yes." The commissioner had, pre-
viously to this, refused an application by counsel on behalf
of the bankrupts to be permitted to examine them with
reference to the statement as to the disposal of the securi-
ties, saying, " If any creditor applies for the banki-upts to
be examined, he can do so ; but, upon the banki^upts' own
application, I refuse it."
The bankers were convicted, and sentenced to fourteen
years' transportation.
In a recent case {e), having a considerable bearing upon
the points above determined, it appeared that an agent,
having been intrusted with a bill of lading, without the
authority of his principals and in violation of good faith
deposited the bill of lading mth his bankers, for his o^\ti
benefit, as a security for advances. He was charged with
this offence before a magistrate. The depositions taken in
support of the charge contained ample evidence to sustain
it. Having afterwards become bankrujit, he was taken by
his creditors and examined respecting the charge before a
commissioner in bankruptcy, and he then made a state-
ment in every respect in accordance with the evidence
contained in the depositions. He was afterwards indicted
on the same charge. On the trial his examination in
bankruptcy was tendered by his counsel as a defence, as
showing that he had disclosed the act before the commis-
sioner in bankruptcy previously to being indicted for the
offence, and that, therefore, he was not now liable to be
prosecuted or convicted; the Court of Criminal Appeal
imanimously held that this evidence of a disclosure was
admissible under the plea of not guilty, but the majority
of the Judges were, however, of opinion, that as the agent
only stated before the commissioner matter which had been
previously known, and previously proved before the magis-
(f) Reg. V. Sl-cen, 28 L. J., M. C. 91 ; Bell, C. C. 97.
n U
290 CRIMINAL LIABILITY OF BANKERS.
trate, he had not made any disclosure within the meaning
of the statute, and that, consequently, he was not entitled
to its protection. The minority of the Judges, however,
holding that, as the statement of the agent was obtained in
the course of a compulsory judicial examination, instituted
bond fide by the creditors for theii' own interest, it was a
disclosm'e before the commissioner, not-withstanding the
pre\T[ous inquiry and publicity of the matter.
The liability affecting dii-ectors for making false reports
of the solvency of their banks, and the prosecution and
pimishment of delinquent directors, officers, and managers
of insolvent banking companies on winding-up, will form
the subject of a separate consideration.
( 291 )
CHAPTER XXXIII.
DISCOUNTS.
Much of tlie business of bankers consisting in the dis-
counting of bills of exchange, it is necessary to state some
points of the law afPecting this matter.
The rule has been stated, that if a person holding a bill
of exchange delivers it to a banker to be discounted, or if,
by the course of dealing between the customer and the
banker, bills received by the latter, on accoimt of the
former, are considered by both parties as cash, minus the
discount, so that the customer is at liberty to di'aw on the
banker, as against those bills, beyond the amount of actual
cash that may be standing to his account in the books,
then, in the event of the bankruptcy of the banker, the
assignees of the bankrupt are entitled to the bills. For
where the banker discounts a bill for a customer, giving
him credit for the amount of the bill, and debiting him
vdth. the discount, there is a complete purchase of the bill
by the banker, in whom the whole property and interest in
it vest, as much as in any chattels he possesses {a).
Therefore, discomiting in this way makes the banker the
purchaser of the hill.
If, moreover, a person discoimts bills with bankers, and
receives as part of the discount other bills not indorsed by
the bankers, and these latter bills tm-n out to be bad, the
bankers are not liable ; for, having taken them mthout
indorsement, the holder takes the risk on himself, inas-
much as the bankers, by not indorsing them, have re-
fused to pledge their credit to their validity, and the
{a) Carstalrs v. Bates, 3 Camp. 301. See Ex parte WakeJieM, 1 Eose,
242 ; Thompnon v. Giles, 2 B. & C. 422, aud ante, p. 138.
U 2
292
DISCOUNTS.
transferee must be taken to liave received them on their
own credit only (/j).
So a banker discounting a bill, whether for a customer
or for a stranger, there being no indorsement by the cus-
tomer or stranger, and the bill not being given in payment
of an antecedent debt, is a mere pm'ohaser, and, on the
bankruptcy of the acceptor, has no recoiu'se against the
pai-ty from whom he took it (r).
A manager of a banking company had permission to
carry on his separate trade ; as a trader, he dealt with the
company on the terms usual between banker and customer,
and being possessed of certain bills in his character of
trader, di^a^vn and accepted by firms of good reputed credit,
he deposited them without indorsing them, and obtained an
advance upon them, his account at the time being already
slightly overdi-awn ; therefore, this transaction was a loan,
not a discount, and upon the bankruptcy of the drawers
and acceptors, the manager was held bound to make good
the loss to the bank {d).
Bankers discoimting a customer's bills at a time when
his accovmt is largely overdra^vn, and carrying the amount
to the credit of his account, are holders for value, though
no money actually pass (e).
Presumption
in favour of
bankers.
Presumption in favour of Banhcrs. — Such a degree of
credit is given to bankers by the Courts, that ^;;7»Ki facie
they will be taken to have discoimted mth good faith.
Thus, where a clerk was sent by his master, a customer of
a bank, to ask for discomit for a bill, but mth orders to
tell them, when he asked for it, the particulars of an
(A) Fyddl V. Clarl\ 1 Esp. 447 ; Emhj v. Lijc, \o East, 7 ; Bank of Eng-
land V. Newman, 1 Ld. Ilaym. 442.
(c) Bank of Engliml v. Newman, 1 Ld. Raym. 442 ; 12 Mod. 241.
{(l) ll'atkin V. VampheU, 1 Jur., N". S. 131.
[e) In re Carew, 31 Beav. 39. For cases supportin;^ the rule tliat a
fluctuatini^- balance may be a valuable conwideratiou for a bill, see Bease
V. Uirst, 10 U. & C. 122 ; Bichards v. .Maccy, 14 M. & W. 484. The onus
of provint;^ such a consideration is upon the payee. In re Boys, L. K.,
10 Eq. 407 ; 3a L. J., Chanc. C55.
SET-OFF AND MUTUAI, CREDIT IN BANKRUPTCY, ETC. 293
arrangement between the holder and the master, the Court
would not presume that the clerk told the bankers (who
discounted the bill) these circimistances, but, on the con-
trary, presimied that they bond fide discounted the bill
without notice of those circumstances, in the absence of
proof to the contrary (/). But when A. fi-audulently
obtained possession of the acceptances of B., and got them
discounted, and can-ied to his account by a banking com-
pany to which he was largely indebted at the time, and
of which he was a director and local manager, it was held
that the bank had notice, and coidd not be considered
bona fide owTiers because of their connexion with A. {g).
Set-off and Mutual Credit in case of Banh'uptcij under Set-ofE and
32 S^' 33 Vid. c. 71, s. 39.— Palmer, having bori'owed money ™^' ^^ ^'^^
from his bankers in Calcutta, deposited East India Com-
pany's paper mth the bank to a greater amount than the
debt, as a collateral secm-ity, and authorized the bank, in
defaidt of repa^nnent of the loan by a given day, to sell
the paper for reimbursement of the bank, rendering him
any sm'i)lus. Before default in repajTiient of the loan he
became insolvent : at the time of the insolvencj^, the bank
were also holders of two promissory notes of Palmer & Co.,
which they had discomited for them before the transaction
of the loan and the agreement as to the deposit of the
Company's paper. The time for the repayment of the
loan ha\ang expired, the bank sold the Company's paper,
the proceeds of which, after satisf;>ang the principal and
interest due on the loan, produced a considerable surplus.
In an action by the assignees of Palmer & Co., against
the bank to recover the surplus, it was held, that the
bank could not set off the amount of the two promissory
notes ; and that the clause of mutual credit in the Bank-
rupt Act did not apply. For though the bank gave credit
to Pabner for the notes they had discoimted for him,
(/) MiddJeton v. Barncd, 18 L. J., Exch. 433. -
{ij) In re Carcic, 31 Beav. 39.
294 DISCOUNTS.
there was uo corresponding credit given by liim to tliem; it
was uncertain whether there would be any money coming
to him or not, and the credit Avas all on one side (/?).
Bankers discounted for a customer bills of exchange to
a large amount, placing the amount to the credit, and
the amount of the discount, to the debit of themselves.
The customer became banki"upt, having at the time a
balance at the bank in his favour of 179/. 19.s. lid. The
bills were indorsed by the bankrupts in blank, and some of
them were paid by the acceptors before the bankruptcy ;
the others, far exceeding in amount the above sum, did
not become due till some time after the bankruptcy.
Before they became due, the assignees commenced an
action for money lent, to recover the balance, and subse-
quently, but still before the bills became due, the bankers
proved against the bankrupt's estate for the whole amount
of the bills, deducting the balance of 179/. 19s. lid.
There was held, in this case, not to be any purchase of
the bills, but merely a loan of money upon them {i) .
It is material to distinguish this case from the former:
in that there was no mutual credit ; the Company's paper
was deposited for a pai-ticular purpose, and no credit was
given for the sm'plus. Also, the duty of the assignees
there was to redeem the paper immediately, and if they
had done so, no debt whatever would have been due in
respect of the loan. Here was a mutual credit, and the
bankers being entitled to set off, the assignees could not
prevent their having the benefit of it, by bringing the
action too soon (/).
But though one of the debts constituting the mutual
credit need not bo due, it is necessary that tlic mutual
credit should have existed before the bankruptcy. So a
(/() Young v. Bank of Bengal, 1 Moore, P. C. 150 ; but sec Xaorojl v.
Chartered Bank of India, L. R., 3 C. P. 444 ; Londim, Bombay and Medi-
terranean Bank v. Xarraivag, L. R., 15 Eq. 93 ; Astleij v. Giirneg, L. R.,
4 C. P. 714.
(() Alsar/er v. C'urrie, 12 M. & W. 751, 757, 758. See Stare;/ v. Barns,
7 East, 435.
SPECIFIC APPROPRIATION OF PROCEEDS ON DISCOUNT. 295
bill drawn by a debtor and accepted by a creditor after
the former had assigned his property to trustees under the
.Bankruptcy Act, 18G1, but before registration thereof,
cannot be set off against prior acceptances of the debtor,
because the date of the deed and not the time of registration
is to be looked to, and at the former time there was no
mutual credit (/i).
Specific Appropriation of Proceeds on Discount. — Bills
were remitted to be discounted, the proceeds being directed
to be applied in a particular way : the remittee did not get
the bills discounted, but received the money on them when
due. Before that time the remitters had stopped payment,
having first desired to have the bills retm-ned to them :
and they became bankrupt before the bills were paid to
the remittee. The latter had to refund to the assignees
the whole of the money (/). And so bills remitted for sale,
the proceeds to be applied to a particular piu'pose, remain
the property of the remitters until the purpose is satis-
fied {m).
So, where a customer pays a sum of money into a bank,
for the pm-pose of providing for particular bills, he being
at the time indebted on advances to the bank to a larger
amount, and they, instead of following his instructions,
place the money to the credit of his account, and, conse-
quently, the bills are refused acceptance, and whilst they
remain unpaid in the hands of the holders the customer
becomes bankrupt, his assignees may recover the whole of
the sum from the bank («).
A branch of the National Provincial Bank of England
discounted for a customer a bill di-awn by him, and ac-
cepted by A. This bill, which v/as for 3G5/., was dated
(/.) Ex parte Ei/dcr, L. R., 6 Ch. Ap. 413; 40 L. J., Bank. G3 ; Sdbi/
V. Graves, L. E,., 3 C. P. 59i.
(/) Buchanan v. Fimllay, 9 B. & C. 738. See p. 138.
{»)) mUbjloU Scalx. Dent, 8 Moore, P. C. 319.
\n) mily. 8inith, 12 M. & W. G18; Farley v. Tariur, 26 L. J., Chauc,
710. Seep. 138.
296 J)ISCOL'NTS.
17tli January, and was at tkree months, and would conse-
quently become due 20th April. On the 19th the cus-
tomer brought another bill to the bank, for the same smn
as the former, dated 18th April, for the pm-pose of retiring
the former. The manager of the bank consented to retii-e
the former bill, but the coiu'se pursued was not strictly a
retiring of the bill ; for the com-se taken was, to send up
to London the fresh bill, giving directions to their London
agents to order pajnnent of the original bill, "^hich had
been pre\dously sent up to them by the manager. A. was
credited in his account \^'ith the amount of the bill, 365/.,
less the discoimt.
After some time, and various fmiher transactions be-
tween A. and the bank had taken place, the bill of the
18th April proved to be forged and was dishonoured.
Under these circmnstances it was contended, in an action
by the bank on the first bill against the acceptor, that
what had been done by the bank in regard to the first bill
was equivalent to a papnent of it, as they had given the
drawer credit for the smn for wliich it was di-awn, less the
discoimt ; but to this the Com't did not assent (o) .
"Where a customer places in the hands of his bankers
two bills for 1,000/., indorsed by him, for the amoimt of
which it is agreed he shall cbaw, the bankers having
refused to discoimt them, and the customer only di-aws
for 65/., and the bankers employ a broker to discount the
bills, and become bankrupt shortly after the bills are de-
posited, the customer is entitled to the proceeds of the
bills (;;).
Re-discount- Ee-(liscountinfj. — A customer drew a bill, which was
^^' accepted, payable at his bankers' ; he discoimted it with
the bankers, indorsing it to them; they re-discounted and
indorsed it to a third person.
On the matmity of the bill it was presented by the
(o) BcU\. Buckhu, 25 L. J., Exch. 163; 11 Exch. 031.
(p) Ex parte Hdtcarch; 2 M., D. & De G. 025.
ACCOMMODATIOX BILLS. 297
holder at the bank, along wdth other bills payable there,
all indorsed by the bankers ; all these were paid Ts-ithout
any indication whether the bankers paid as indorsers or as
agents for the acceptors ; the account of the acceptor of
this bill was overdraA\Ti at this time, and he stopped pay-
ment the same day.
Next day notice of dishonom- was given by the bankers
to the customer, and he was debited ^\ith the amoimt of it.
It was left to the jury to say whether the bankers paid
as indorsers on their own accoimt, or as agents of the
acceptor. The jury found that they paid in the former
character, which was tantamount to finding that the bill
was dishonom-ed, and they had a verdict, and the Court
held the bankers to have had a right to pay as indorsers,
reserving to themselves time to inquire whether they would
honour the bill or not, and that there was no obligation on
them to inform the holder in what capacity they paid {q).
Accommodation Bills. — "WTiere bankers discount for a
customer, the drawer, a bill accepted for his accommoda-
tion, which is dishonoured, and after that event, have notice
that it was an accommodation bill, and are requested by
the customer not to apply to the acceptor, to which they
assent, and afterwards the customer's account with them
shows a balance in his favour to a larger amount than the
bill, the bankers are bomid to discharge the bill out of the
balance, and cannot keep it as a security for the fluctu-
ating balance which might ultimately become due to them,
and, therefore, if they sue the acceptor, they ^\•ill be non-
suited {}').
It makes no difference that after the balance has been in
his favour, as above stated, the customer becomes greatly
indebted to the bank, and fails before action (r).
{q) Pollard \. Ogden, 2 EL & BL 459; see Attcnhorough v. Mackenzie,
25 L. J., Exch. 244.
{>■) Marsh v. Hoidditch, Chitty on Bills, 283, n., 10th ed. ; compare
Hammerslci/ v. Knowlys, 2 Esp. 665. As to what amounts to an accom-
modation bill, see In re London, Bombay, %e. Bank, L. R., 9 Ch. 686 ; 48
L. J., Bank. 683.
298 DISCOUNTS.
Death of Drawee. — Bankers, having discoimted for a
customer (wlio did not indorse) a bill di'a-\vn by B. on A.,
another customer, and accepted by him, payable at the
bankers' house, on the morning of the day on which it be-
came due, ^vrote it off in A.'s account to his debit, having
at that time in their hands 1,421/. to his credit. The
bill was for 467/. A. was at this time dead, but this was
imknown to the bankers at the time they debited A.
The bankers were held to be entitled, when the bill be-
came due, to reimbm-se themselves out of the acceptor's
fimds in their hands, having no notice of the death (s).
Conditional Conditional Indorsement. — The payee of a foreign bill
indorsement. ^^ exchange (one Eoberison) annexed a condition to his
indorsement before acceptance, thus, " Pay the mthin sum
to Messrs. Clerk and Boss, or order, upon my name
appearing in the Gazette as ensign in any regiment of the
line, between the 1st and 64th, if within two months from
this date, E. Eobertson."
The bill was dra-svn upon and accepted by Messrs. Ken-
sington & Co., bankers, in London, but not till after it was
indorsed by the payee, as above, and after it was indorsed
by Clerk and Eoss. There were several mesne indorse-
ments, until it came by indorsement to the Bank of Eng-
land, who discounted it. When the bill arrived at matu-
rity, including the daj's of grace, the Bank of England
presented it to Messrs. Kensington, by whom it was paid.
Eobei-tson's name never having appeared ui the Gazette
as ensign in any regiment of the line, the condition of tlie
indorsement was not performed; and, upon Eobertson
piling the acceptors for the amount of the l)ill, the Com-t
considered him to be entitled to recover, because Messrs.
Kensington had accepted after the condition had been
superadded to the bill, and that condition had been super-
added to the bill at the outset, and before it got into cir-
(s) Rogcrson v. Ladbrokc, 1 Biug. 93.
RESTRICTIVE INDORSEMENTS. 299
dilation, and tlie condition not ha\'ing "been performed, and
the acceptance ha^dng been made ■with knowledge of the
restriction, the property, in such case, reverted to the payee,
who had a right to come upon the acceptors at maturity,
just as if he had not indorsed at all (t).
Hence it follows, that such a bill cannot be safely dis-
counted without ascertaining that the condition on which
the payee indorses has been satisfied (ti) .
It has, however, been questioned whether it is allowable
by the custom of merchants to indorse a bill of exchange
ydih a condition which restrains the indorsee fi'om indorsing
over in a certain event (x).
Restrictive Indorsements. — The payee or indorsee of a bill
of exchange having the absolute o^^^lership in, and the j^ower
of disposal over, it, has like^^ise the power of limiting its
payment to whom he pleases, and of designating the
pm-pose for which such pajanent shall be applied, and
so to restrain its negotiability (y). Some considerable
difficulty frequently arises in deciding what does and what
does not amount to a restrictive indorsement. An in-
dorsement to " A.," without mentioning " or order," will
not amount to a restrictive indorsement, nor prevent the
bill from being negotiated ; for, the Courts leaning strongly
in favom' of the negotiability of a bill, nothing shoi-t
of express words or necessary implication will have that
eflect (s). The words "Pay to A. B. only," or "A. B.
and no one else," on the other hand, would clearly amomit
to a restrictive indorsement, so as neither to authorize in-
dorsement over or pa^Tuent to any other person {a).
Where the person uses words to show that the restrictive
[t) liobertson v. Kensington, 4 Taunt. 30 ; Savage v. Aldrcn, 2 Stark. 232.
(«) Ibid.
{x) Soarcs v. Gb/n, 8 Q. B. 2-i ; 14 L. J., Q. B. 313.
(y) Story on Bills, p. 229; Chitty on Bills, 174; Byles, 159; i:diev.
East India Companij, 2 Biut. 1227; 1 Bl. R, 295.
(-) Achcson V. Foioitain, 1 Sir. Ecp. 557 ; Edie v. East India Compang,
supra; Story, 230; Chitty, 174; Byles, 151, 161.
(«) Story, 231; Chitty, 174; Ediey. East India Company, supra.
300 -^ DISCOUNTS.
indorsement was made to the restricted indorsee as the
agent or trustee of the indorser, or of some third party
named by him, as " Pay to A. B. or order for my use," "Pay
to A. B. for my account," " Pay to A. B. for the use of
C. D. :" such indorsement, though it would restrain the
negotiahiHty of the bill, so far as to prevent the indorsee
fi'om indorsing or transferring it so as to convey any
beneficial interest in the bill, would not, it would seem,
necessarily restrict him from indorsing it so as to convey
a right of action upon it ; but every subsequent holder
would receive the money subject to the original designated
appropriation thereof, and, if he voluntarily assisted or
aided in any other appropriation, it would be a \\Tongful
conversion, for which he woidd be responsible (/>) . A banker,
therefore, discounting such a bill, does it at his peril, and
is bound to see to the application of the money paid by
him {h). So, where a bill of exchange was indorsed by the
payee generally to A., and by him to B., in these words,
" Pay to B. or his order for my use," and B. applied to
his bankers to discount the bill, and the}^, without making
any inquiry did so, and ajiplied the proceeds to the use of
B., it was held that the indorsement was restrictive, and
that the property in the bill remained in A., and that lie
was eiititled to recover the amount of the bill from the
bankers (f) .
The words, " the within must be credited to B., value on
accoimt," have been held to constitute a restrictive indorse-
ment (d) ; but not to the words " value in account mth
Oriental Bank" (^).
Acceptances Acceptances per Procuration. — An acceptance '^per proc."
pcrprocttra- -g r^^^ express notice to a person taking the bill, that tlie
authority of the agent is limited, and, consequently, a
(i) See Jfiirrnw v. Stuart, 8 Moore, P. C. 273. This case is contrary
to the doctrine laid down in Bj-lcs and Baylcy as to this kind of restric-
tive indorsement.
(c) Hicjourneij v. Lloyd, 8 B. & C. G22.
(d) Archer v. Bank of Enqlnnd, Doug. 638.
\e) Bucldnj V. Jackson, L". R., 3 E.x. 135.
AGENTS. 801
banker who discounts the bill cannot maintain an action
against the principal, if the agent has exceeded his
authority (/). But an acceptance in these words, " for
Eiehardson & Son, Thomas Popple," is not equivalent, in
mercantile law, to the form ^^ per jjroc. Richardson & Son,
Thomas Popple." The fonner expression does not, like
the latter, import a special and a limited authority to do
a specific act, nor does it put the drawer of a bill, accepted
in that form, upon discovery or inquiry, whether the agent
has exceeded his authority or not (g).
Indorsement per Procuration. — So an indorsement of a Indorsement
bill of exchange, ^' per proc.,'' is an express intimation that ^^^/'^^^'^'
the person indorsing professes to act imder an authority
from some principal, and imposes upon an indorsee, or a
banker discounting the bill upon the faith of such indorse-
ment, the obligation of ascertaining that the person so
indorsing is acting "sxTithin the limits and terms of his
authority ; and, consequently, if the indorsement is wholly
unauthorized by the principal, the banker "will not be en-
titled to recover against him (/c).
Agents. — A person who indorses a bill as agent ; though
if he has no authority to do so, cannot be rendered Hable
on the bill, even although the plaintiff show that he
acted maid fide (i). He may, however, be made liable on
(/) Staff!/ V. MlioU, 12 C, B., N. S. 373 ; 31 L. J., C. P. 2G0 ; Alexander
V. Mackenzie, 6 C. B. 766.
{g) 0' Evilly v. Richardson, 17 Ir. C. L. R. 74.
(//) Alexander v. Mackenzie, 6 C. B. 766 ; 18 L. J., C. P. 94. In mer-
cantile transactions there are two forms of indorsement of negotiable
instruments by an agent: one simply "p.," "pro," "for," which
expresses an authority generally; the other, "per pro," or "p. p.,"
which expresses an authority created by procuration or power of attornej-;
and, where a bill of lading was indorsed by an agent in the first of these
forms, it was held that the indorsement was not so irregular on the face
of it as to render a banker who was instructed to accept the drafts of a
third person on being handed a clean bill of lading of a cargo consigned
to the latter liable for neglect of duty. Ulster Bank v. Synnott, 5 Ir. R.,
Eq. 595.
[i) Wilson V. Barthrop, 2 M. k W. 863; Polhill v. Walter, 3 B. k Ad.
114.
302 DISCOUNTS.
an implied warranty that he had the authority he repre-
sented himself as having (/o). An agent applied to a
banking company on several occasions to discount bills
drawn by his principal, and at the commencement of the
transactions with them informed them who the drawer and
acceptors were of a bill which he applied to them to dis-
count, and they agreed to discoimt it without requiring the
agent's indorsement. Several subsequent discounts took
place under similar circumstances ; but upon some of the
bills offered, they required and obtained the agent's in-
dorsement. The acceptances turned out to have been
forged by the principal, of which fact the agent was wholly
imaware.
The agent became bankrupt, and it was held, there
being nothing to show that the agent had not handed over
the proceeds of the bills to the principal, or that the
proceeds could be recalled, that the banking house could
not prove upon the bills which the agent had not in-
dorsed (/).
A person receiving a bill to get discounted has no
authority to deal with it otherwise than for discount, and
a deposit of it along "svith other bills, with a bill broker, as
a security for advances, is beyond the scope of the autho-
rity, and passes no property (/«).
BanJirrs^ Commission. — With regard to commission, it
seems obvious, and has been expressly laid down, that a
banker is as well entitled to his commission for his trouble
in transacting money negotiations, as a factor, for his
trouble in effecting sales ; commission is a la-wf ul charge,
provided it is reasonable and usual (»), this last fact being
(yt) CoUen v. Wright, 7 E. & B. 301; ToIhiU v. Walter, supra.
(/) Ex parte Bird, 4 De G. & S. 273. A person wlio docs not indorse a
bill may, nevertheless, be compelled to repay tlie money he has obtained
on it, siioidd it turn out a forj^ery, as on a consideration tliat has failed.
Jones V. Ryde, h Taunt. 488 ; I'olhill v. Walter, 3 B. & Ad. 114.
(»«) Herschfeld V. Jlroini, 3 F. & F. 219.
(w) Curtis V. Livcset/, cited 4 M. & S. 197; Ex parte Gwyn, 2 Deac. & C.
12 ; Wimh v. Fe>ni, 2 T. R. 02, n.
bankers' commission. 303
a qnestion for the jury(o). Commission may also be
charged for the trouble of obtaining the acceptance and
payment of bills {p).
Charging commission for collecting bills does not impose
upon the bankers a liability to give notice of dishonoiu* in
case the bills are not paid on presentment ( q) .
(o) Masterman v. Coterie, 3 Camp. 488 ; Carstairs v. Stein, 4 M. & S. 192 ;
Hammett v. Yen, 1 B. & B. 144.
(jo) Bayncs v. Frii, 15 Ves. 120.
(y) In the case of As/i worth v. 3Iiller, tried before Mr. Justice Mellor
and a special jiuy at Manchester, 22nd March, 1865, it appeared that it
was an action brought to recover from the defendant, as the public officer
of the Manchester and Liverpool District Bank, the value of a bill of ex-
change for 272/. 9s. M., which had been handed to them by the plaintiff
for collection, and of the dishonour of which they had not given him due
notice, whereby he was unable to recover against his indorsers. It
appeared that the plaintiff was a cottou-waste dealer and spinner at
Rochdale, and the banking company had a branch bank there with a
manager. In September, 1864, the plaintiff took the bill from Fielden &
Co., of Rochdale, in discharge of an account for 166^., handing them the
difference. The plaintiff kept no account with the bank, but had been
in the habit for years of handing them cheques for collection, for
which the bank charged commission and handed him the proceeds. The
bill became due on the 24th of November, 1864, and on the 18th of
November the plaintiff left it with the cashier of the bank, who said he
would do the business for him. On the 30th of November, the plaintiff
called again at the bank, and was then informed that the bill was dis-
honoiu'ed, got the bill back, and paid the bank charges — 22*. M. Upon
the plaintiff, on the same day, applying to Fielden & Co., they disclaimed
all liability on account of the delay, and so did the previous indorsers
upon being applied to. The defence on the part of the bank was that
they never gave notice of dishonour to casual customers, who were told
to call on the day the bill would be returned, and that such was the
custom and usage of bankers ; and, moreover, that in the present instance
the plaintiff had actually been told to call on the 26th of November, and
that it was his neglect that he did not call on that day. The plaintiff
denied that he had been told to call either on that occasion or on any
other. The jury returned a verdict for the defendant, as they were of
opinion that the bank had established their case on the ground of general
usage among bankers. Mr. Morse, in his Treatise on Banks and Bank-
ing, makes the following pertinent observations on the subject of bankers
charging conurdssion for the collection of mercantile paper: — "Some-
times," he says, at page 323, " banks charge a commission for collection
where the business is required to be done in distant jilaces. Sometimes
they do it without charge, trusting to the indirect profits and advantages
which may be expected to accrue by reason of the chance of the money
being left uncalled for during a few days following its actual receipt and
their consequent use of it for that time, or from the hope of attracting
customers and increasing their business by offering such facihties without
extra charges. These motives of self-interest, which must always be
supposed to influence the bank, when it consents to collect without direct
compensation, are regarded as a sufficient and valuable inducement for
the undertaking to collect, and prevent the bank from availing itself of
the plea that its conti-act was without consideration." With respect
304 DISCOUNTS.
to the obligation of collection undei-taken by bankers, Mr. Morse, in a
previous part of his work, page 322, says :—" Collection upon notes,
drafts, bills of exchange, and, in short, upon every species of business
paper, is a duty very commonly undertaken by banks on behalf of cus-
tomers. After the collection is made the bank becomes a simple contract
debtor for the amount, less the commission, if any has been charged. If
the party for whom the collection was made is a regular depositor, the
sum will be properly placed to his credit upon his general deposit account,
unless a peculiar usage or special instructions demand some different
course of dealmg. If the party has no deposit account the bank simply
owes him the amount on demand."
( 305 )
CHAPTER XXXIV.
BANK OF ENGLAXD.
Corporation.— By tlie National Debt Act, 1870, (33 & 34
Yict. c. 71,) s. 72, the Bank of England, which was origi-
nally created a corporation by the cro^vn by -vdrtue of a
statute in the year 1694 («), is to continue a corporation
until all stock is duly redeemed by parliament.
Directors. — By 35 & 36 Yict. e. 34, s. 1, section 52 of
the 8 & 9 "Will. III. c. 20 (which section relates to elections
of directors of the Bank of England), shall have effect as
if seven-eighths had been therein mentioned instead of two-
thiixls.
By sect. 2, any new or altered bye-law from time to
time made by a General Court of the Corporation of the
Bank of England for the execution of the act, not being
repugnant to the law of England, shall be effectual mthout
further confirmation or approval.
Deposits and Discounts, — The Bank of England is largely
engaged as a bank of deposit and of discoimt ; and in
these respects nearly, if not altogether, the same rules
apply to its regulations and its relations to customers as
have been stated in respect of banking estabHshments
generally. The Bank of England in its trading capacity
is in the same position as an ordinary bank. Therefore,
where a customer was in the practice of making his
acceptances payable at the Bank of England, and, in a
particular instance, an acceptance of his was presented at
(«) 5 & 6 Will. 3, c. 20, s. 19. Revised Edition of Statutes, 1871.
G. X
306 BANK OF ENGLAND.
a quarter after nine, and left till eleven o'clock, a.m., and
then refused pajonent for want of assets, and being after-
wards, at six, P.M., presented again hy a notary, was again
refused payment by a person stationed by tbe bank, al-
tbougli the bank, before six o'clock, bad received sufficient
assets to cover tbe bill, it was considered that the bank
was not liable at the suit of the acceptor for negligence
in dishonoming his bill, because the second presentment
took place after banking hom's {b).
The Bank of England does not, as a general rule, receive
deposits repayable with interest (c) .
Branch Ban'ks. — The 7 Greo. IV. c. 46, s. 15, empowers
the Bank of England to appoint agents to carry on their
business at branch establishments in any place in England.
A notice of an act of bankruptcy given to the bank in
London, in time for communication to be made to the
branch banks, "U'ill be sufficient to bind the bank in re-
spect of transactions with the bankrupt at any of these
branches id). But each branch is to be treated as a dis-
tinct establishment for the pm-pose of giving notice of dis-
honour' of a bill of exchange (e).
By the same statute, notes or bank post bills issued at
any branch are payable in coin there, as well as in London,
but when issued in London, they are not payable at the
branch banks [d) .
Bank of Issue. — The privileges of the bank, as a bank of
issue, wiU be treated of separately (/).
(i) TFJiUalrr v. Bank of England, 1 C. M. & H. 741.
\c) In September, 18G4, however, the bank allowed interest at the rate
of 5 per cent, on a large sum of money whiih the Metropolitan Board of
Works was boimd by Act of Parliament to keep at the bank, as an extra-
ordinary exception to its custom.
{(l) Willis V. Banlc nf England, 4 A. & E. 21.
((') Brown v. London and Korth-ircstcrn Railway Company, 4 B. & S.
337. See Trince v. Oriental Bank Corporation, L. R., 3 App. Ca. 325;
Woodland v. Feare, 9 E. & B. 32.') ; Garnctt v. McKvwan, L. 11., 8 Ex. 10.
( / ) See post. Chapter XXiVII., Banks of Issue, and Chapter
XXXVIII., Bank Notes.
STOCK IN THE PUBLIC FUNDS. 307
Proving in Bankruptcy. — The Bank of England being
a body politic and incorporate (r/), may prove in bank-
ruptcy by an agent, pro\T.ded the agent, in his declaration
of proof, states that he is authorized under seal to make
such proof ill). For this pm-pose, the agent is usually .
authorized by a power of attorney under the seal of the
bank (/).
Agent of the Government. — The Bank of England is the
banker or agent of the Government for the management of
the National Debt, and the Bank of Ireland acts in a
similar capacity in regard to the public debt of Ireland.
The unredeemed portion of these debts is represented by
stock and terminable annuities, transferable at the Bank of
England and at the Bank of Ireland, ^vith interest payable
half-yearly.
Stock in the Puhlic Funds. — The existing public stocks
are the Consohdated Thi-ee Poimds per Centimi Annuities,
the Eeduced Thi-ee Poimds per Centum Annuities, New
Five Poimds per Centum Annuities, New Three Poimds
per Centmn Annuities, New Three Pounds Ten Shillings
per Centum Annuities, and Two Poimds Ten Shillings per
Centum Annuities, which form part of the permanent,
fimded, consolidated, or National Debt of the United
Kingdom of England, and are transferable at the Banks of
England and of Ireland. The natm-e of stock and money
in the Pubhc Funds is this : stock is a chose in action ;
it has no locality, except for the purposes of probate and
administration ; it does not fall under the head of goods
and chattels, so as to pass by a grant of bona et catalla
felonum (/,•) ; it has been said neither to be a chattel, nor to
{g) 5 & 6 WiU. & M. c. 20, s. 20.
(/(.) The Bankruptcy Act, 1869, s. 80 (par. 7), and Bank Gen. Reg. G9.
(«■) Ex parte Bank of England, 1 Swanst. 19 ; Xaghr v. Mortimore,
10 Jur., N. S. 1001, 1003.
(/.•) Hex- V. Capper, 5 Prico, 217.
x2
308 BANK OF ENGLAKl).
have any resemblance to a personal chattel (/) ; it cannot
he sued for as money {m) , it does not pass imder the term
" money," in a will (n) ; hut it does pass under the term
" secm-ities for money," unless the expression is controlled
hy the context. However, stock in the funds has been
said to pass or not under the word " moneys," or the word
" goods," or the word " chattels," according to the whole
context of the ^dll, and either " goods," or " chattels," used
simply, and without qualification, will pass it in a will (o) ;
and where the testator did not bank with the Bank of
England, a bequest of " all my money in the Bank of
England," passed stock in the funds (p).
Stock Certificates.— The National Debt Act, 1870,
enables the holders of pubUc stocks in England and
Ireland to convert their stock into cei*tificates to bearer,
having coupons attached for the payment of the dividends ;
and the 26 & 27 Yict. c. 73, is a similar enactment in
favour of holders of India stock.
India Stock. — The capital stock of the old East India
Company was not government stock {<]), nor is the 5 per
cent, stock created under the 22 & 23 Vict. c. 39, and
subsequent acts, for the loans contracted in this country
for the use of the Indian government (r). Both these
{I) Wildman v. Wildman, 9 Vcs. 119.
(»?) Nightingale v. Devismc, 2 W. Bl. 684.
(«) £x parte Simpson, 1 De Gex, 9 ; Goadon v. Botterill, 1 M. k K. 56 ;
Willis V. Flasket, 4 Beav. 208 ; Douglas v. Congreve, 1 Keen, 410; Hotham
V. Sutton, 15 Ves. 319.
(o) Kendall v. Kendall, 4 Russ. 3G0. Sco Willis v. Plaslctt, 4 Beav. 208 ;
I'hillips V. Kastwood, 1 LI. & Go. 291.
(p) Gallini v. Noble, 3 Mcr. G91.
('/) Brown v. Brown, 4 Kay & J. 704. By 3G Vict. c. 17, provi.sion is
made for the redemption or commutation of this stock, aud 3C Vict. c. 32,
provides the funds for the purpose.
(/•) The stock is transferable at the Bank of Enjjrlaud, and the dividends
payable there by virtue of the 23 & 24 Vict. c. 102, and 24 Vict. c. 3, s. 9,
and at the Bank of Ireland by virtue of tlie 25 Vict. c. 7. By 34 & 35
Vict. c. 29, dividend wan-ants may be sent by post. By 27 & 28 Vict. c. 50,
a.ssignments and transfers of India stock iu tlie Bank of Ireland are valid,
althoufch not accepted in writing;.
CONTRACTS FOR THE SALE OF STOCK.
stocks are charges ouly ou the territorial revenues of
India. But trustees may invest trust moneys in these
stocks without being guilty of a breach of trust, imless
expressly prohibited by the terms of their trust (s).
By 23 Vict. e. 5, s. 2, transfers of the tenitorial debt of
India, or of the Indian government loans registered in the
books of the Indian office in London, or in the Bank of
England, are exempt from stamp duty.
Indian government notes, or the certificates or stock
issued in lieu thereof, registered in the books of the bank:
or of the India office in London for the paATuent of in-
terest, are to be deemed personal estate of a person dying
in England, for the pui-pose of probate duty (/).
Contracts for the Sale of Stock. — A contract for the sale
of stock differs from a contract for the sale of a specific
chattel, inasmuch as stock does not belong to the head of
chattels; and, therefore, a contract for the sale of stock
would be satisfied by the delivery of any stock of the
description bargained for ; consequently, what is usually
called a contract for sale in such a case, does not mean an
actual sale, but only a contract to deliver, and such con-
tract is not a contract for the sale of "goods, wares or
merchandise," within the 17th section of the Statute of
Frauds, so as to requii-e a memorandimi in writing ((0-
The contract requires to be stamped in order to be
valid ipc) .
(s) 22 & 23 Vict. c. 35, s. 32 ; In re Colne Valleij Act, 29 L. J., Chanc. 33 ;
In re Langford, 31 L. J., Chanc. 334. By 36 Vict. c. 32, s. 16, the capital
stock created under that act for the redemption or commutation of the
capital stock of the East India Company is to be deemed India stock
within the 22 & 23 Vict. c. 35, s. 32, unless or until Parliament shall
otherwise provide.
{t) 23 Vict. c. 5, s. 1.
(m) Heseltine v. Siggers, 1 Exch. 856.
[x] By the Stamp Act, 1870, Sched., tit. " Contract Note," any note,
memorandum or writing, commonly called a " contract note," or by what-
ever name the same may be designated, for or relating to the sale or
purchase of any stock or marketable secimty of the value of bl. or upwards,
is subject to a penny stamp duty.
By sect. 69 (1), the duty on a contract note may be denoted by an
309
310 ' BANK OF ENGLANJ),
Transfer of Tmmfer of Stocl: — By the National Debt Act, 1870,
stock. g^ 22, in the offices of the respective accountants-general
of the Banks of England and Irehand hooks shall be kept
wherein all transfers of stock shall be entered. Every
entry shall be conceived in proper words for the purpose
of transfer, and signed by the party making the transfer,
or, if he is absent, by his attorney thereunto lawfully
authorized by writing under his hand and seal, and
attested by two or more credible witnesses. The person
to whom a transfer is so made may, if he thinks fit, under-
write his acceptance. And no other mode of transferring
stock shall be good in law, except where otherwise pro-
vided by act of parliament. By sect. 24, the Banks of
England and Ireland before allowing any transfer of stock
may, if the circumstances of the case appear to them to
make it expedient, require evidence of the title of any
person claiming a right to make the transfer. That
evidence shall be the declaration of competent persons
made under the Statutory Declarations Act, 1835, 5 & 6
Will. IV. c, 62, or of such other natm^e as the banks
requii'c. The bank, however, is not boimd to accept as
sufficient evidence of the death of a stocldiolder on a joint
accoimt in its books such proof as would satisfy the Com-t
of Chancery {>/). The stock vests, by the transfer, without
acceptance {z).
"Where a statute declared the stock created under it to
be transferable as the act directed, and not otherwise, and
enacted, that the entries of transfer shaU be signed by the
adhesive stamp, -vvliich is to bo cancelled by the iiorsou by whom the noto
is first executed.
lij sect. G9 (2), every person who makes or executes any contract note
chart,'eable with duty, and not being duly stamped, shall forfeit the sum
of 201.
By sect. G9 (3), no broker, agent or other person shall have any legal
claim to any charge for brokerage, commission, or agency, with reference
to the sale or purchase of any stock or marketable security of the value
of 5/. or upwards mentioned or rofeiTcd to in any contract note, unless
such note is didy stamped.
(y) I'rosscr v. Dcdi/c of IJi/fflaiid, 41 L. J., Chauc. 327.
(z) Hex V. Oadc, 2 Leach, C. C. 732.
TRANSFER BY EXECUTORS OR ADMINISTRATORS. 311
parties making such transfers, and that any person to whom
such transfer shall be made shall underwrite his acceptance
thereof, and that no other method of transferring such stock
shall be valid ; and a person alleging himself to be a holder
of stock brought an action against the Bank of England
for not paying dividends, it was held that he could not
dispute the title of the transferee, on the ground that
such transferee had not mider-svritten his acceptance, the
claimant of the dividends having himself executed the
transfer in the prescribed mode, and pocketed the price of
the stock (a).
If the Bank of England makes an unreasonable delay in
passing a power of attorney for the transfer of stock, they
are liable in damages for any loss sustained in consequence ;
they are to have time to take all reasonable means for
clearing up any doubt as to the authenticity of the power
of attorney, which they may reasonably entertain {b).
This being the case, it follows, — and it follows a fortiori,
— that they are responsible in an action if they refuse to
transfer, and a mandamus does not therefore go to compel
them to transfer (c).
Transfer by Executors or Administrators. — By the
National Debt Act, 1870 {d), s. 23, the interest of a stock-
holder, dying, in stock shall be transferable by his executors
or administrators, notwithstanding any specific bequest.
The Bank of England or of Ireland shall not be required
to allow any executors or administrators to transfer any
stock mitil the probate of the will of, or the letters of
administration to, the deceased has or have been left wdth
the bank for registration, and may require all the executors
who have proved the will to join in the transfer. Although
there is no specific bequest, the bank is bound to permit
(ff) Foster V. Bank of England, 8 Q. B. 689.
\b) Sutton V. Bank of England, 1 C. & P. 193 ; R. & M. 52.
\c) Hex V. Bank of England, 2 Dougl. 524; Com. Dig. Action on the
Case, A. 4.
{d) 33 & 34 Vict. c. 71.
survivors.
312 BANK OF ENGLAND.
the executor to transfer unless it can be shown that he has
assented to the legacy (c).
By joint pro- By Joint Proprietors and hy Survivors. — A joint tenant
prietors and £ g^^^,], canuot legally transfer his share ; for virtually, at
least in the case of two joint tenants, that would amount
to the power of transferring the whole {d) .
Stock standing in the names of two xoersons jointly, on
the death of one becomes, at law, the absolute x^roperty of
the sm-vivor, and therefore the administrator of the de-
ceased cannot maintain against the survivor an action to
recover the deceased's share, although, if there is a trust'
in favom- of a third person, the survivor may be responsible
in a Com-t of Eqiiity for the disposition of the property
according to the trust (^) .
When stock has been pm-chased in the joint names of
two persons, out of money standing to theii- joint account
in the bank, it is not necessarily to be considered as hold
in joint tenancy, but the origin of the money and the acts
and intentions of the parties may be looked to, and a con-
clusion in favour of a tenancy in common cka^vn from these
circumstances (/). Two sisters, being tenants in common
of estates, had money arising from the rents standing to
their joint account in the bank. Part of the money was
from time to time invested in the purchase of stock in
their joint names, and part on mortgage, the moiigaged
premises being conveyed to them as tenants in common.
Each sister, by her ^^ill, affected to dispose of her share
of the stock: it was held, that they were entitled to the
stock as tenants in common and not as joint tenants ().
But where two sisters carried on business as fanners, and
{(■) FmnHin v. Bank of England, 9 B. & C. lo6.
{d) Hhman v. Bank of England, 14 Sim. -188. See further as to the
right of survivorship, Jn re Egkgn, 6 Ch. D. 115; Tnnhndge x. Cord, 2.')
L. T. 150; Batstone v. tialter, L.'R.., 10 Ch. 431.
{<•) Crossrwld V. Such, 8 Exch. 825 ; 22 L. J., E.xch. 325.
(/) Bobinson v. Prcstun, 27 L. J., Chanc. 395; 4 Kay & J. 505. See
Morlvii V. Bird, 3 Vcs. G31 ; Lake v. Gibson, 1 L. C. 198.
{g) Robinson v. Brcdon, 27 L. J., Chanc. 395; 4 K. & J. 505.
POWERS OF ATTORNEY. 313
had a joint account at tlieir bankers, and an establisliment
and purse in common, and invested part of tlieii- money
in the piu'chase of consols, in their joint names, and
had a balance due to them on their banking accoimt,
besides a sum due from their bankers on dejiosit notes,
on the death of one, the two sisters were considered to be
joint tenants of the consols, and tenants in common of the
balance and of the deposit notes {//).
Two sisters, spinsters, executrixes and beneficiaries imder
their father's mil, transferred a poi*tion of the fund be-
queathed to them as tenants in common into their joint
names, and afterwards out of the proceeds of that of which
they were tenants in common purchased stock in their joint
names. They lived together, had all things in common,
and made mutual wills in each other's favom-. Held, first
that the transfer made them joint tenants of the fmid
transferred, and secondly, that they were joint tenants of
the stock afterwards pm-chased out of the proceeds of a
fimd of which they were tenants in common (i).
Poicers of Attorney. — A power of attorney, to transfer
stock, is revocable, by a stockholder acting personally for
himself, without deed (k). So is a power to receive divi-
dends (/). Stock may be legally transferred under a power
of attorney after the death of the graitor, if without notice
of his death (m). So after the revocation of the power, if
before notice of the revocation [n) . Powers of attorney for
the transfer of stock, or for the receipt of dividends, are
subject to certain stamp duties (o).
(A) Bone v. Pollard, 24 Beav. 283.
(i) In re Enghes, 24 L. T. 415.
{k) Rex V. Wait, 11 Price, 518 ; 7 Moore, 473.
\l) Clark V. Laurie, 26 L. J., Exch. 36.
(w) A'iddillY. Farnell, 3 Sm. & G. 428 ; 26 L. J., Chanc. 818.
(«) Story on Agency, s. 470, 5th edit.
(o) The stamp duties on letters or powers of attorney are rcgiilated by
the Stamp Act, 1870. They are as follows : —
(1.) For the receipt of the dividends or interest of any stock : £ s. d.
AYhere made for the receipt of one payment only . . . , 1
In any other case 5
314
BANK OF ENGLAND.
Forged
powers of
attorney.
Tiraisfcr of SfocJc under Forged Poicers of Attorney. —
A forged power of attorney lias no effect to transfer stock
standing in the name of A. to the name of B. ; conse-
quently, if the bank transfers A.'s stock under a forged
power of attorney, the hank will he liable to replace A.'s
stock (7;). A. may recover damages against the bank for
not making a transfer from A. to a purchaser {p).
If, however, A. had knowledge of the forgery, and re-
fused, or omitted to apprise the bank of it, such conduct
woidd disable him from recovering {q).
If one of two trustees of stock forges the signature of
his co-trustee to a power of attorney, and imder it sells
out stock and absconds, the bank is compellable, in a
Com-t of Equity, to re-invest the stock in the name of the
other trustee (r).
If the common seal of a corporate body holding stock is
improperly affixed to a letter of attorney mthout the
£ 5. d.
(2.) For the receipt of any sum of money, or any bill of ex-
change or promissory note for any sum of money, not
exceeding 20^., or any periodical i^ayments not exceed-
ing the annual sum of 10^. {not being here'uihcfore
charged) 5
(3.) For the sale, transfer or acceptance of any of the govern-
ment or parliamentary stocks or funds :
Wliere the value of such stocks or funds does not
exceed 20^ 5
In any other case 10
(4.) Of any kind whatsoever not hereinbefore described 10
(5.) Letter or power of attorney for the receipt of dividends of
any definite and certain share of the govci-nmcnt or
parliamentary stocks or funds producing a yearly divi-
dend of less than 3/. is exempted.
By sect. 103, a letter or power of attorney for the sale, transfer or
accejitance of any of the government or parliamentary stocks or funds,
duly stamped for that purpose, is not to be charged with any further
duty by reason of containing an autliority for the receipt of the dividends
on the same stocks or funds.
By sect. 101, a writing under hand only containing an order, request
or direction from the owner or proprietor of any st^ck to any company, or
to any banker, to pay the dividends or interest arising from such stock to
any person therein named, is not chargeable with duty as a letter or
power of attorney.
[p) Coles V. Bank of England, 10 A. & E. 419 ; IFumc v. BoUand, 1 C.
& M. 130 ; Davis v. Banlc of England, 2 Bnig. 393.
[q) Stracg v. Bank of England, 6 Bing. 751.
(>•) Sloman v. Bunk of England, 11 Sim. 175; Midland Railway Company
V. Taylor, 8 Jur., N. S. 419, H. L.
MORTGAGE OF STOCK. 315
knowledge or consent of the corporation (even tliougli
affixed by their agent), and a transfer is made in conse-
quence, the bank is liable unless the corporation has been
guilty of negligence, or has subsequently ratified the act.
In fact, it is the duty of the bank to prevent the entry
of a transfer in their books until satisfied that the person
who claims to be allowed to make it is duly authorized so
to do. Were the law otherwise, the whole property of
every stockholder would be at the mercy of the bank
clerks.
It is felony to forge any power of attorney for the
transfer of any stock at the Bank of England or of Ire-
land (s), or to forge any name, handwriting or signature,
purporting to be the name, handwriting or signature of
a witness attesting the execution of such power of at-
torney (t) .
Transfer into Fictitious Names. — If a bankrupt, for the Fictitious
pm-pose of defrauding his creditors, purchases stock, of °'''™^^'
which he obtains the transfer into a fictitious name, a
Court of Equity will afford relief to the creditors, by
ordering the Bank of England to erase the fictitious name,
and insert that of the bankrupt as the transferee {ii).
Forging Transfers. — It is felony to forge the transfer of
any share or interest of or in any stock transferable at the
Bank of England or at the Bank of Ireland {x).
Personating Stockholders. — The personating of an owner
of stock in the funds, or of the dividends, and thereby en-
deavouring to transfer the stock or receive the dividends,
is felony (y).
Mortgage of Stock. — A mortgagee who has advanced Mortgcage of
on the secmity of stock for a fixed period is bound, in the
(.s) 24 & 25 Vict. 0. 98, s. 2.
[t] Ibid. s. 4.
(«) Green v. Bank of England, 3 Y. & C. 722 ; 32 & 33 Vict. c. 71, s. 22.
\x) 24 & 25 Vict. c. 98, s. 2.
\u) Ibid. s. 3.
316 BANK OF ENGLAND.
absence of express stipulation to the contrary, to retui'n the
identical stock pledged at the expii-ation of the loan, and
for this purpose stock is as capable of identification as any
other security. If he sells the stock in pledge during the
currency of the loan, he is accountable to the mortgagor
for any profit made by the sale (s).
Bank Boohfi. — Making false entries or altering any
words or figui-es in the books of the Bank of England or
of Ireland, in which the accounts of the owners of stock
are kept, with intent to defraud, is felony [a).
Inspection of Boohs. — The books of the Bank of Eng-
land cannot be inspected by persons who have no interest
in them, or who seek an inspection for pm-poses of a private
nature, unconnected with the objects for which the books
are kept.
A fund-holder has a right to inspect and copy entries
relating to the stock and its transfers in which he is inte-
rested; but he has only the right as to the particular
entries relating to the particular parcel of stock, and no
other {b) ; and the bank is accordingly liable to furnish a
list of such of their books as contain entries of stock in
which the party applying is interested, and the Courts of
Equity enforce this obligation (c).
The bank books are, in general, not removable, on the
ground of public inconvenience (c/), and they are proveable,
by examined copies made under the provisions of the Act
of 1879 (c).
The bank books are the best evidence of the transfer of
stock, but still it is not always necessary that they should
(2) Langtu)! v. Walte, 37 L. J., Chanc. 345; 4 L. R., Ch. 402.
{a) 24 & 25 Vict. c. 98, s. 5.
[b) Foster V. Bank of England, 8 Q. B. 689.
{() Ueslop V. ]iank of Emjland, 6 Sim. 192.
{(I) Murtlmcr v. M'CaJlnn, G M. & W. 5S, G7, fiO ; Rex v. Gordon,
Dougl. 572, II. ; J>"ris v. Hank of Knglatid, 2 Biup. 404.
(/)'yce Bankers' Books Evidence Act, 1879 (42 A: 43 Vict. c. 11), printed
in Appendi.x. The effect of sect. 3 of tlie Atrt is to make copies of entries
in the Looks of a banker evidence ap^ainst any one. Jlurdnuj v. Jl'Utianis,
14 Ch. D. 197.
TRUSTS.
be produced to afford this proof; the signature of the
alleged transferee may be proved by a person who knew
the party's handwiiting, and had inspected the signature
of acceptance in the books (./').
Trusts. — The Bank of England does not take notice of
trusts ; they are not to look beyond the legal title ; there-
fore they cannot prevent an executor selling out or trans-
ferring stock into his own name {g), and are not charge-
able, if he transfers the stock to persons not entitled under
the will {/i). There is a case decided in relation to this
point a good many years ago, in which the facts were
these : —
A transfer was made of stock at the bank in the name
of a wife by her husband, which stock, it Avas suspected, she
held by virtue of a trust to her separate use. A memo-
randum was made by the bank on the transfer, indicating
that a flaw w^as suspected in the title. This, it was held,
must not be allowed ; it was further held, that no secret
trust, as against the party having an open legal title, will
affect the bank.
Lord Mansfield added, " I won't say a word against the
holder of the stock having his action against the bank, for
disparaging his title " (/).
The fact is, if the bank looked beyond the legal title, for
instance if they took notice of the trusts of a will, they
must be held to take notice throughout, and therefore they
would have to stand the consequences of resulting trusts,
and such trusts as would be raised by a Court of Equity (k) ;
in fact, if so, they would be charged with all the trusts in
the kingdom (/).
In reality, there is nothing in the statutes relating to the
(/) Mortimer v. Bl'Callau, 6 M. & W. 08.
[f/) Bank of Enylaml v. I'arsons, 5 Ves. 665.
[h] Ilartya v. Bank of England, 3 Ves. 55.
((') Ladij Mayo'' s case, Lofft, 65.
{k) Bank of England \. Parsons, 5 Ves. 669.
(0 3 Ves. 58.
317
318 BANK OF ENGLAND.
establisliment or regulation of the bank, which makes them
■ trustees of the public funds for any person ; if they volun-
tarily enter in their books a trustee's account, they may,
under certain circumstances, become liable for the perform-
ance of the trusts ; they stand much in the same relation to
stock, that a depositary of goods does to the goods ; if they
have distinct notice that the person in whose name the
stocks stand is not the real owner, or holds subject to a
claim, and they, nevertheless, allow the transfer to be
made, there they may be, but then only, responsible for
the transfer {m) .
It is common, in order to avoid the frequent recurrence
of the necessity of appointing fresh trustees — at least it is
not uncommon when the stock is considerable — to appoint,
in the first instance, four trustees ; for then, on the decease
of one, or even of a second, of the trustees, there still re-
mains the check which one mind may be supposed to hav^
over a tendency to dishonesty in the other.
In general, it is a rule with the Bank of England, not to
allow a fund to be transferred into the names of more than
four joint owners.
Distringas iipou. — A claimant to an interest in stock
transferable at the Bank of England, standing in the name
or names of any person or persons, or body politic or cor-
porate, in the bank books, who was desirous of restraining
the transfer of such stock, or the payment of the dividends
thereof, formerly issued a di.striiir/as, prepared by his soli-
citor, and sealed by the clerk of records and writs, in the
form prescribed by the 5 Vict. c. 5, s. 5 (»). The writ was
then served on the Bank of England, together with a
notice not to permit the transfer, or not to pay the divi-
dends, as the case might be.
(m) Hiimbcntonc v. Chase, 2 Y. & C. 209.
(w) Fonri of Affidavit, Order XXVIT., Gon. Ordors, IT. T. 18G0; 29
L. J., Chauc. 20. Sco Jn re Marquis of Jlirfford, 1 Hare, 58-1 ; iratts v.
jrail-i, 40 L. J., Chanc. 388.
DISTRINGAS UPON. 319
Now, however, by the Rules of the Supreme Court,
1880, it is provided that no distringas shall thenceforth he
issued under the ahove act, and in place thereof it is
enacted (o) : —
By Rule 23, that any person claiming to be interested in any stock Filing and
standing in tho books of a companj^ may, on making an affidavit ^^Y*^^.^*
in or to the effect of tbo form B. 28 in tko schedule thereto, and on notice as to
filing the same in the central office with a notice in or to the effect stock.
of the form B. 23 in the same schedule annexed thereto, and on ^ , • ^^^ * I-
r. 4.
procuring an office copy of the affidavit and a duplicate of the filed
notice authenticated by the seal of the central office, serve the office
copy and duplicate notice on the comi^any.
By Rule 2-1, there shall be appended to the affidavit a note stating Affidavit to
the person on whose behalf it is filed, and to what address notices ^^^*° address
(if anj') for that person are to be sent. All such notices shall be Qj.^ XL VI
deemed to have been duly sent if sent through the post by a pre- r. 5.
paid letter directed to that person at the address so stated or at any
such substituted address as thereinafter mentioned, whether the
person to whom the notice is sent is living or not.
By Eule 25, the address so stated may, from time to time, be Alteration of
altered by the person by or on whose behalf the affidavit is filed, '?-'^Y*^f^-
but all notices sent by post before the alteration to the address j.. 6."
originally given or for the time being substituted therefor shall
not bo affected by any subsequent alteration. Any such alteration
of address may be made by service of a memorandum thereof on
the company in the manner required for service of a notice under
this order.
By Eule 26, the service of the office copy of the affidavit and of Service of
the duplicate of the filed notice shall for the period of five years amdavit and
,-, , ,. ••.,,■. / n ii i- • -, filed notice to
from tho day oi service, but not longer (unless tho notice is renewed i^^ve same
as thereafter mentioned), have tho same force and effect as if these effect as wTit
rules had not been made and a writ of distringas in respect of the o -d '^XTVT^'
stock had been duly issued under the act 5 Vict. c.5,s.5. r_7.
By Eule 27, the original notice may be kept on foot from time to Renewal of
time by a notice of renewal signed by the person by whom or on notice.
whose behalf the original notice was given, and served on tho ^^'^- ^^^^I-
company, provided the notice of renewal, if only ono is given, is
served before the expiration of five years from the day on which
the original notice was served, or, if more than ono is given, then
(o) Ord. XLVI. In these rules the expression "Company" includes
the Governor and Company of the Bank of England and any other public
company, whether incorporated or not, to which 5 Vict. c. 5, s. 5, applies;
and the expression ' ' stock ' ' includes shares, securities, and money.
320
BANK OF ENGLAND.
Withdrawal
or discharge
of notice.
Ord. XLVI.
r. 9.
Effect of
request for
transfer of
stock or
I^ayment of
di\ddend.
Ord. XLVI.
r. 10.
Amendment
of description
of stock.
Ord. XLVI
r. 11.
before the expiration of five years from the day on which the last
previous notice of renewal was served. Each such notice of renewal
shall have the effect of continuing and keeping on foot the original
notice for the period of five years from the day on which the first
notice of renewal or the last previous notice of renewal (as the case
may be) was served.
By Eulo 28, a notice filed under this order may at any time be
withdrawn by the person by whom or on whose behalf it was given
on a written request signed by him, or its operation may be made
to cease by an order to be obtained by motion on notice or by peti-
tion duly served by any other person claiming to be interested in
the stock sought to be affected by the notice.
By Eulo 29, if, whilst a notice filed under this order continues in
force, the company on whom it is served receive from the person in
whose name the stock specified in the notice is standing, or from
some person acting on his behalf or representing him, a request to
permit the stock to be transferred or to pay the dividends thereon,
the company shall not by force or in consequence of the service or
of any renewal of the notice, be authorized, without the order of
the court, to refuse to permit the transfer to be made or to withhold
the payment of the dividends for more than eight days after the
date of the request.
By Eule 30, if the person who files a notice under this order
desires to correct the description of the stock referred to in the filed
notice he may file an amended notice and serve on the company a
duplicate thereof sealed with the seal of the central office, and in
that case the service of the notice shall be deemed to have been
made on the day on which the amended duplicate is so served.
Dividends.— Bj the National Debt Act, 1870, s. 25, the
Banks of England and Ireland may close their books for
the transfer of stock on any day in the month next prece-
ding that in which the dividends on tliat stock are payable,
but so that the books be not at any time so closed for more
than fifteen days. The persons who on the day of such
closing are inscribed as stockliolders shall, as between them
and their transferees of stock, be entitled to the then cur-
rent half-year's dividend thereon.
By sect. 17, tlie Bank of England and Ireland before
allowing the receipt of any dividend on any stock may, if
the circimistance of ihc case a])pcar to tliem to make it
TRANSMISSION OF WARRANTS BY POST.
expedient, requii-e evidence of the title of any person
claiming a right to receive the dividend. That evidence
shall be the declaration of competent persons mider the
♦Statutory Declarations Act, 1835 (u), or of such other
natm-e as the banhs reqiiii-e.
By sect. 19, the banks are also authorized to pay the
dividends under the power of attorney of one joint owner,
where the other is either an infant or a person of unsound
mind.
Action to recover. — In an action, however, against the
bank for the nonpajnnent of dividends, the plaintiff must
allege and prove that the money to discharge the divi-
dends has been received by the bank from the govern-
ment, for the bank has no more than the care of the
stock ; and it must be shown that they have funds, before
they can be proved to have committed a breach of duty in
not papng them over to the plaintiff (o) .
Forging Poicers of Attorney to receive. — Forging a power
of attorney for the receipt of any dividend is a felony (;;).
Transmission of Warrants bi/Post. — By the National Debt
Act, 1870 (q), s. 20, the Banks of England and Ireland
may, from time to time, with the sanction of the Treasmy,
make arrangements for the payment of dividends on stock
by sending the wan-ants through the post, and every waiTant
so sent by post shall be deemed a cheque on the Bank of
England or of Ireland (r). By sect. 21, where a stock-
holder desii'es to have liis dividend warrants sent to him
by post, he must make a request for that purpose to the
Bank of England or of Ireland, in wiiting signed by him,
(«) 5 & 6 WiU. 4, c. 62, ss. 2—5.
(o) Bank of England y. Davis, 5 B. & C. 185.
Ip) 24 & 25 Vict. c. 98, s. 4.
[q) 33 & 34 Vict. c. 71.
(/■) So by 36 & 37 Vict. c. 44, where goTermnent annuities for life or
years are payable by the Commissioners for the Reduction of the National
Debt, the warrants may be sent by post at the request of the annuitants.
G. Y
321
322 BANK OF ENGLAND.
in a form approved by the bank and the Treasury, and
must give to the bank an address which must be in the
United Kingdom, or the Channel Islands or the Isle of
Man, to which the letters containing the warrants are
from time to time to be sent. The posting by the bank of
a letter containing the dividend warrant, addressed to the
stockholder at his request, will be equivalent as respects
the liability of the bank to the delivery of the w^rant to
the stockholder himself.
Making out False Dividend Warrants. — It is felony for
any clerk, officer or servant of the Bank of England or
of Ireland, to make out or deliver any dividend warrant
for a greater or less amount than the person on whose
behalf the warrant is made out is entitled to, with intent
to defraud (r).
Unclaimed Unclaimed Dividends. — By the National Debt Act,
div-idends. 2870 (.s), s. 51, all stock, no dividend whereon is claimed
for ten years before the last day on which a dividend
thereon becomes payable (except where payment of divi-
dend has been restrained by a Court of Equity), shall be
transferred in the books of the Bank of England or of
Ireland (as the case may be) to the National Debt Com-
missioners. By sect. 55, the governor, or deputy governor
of the Bank of England or Ireland, may direct the ac-
countant-general or deputy accountant-general or secretary
or deputy or assistant secretary of the bank to re-transfer
any stock transferred to any person showing his right
thereto to the satisfaction of the governor or deputy
governor, and to pay tlio dividends due thereon, as if the
same had not been transferred or paid to the National
Debt Commissioners. But in case the governor or deputy
governor is not satisfied of the right of any person claiming
(?•) 24 & 2.) Vict. c. 98, 8. 6.
(a) 33 & 34 Vict. 0. 71. This act repeals the 56 Geo. 3, c. CO, the
former statute on this subject.
BANK STOCK.
to be entitled to an}^ sucli stock or dividends, tlie claimant
may, by petition in a summary way, state and Terify liis
claim to the Com't of Chancery.
Under this statute it is not necessary for the claimant to
show himself to be beneficially interested in the stock ; to
prove a legal claim to it is sufficient {f) . But then it is
not a matter of course, where there is anj'ihing to indicate
the party not to be beneficially entitled, to order a re-
transfer upon the claimant making out a legal title, such
as a transfer would have been made to him upon, if the
ten years had not elapsed ; thus, if stock stands in the
names of two persons, one of whom smwives the other up-
wards of ten years, but has not, duiing that time, claimed
any di\'idends, the Court refuses, upon petition of the
sur^dvor's widow and personal representative, to order the
stock to be re-transferred into her name, or into the names
of the two deceased persons, but directs a reference to
inquii'e who is entitled to the stock, with liberty to state •
special circumstances («).
On a re-transfer of stock, the unpaid dividends are simply
payable without any accumulations arising from re-invest-
ment of dividends (.r).
Ba)ik Stock.— Beiove the 22 & 23 Yict. o. 35, s. 32, an
investment by trustees of trust moneys in Bank of England
stock, though it was practically as safe as the government
funds, was not regarded by the Courts of Equity as a
proper investment of trust moneys, and, upon knowledge
of the fact that such an investment had been made, they
would have ordered the stock to be sold out, and the pro-
ceeds invested in consols. If any loss was occasioned
to the trust estate by fluctuation in the prices of the bank
stock, or of the government stock, between the dates when
(0 In re Bigg, 1 T. & C. 245.
[u) Ex parte Ram, 3 M. & 0. 25 ; In re Bishton, 27 L. J., Chanc. 168 ;
ITiDitY. Pcaeock, 6 Hare, 361.
(.r) In re Ashmead, L. E,., 8 Ch. 113 ; 42 L. J., Chanc. 314. See also
on this subject I» re Arldand, 26 L. T. 418.
y2
323
324 HANK OF ENGLAND,
the investment was made, and tlie re-investing in consols,
the trustee had to make good the difference (y). But now
a trustee, or an executor, or an administrator, unless he is
expressly forbidden by the instrument creating his trust,
may invest any trust fund in the stock of the Bank of
England or of Ireland, and the trustee so doing will not be
liable on that account as for a breach of trust, if the in-
vestment is in other respects reasonable and proper (s).
Upon a loss sustained by a depreciation in the price of
consols, a trustee upon a proper investment will not be
liable for the difference {a) .
Bonuses. Bonuses. — An extraordinary division of a sum of money
among the proprietors of bank stock, beyond the ordinary
dividend, by way of bonus, is considered as an accretion
to the capital ; therefore, a tenant for life of the bank stock,
in respect of wliich the division is made, is not entitled to
.the bonus, but only to the dividends upon it considered as
capital, as they accrued during his life {h) ; it makes no
difference that the division was in money, and not in
stock ; that did not cause it to be considered as a profit
arising and payable in the time of the tenant for life, and
to which, therefore, he was entitled, inasmuch as all the
profits, ordinary and extraordinary, arose in the j^ame
way (h).
Stock stood in the names of trustees under a mamage
settlement, to pay the dividends Avith any bonuses tliat
might from time to time be allowed, and when the same
should be payable, to a husband and his wdfe and the
survivor for life : it was held, that the husband was abso-
lutely entitled to a bonus declared during his life estate (c).
He did not take the bonus, but allowed it to be added to
(v) llaneon v. Ailoi, 2 Dick. 498 ; Clough v. Bond, 3 M. & C. 490.
(;) 22 & 23 Vict. c. 35, 8. 32, aud 23 & 24 Vict. c. 38, s. 12.
\a) I'vut V. Crcnie, 2 Dick. 499, n.
\b) lirandcr v Bmmlcr, 4 Ves. 802; 14 Vcs. 70, 78; 13 Trico, 774;
Paria v. Taris, 10 Vcs. 185; Cliv)tun v. Gir.s/iiiiii, 10 Vcs. 290; //'(« v.
tStecre, 13 Ves. 3G3. See lie Ilopl'hi^' Trust, 22 W. R. 087.
(r) In >r Mitf'iiii, I Jur., N. S. 1077.
STAMPS ON BILLS AND NOTES. 325
the capital and received the dividends on the whole. On
his death, the wife as survivor was entitled to receive the
bonus {(i).
Bequests. — When a person is possessed of money in
consols and other government securities, and also of hank
stock, and bequeaths " all his fortune standing in the
funds," the bank stock does not pass. The reason is, that
the words "the funds" have received an interpretation to
mean " the public funds," as appears from the Stamp Acts,
which have always made a distinction between bank stock
and the government funds (e) .
On the other hand, when a person not having either at
the date of his will or at the time of his death any bank
stock, but having some Three and a quarter per Cent.
Annuities, there being no other stock standing in his
name, bequeaths " all my bank stock," the annuities mil
pass (/).
Stamps 0)1 Conveyance or Transfer of Bank StoeJx. —
By the Stamp Act, 1870, Schedule, the conveyance or
transfer, whether on sale or otherwise of any stock of the
Bank of England is chargeable with the duty of 7s. 9d.
Stamjys on Bills and Notes. — The promissory notes, bills
of exchange and bank post bills of the bank are exempt
from stamp duty {rj), and are re-issuable after payment
as often as the bank thinks fit. But the j)ractice of the
bank is never to re-issue a note or a bill which it has once
paid.
{d) In re ilittam, 4 Jur., N. S. 1077.
\e) Grainricr v. Slingsby, 25 L. J., Chanc. 573; 8 De G., Mac. & G. 385;
S. C. 7 H. L. Cas. 273.
(/) Ihal-e V. Marfw, 26 L. J., Chanc. 786.
{(j) 55 Geo. 3, c. 184, s. 20; 7 & 8 Vict. c. 32, s. 7.
( 326 )
CHAPTER XXXV.
BANK OF IRELAND AND BANK OF SCOTLAND.
The Bank of Ireland was establislied by a royal charter
in pursuance of an act of tlie Irish parliament (a), and
possesses similar privileges to the hank of England, and
is governed by similar principles. The restriction in that
act against the bank lending or advancing money to be
secnred by mortgage or sale of lands, tenements, or here-
ditaments, redeemable, has been repealed by 23 & 24 Yict.
c. 31.
The 35 Yict. c. 5 alters the charter as to the number
and election of the directors.
The 8 & 9 Yict. c. 37 continues the bank's privileges
imtil determined by notice in the Dublin Gazette, and re-
gulates the issue of bank notes or bills payable on demand.
The notes, bank post bills and bank bills of exchange of
the bank may be signed by machinery (b).
The Bank of Scotland, by the name of the governor
and company of the Bank of Scotland, was established by
an act of the Scotch parliament in 1695. The 1-4 Geo. III.
c. 32, recognizes its establishment and continues the act
in force. The commissioners of the treasmy may com-
pound with the Bank of Scotland, the Royal Bank of
Scotland, the British Linen Company, and other Scotch
banks, for the stamp duty payable on their notes and bills
of exchange (c). The 8 & 9 Yict. c. 38, regulates the issue
of bank notes in Scotland.
(ft) 21 & 22 Geo. 3, c. IG (Irisli).
{b) 27 & 28 Vict. c. 78.
(c) 10 & 17 Vict. c. C3, 8. 7. By 3G Sc 37 Vict. c. ccvii, s. 2, tlie Royal
Bank of Scotland may establish a branch in London, but this power shall
not authorize it to issue its own bank notes elsewhere than in Scotland.
( 327 )
CHAPTER XXXVI.
CRIMINAL LIABILITY OF OFPICERS AND SERVANTS OF THE
BANK OF ENGLAND AND OF THE BANK OF IRELAND.
An officer or servant of the Bank of England, or of Ire-
land, intrusted -uath any bond, deed, note, bill, dividend
warrant, or warrant for tlie payment of any annuity or
interest, or money, or with any security, money, or other
effects of or belonging to the Bank of England or of Ire-
land, or having any bond, deed, note, bill, dividend war-
rant, or warrant for the payment of any annuity or interest,
or money, or any security or other effects of any other
person, body politic or corporate, lodged or deposited with
the Bank of England or of Ireland, or with him as an
officer or servant of the Bank of England or of Ireland,
secreting, embezzling or running away with any such
bond, deed, note, bill, dividend or other warrant, security,
money or other effects, or any part thereof, will be guilty
of felony (a), and on conviction will be Kable, at the dis-
cretion of the coiu-t, to be kept in penal servitude for life,
or for any term not less than five years, or to be imprisoned
for any term not exceeding two years, with or without
hard laboui", and with or without solitary confinement (b).
(a) 24: & 25 Vict. c. 96, s. 73.
(i) 27 & 28 Vict. c. 47, s. 4.
( 328 )
CHAPTER XXXYII.
BANKS OF ISSUE.
Bank of Emjlaml — The Bank of England is a "bank of
issue, and its powers, in this respect, are defined by the
7 & 8 Yict. c. 32, commonly called the Bank Charter Act
of 1844 {a). By that act the banking and issue depart-
ments were separated, and the bank was authorized to
issue from the issue department into the banking depart-
ment notes payable on demand, to the amount of
14,000,000/., upon the credit of securities of equivalent
value first being lodged in the issue department. The
amount of these securities or the notes may be diminished
from time to time, but cannot be increased {h) or ex-
ceeded (c), " save in exchange for other Bank of England
notes, or for gold coin, or for gold {d) or silver bidlion {e),
purchased or received for the issue department or in ex-
((?) The act is printed in the Appendix of Statutes.
{b) Sect. 5, however, provides for a limited increase of seciu-ities and
notes. If a coimtry banker shall cease to issue his own notes, an order in
council may empow-er the bank to increase the securities, and issue addi-
tional notes, but such increase is not to exceed two-thirds of the authorized
issue of such banker. In the preamble of the 21 Yict. c. I , indemnifying
the bank, on the occasion of an over-issue, in 1857, the amoimt of the
seciu-ities acquired and taken in the issue department is there stated to bo
limited to 11,750,000/. under the provisions of the act and an order in
council. The bank, by sect. 9 of the 7 & 8 Vict. c. 32, is to allow (lie
public the profits of its increased circulation, which profits, by the 2'1 Vict.
0. 3, s. 4, are payable between the 6th of April and the 5th of July yearly,
to the account of the comptroller of the Exchequer.
(f) In 1857, thebank having- issued notes in excess of its authorized cir-
culation by direction of the government in order to meet an extraordi-
nary demand for discount and to avoid pressure on the reserves of the bank,
the 21 Vict. c. 1, was passed to indemnify the bank, and confirm the issue.
{(l) By sect. 4, Bank of England notes may be demanded at the issue de-
partment in exchange for gold bullion at the rate of £3: 17s. ^d. per
ounce of standard gold, but it must be melted and assayed at the expense
of the parties.
(c) Sect. 3 limits the amount of silver bidlion to be retained at a time
by the bank iii the issue department to one-fourth of the gold coin and the
bidliou in that department.
OTHER BANKS OF ISSUE.
change for securities acquired and taken in that depart-
ment."
An account of the notes in circulation and of the secu-
rities in the issue department, as well of the capital stock,
deposits, money and securities in the banking department,
is to he transmitted weekly to the commissioners of stamps
and taxes (/), and published in the Gazette.
The notes of the bank payable to bearer on demand are
exempt from stamp duty(f7), and may be signed by
machinery instead of being written by cashiers of the
bank {//).
Other BanlxS of Issue. — No bank other than the Bank of
England and those banks lawfully issuing such instrmnents
on the 6th of May, 1844, can issue bills or notes payable
on demand {i).
(1.) By the 39 & 40 Geo. III. c. 28, s. 15, it was forbidden to esta-
blish, any corporate bank whatever, or any bank where the number
of bankers in partnership should exceed six, so as " to borrow, owe,
or take up any sum or sums of money, on their bills or notes, pay-
able on demand, or at any less time than six months from the
borrowing thereof," during the continuance of the privileges seciired
to the Bank of England, by former acts of parliament.
(2.) In 1826, the 7 Geo. IV. c. 46 was passed, legalizing the
formation under deeds of settlement of banking copartnerships
consisting of more than six persons, provided they did not carry on
business within the distance of sixty-five miles from London, and
had not any of their banking establishments in London. Every
member was also responsible for the payment of all bills and notes
issued, and for all sums of money borrowed, owed or taken up, by
the copartnership. These restrictions and conditions were imposed
by the first section of the act [j).
(/) By the 12 & 13 Vict. c. I, the commissioners are now called the
commissioners of inland revenue.
{o) 7 & 8 Vict. 0. 32, s. 7.
(h) 1 Geo. 4, 0. 92, s. 3, and 16 & 17 Vict. c. 2, s. 1.
(i) 7 & 8 Vict. c. 32, see post.
{j) The acceptance by one of these copartnerships of a customer's hill,
at less than six months' date, on accoimt of a balance in favour of the cus-
tomer, was a horruwbig in point of law, within the meaning of this statute.
The di-awiug of a bill, at a longer period than six months, though the
acceptance was within six months of its maturity, was a violation of the
329
LiANKS OF ISSUE.
(3.) By 9 Geo. IV. c. 23, s. 1, it was enacted, tliat it sliould be
lawful for any person or persons carryinrj on the business of a hanher
or hankers in England (except within the city of London or within
three miles thereof), having first dnly obtained a licence for that
purpose, and given security by bond, to issue, on unstamped paper,
promissory notes for any sum of money amounting to five pounds
or upwards, expressed to be payable to the bearer on demand, or to
order, at any period not exceeding seven daj^s after sight ; and also
to draw and issue, on unstamped j^aper, bills of exchange, ex-
pressed to be payable to order, on demand, or at any period not
exceeding seven days after sight, or twenty-one days after the date
thereof : provided such biUs of exchange be drawn upon a person
or persons carrying on the business of a banker or bankers in
London, Westminster or the borough of Southwark ; or provided
such bills of exchange be drawn by any banker or bankers at a
town or place where he or they shall be duly licensed to issue
unstamped notes and bills, under the authority of this act, upon
himself or themselves, or his or their copartner or copartners, pay-
able at any other town or place where such banker or bankers shall
also be duly licensed to issue such notes and bills as aforesaid.
(4.) But by 3 & 4 Will. IV. c. 98, s. 2, it was enacted, that
banks consisting of more than six persons should not have the
power to issue notes payable on demand in London or within
sixty-five miles thereof; but were permitted, by section 3, to
carry on the business of banking within the above limits, ])vo-
vided they did not issue biUs or notes at less than six months'
date (y )..
(5.) By sect. 10 of 7 & 8 Vict. c. 32, as above stated, it is enacted
that no person, other than a banker, who, on the 6th of May, 1844,
was lawfully issuing his own bank notes, shall make or issiie bank
notes in any part of the United Kingdom.
And by sect. 11, after the 19th of July, 1844, it shall not be lawful
for any banker to draw, accept, make or issue, in England or AVales,
provisions of the statute, and no person, who was privy to it, could
enforce the iiccoptauce {iSuoih v. JJank of EngUuul, G Bing. N. C. 415). So,
wlioro a London joint stock bank, coiisistiug of more than six persons,
agi'eed with a Canadian bank tliat the manager of the London bank should
accept bills drawn by the Canadian bank, i)ayable at a date earlier than
six months, and the London bank should provide funds for meeting them,
the House of Lords hold that the acceptance of such bills was uulawfid,
and an infringement of the privileges of the Bank of England {I'crr'mg v.
Bitnston, 11. & M. 42G).
{j) Under this section, it was held that a paiincrship consisting of
more than six persons, and within sixty-live miles of London, could not
accept a bill of less than six months' date di-awn by a customer upon
them {Bank of Eixjlandw. Anderson, 9 Bing. N. C. ijS!)).
WEEKLY RETURNS. 331,
any bill of cxchango or promissorj' note, or engagement for tlio pay-
ment of money, payable to bearer on demand, or to borrow, owe
or take up, in England or Wales, any sums or simi of money on tbo
bills or notes of such banker payable to bearer on demand, save and
except tbat it shall be lawful for any banker, who was on the 6th of
May, 1 8-44, carrying on the business of a banker in England or "Wales,
and was then lawfully issuing, in England or Wales, his own bank
notes under the authority' of a licence to that effect, to continue to
issue such notes to the extent and under the conditions hereinafter
mentioned, but not further or otherwise ; and the right of any com-
pany or partnership to continue to issue such notes shall not be in
any manner prejudiced or affected by any change which may here-
after take i)lace in the personal composition of such company or
partnership, either by the transfer of any shares or share therein,
or by the admission of any new partner or member thereto, or by
the retirement of anj^ present partner or member therefrom : pro-
vided always, that it shall not be lawful for any company or part-
nership, now consisting of only six or less than six persons to issue
bank notes at any time after the number of partners therein shall
exceed six in the whole. On the death of any of tae members of a
firm, the privilege of issuing notes continues to the surviving
members (A-). And by sect. 26, any society or company or any per-
sons in partnership, though exceeding six in number, and carrying
on business in London, or within sixty-five miles thereof, may
di-aw, accept or indorse bills of exchange, not heing payable to hearer
on demand. The 3 & -i Will. 4, c. 98, s. 3, is therefore repealed in
respect of this restriction (/).
A banker, who becomes bankrupt, or ceases to carry on his biisi-
ness, or discontinues to issue his own notes, is prohibited from
recommencing or resuming the issue (m).
WeeMu Returns. — By 4 & 5 Yict. c. 50, s. 1, all bankers
in England, Scotland and Ireland, with the exception of
the Bank of England, issuing notes payable on demand
are to keep accounts of the amount of notes in circulation
at the close of each week, and to make verified returns
thereof every four weeks, under a penalty of 50/. By
sect. 3, from these accounts and the accounts which the
Bank of England is bound to render, the amount of these
(/.•) Smith V. Everett, 27 Beav. 446; 29 L. J., Chanc. 23G.
(/) A .summary of the above acts will be fouud in the Chapter on
Joint-Stock Banks.
{m) 7 & 8 Vict. c. 32, s. 12.
BANKS OF ISSUE.
notes in circulation in the United Kingdom every four
weeks is ascertained.
Monthlij Averages. — Any excess, above the limited
monthly average circulation, is prohibited by 7 & 8 Viet,
c. 32, s. 17, under the forfeitui-e of a sum equal to the
amount in excess of the authorized circulation.
By sect. 18, banks of issue are to render in a given form
weekly accounts to the Inland Revenue of the amount of
their notes in circulation under a penalty of 50/. ; and by
sect. 19, a mode of ascertaining the average amount of
bank notes in circulation is prescribed ; and by sect. 15,
the London Gazette is made conclusive e\idence in all
Com'ts of the amount of bank notes which the banker
named in the certificate of the commissioners is by law
authorized to issue and to have in circulation.
The commissioners (by sect. 20) are empowered (with
the consent of the Lords of the Treasmy), to examine,
copy or make extracts from the books of all banks of issue,
containing accounts of the notes in circulation, to ensure
the rendering true accounts.
Return of Names to the Stamp Office. — By sect. 21,
every banker in England and Wales is bound under a
penalty of 50/. on the 1st of January in each year, or
within fifteen days afterwards, to make a rotmni to the
Inland Revenue Office of his name, residence and occu-
pation ; and in the case of a company or partnership, of
the name, residence and occupation of every member of
the company or partnership, and also the name of the fu-m
under which the banker or company carries on business,
together with the names of the places of tlieii' business.
The 8 & 9 Vict. c. 76, s. 5, prescribes the mode of re-
covering and applying the penalties.
Unit in;/ of Banks of Issue. — A jiro vision is made by tlio
7 & 8 Vict. e. 32, s. 10, for the pm-pose of facilitating the
bankers' licences. 333
union or amalgamation of banking establishments, as far
as regards the cii'ciilation of theii" notes.
By Copartnersh'qjs under 7 Geo. IV. c. 46. — Banking
copartnerships established nnder this statute are entitled
to issue and re-issue notes, without being stamped, upon
security being given by sect. 1 6 ; but the enactment must
be read in conjunction with the provisions of the 7 & 8
Vict. c. 32, s. 12, as to becoming banki^upt, and rendering
accounts of their issue and circulation.
On issuing bills or notes before making the retm-ns,
they forfeit 500./. for each week of theii- neglect, by
sect. 18.
Irish and Scotch Banls. — The issue of bank notes in
Ireland {n) and in Scotland (o) is governed by similar
provisions and restrictions as the English banks are by
the Bank Charter Act of 1844.
Bankers^ Licences. — Bankers and joint-stock banks in
England, Ireland and Scotland, authorized to issue bank
notes, must take out annual licences, on which a duty of
30/. is payable respectively. The 55 Greo. III. c. 184,
Sehed. tit. Licence {p), unrepealed by 38 & 34 Yict.
c. 99, and the 24 & 25 Yict. c. 91, s. 35, regulate the
grant of these licences in England and Scotland, and the
9 Geo. IV. c. 80, and 5 & G Vict. c. 82, s. 31, also unre-
pealed by 33 & 34 Vict. c. 99, as to Ireland.
The 9 Geo. IV. c. 23, enabled bankers in England,
except within the city of London or within three miles, as
ah'eady stated {q), to issue their promissory notes and to
draw bills of exchange not exceeding seven days after
(w) 8 & 9 Vict. c. 37. This act is in the Appendix of Stattitea.
(o) 8 & 9 Vict. c. 38, -which is inserted in the Appendix of Statutes.
{p) The tenns in which the duty is imposed are as follows : — " Licence
to be taken out yearly by any banker or bankers, or other person or
persons, who shall issue any promissory notes for money payable to the
bearer on demand, and allowed to be re-issued, 30/."
f//) See ante, p. 330.
BANKS OF ISSUE.
sight, or twenty-one days after date, on tlie condition of
obtaining a licence. Thus, "by sect. 2 : —
It shall be la-s\'fiil for any two or more of the commissioners of
stamps to grant to all persons cai-rying on the business of bankers
in England (except as aforesaid), who shall require the same, licences
authorizing such persons to issue such promissory notes, and to draw
and issue such bills of exchange as aforesaid, on unstamped paper ;
which licences shall be and are hereby respectively charged with a
stamp duty of thirty pounds for every such licence.
By sect. 3, a separate licence shall be taken out in respect of every
town or place where any such unstamped promissory notes or bills
of exchange as aforesaid shall be issued or drawn : provided always,
that no person or persons shall be obliged to take out more than
four licences in all for any number of towns or places in England ;
and in case any person or persons shall issue or draw such unstamped
notes or bills as aforesaid, at more than four different to-R-ns or places,
then, after taking out three distinct licences for three of such towns
or places, such person or persons shall be entitled to have all the
rest of such towns or places included in a fourth licence.
By 7 & 8 Vict. c. 32, s. 22, every banker who shall be liable by law
to take out a licence from the commissioners of stamps and taxes, to
authorize the issuing of notes or bills, shall take out a separate and
distinct licence for every town or place at which he shall, by himself
or his agent, issue any notes or bills requiring such licence to autho-
rize the issuing thereof, anything in any former act contained to the
contrary thereof notwithstanding : pro-sided always, that no banker,
who, on or before the Gth of May, 18-44, had taken out four such
licences which on the said last-mentioned day were respectively in
force, for the issuing of any such notes or bills, at more than four
separate towns or places, shall at any time hereafter be required to
take out or to have in force at one and the same time more than four
such licences, to authorize the issuing of such notes or bills at all or
any of the same towns or places specified in such licences in force on
the 6th of May, 18-44, and at which towns or places respectively such
bankers had on or before the said last-mentioned day issued such
notes or bills in pursuance of such licences or any of them respec-
tively.
By 9 Geo. IV. c. 23, s. 4, every licence granted under the authority
of that act shall specify all the particulars required by law to be spe-
cified in licences to be taken out by persons issuing promissory notes,
payable to bearer on demand, and allowed to bo re-issued ; and every
such licence which shall be granted between the lOth of October and
the nth of November in any year shall bo dated on the 11th of
STAMP DUTIES ON TWSK NOTES. 835
October, and every such licence wHcli shall be granted at any other
time shall be dated on the day on which the same shall be granted ;
and every such licence shall (notwithstanding any alteration which
may take place in any copartnership of persons to whom the same
shall be granted) have effect and continue in force from the day of
the date thereof, until the 10th of October then next following, both
inclusive, and no longer.
Joint Stock Banlis' Licences. — The 24 & 25 Yiet. c. 91,
s. 35, enacts, that, where a company or copartnership con-
sists of more than six persons, it shall be sufficient to specify
in the licence or certificate the names and places of ahode
of any six or more of such persons who may he presented
to the commissioners, and to grant the licence or certificate
to them as and for the whole of the company or copartner-
ship, or otherwise to specify only the name or style of the
company or copartnership, and to grant the licence or cer-
tificate to such company, in and hy the said name or style,
as the commissioners may think fit ; and such licence and
certificate are to he as good and available as if the names
and places of abode of all the members of the company had
been specified therein, and the licence had been granted to
them.
Stamp Duties on Bank Notes. — The Stamp Act, 1870,
imposes or rather re-enacts the duty payable on bank
notes, which are issuable and re-issuable by licensed
bankers (r).
{>■) In the Schedule, which by sect. 6 (1) is made a part of the act, as
follows : —
£ s. d.
For money not exceeding 1? 5
Exceeding \I. and not exceeding 21 10
,, 21. „ bl 13
,, bl. ,, 10/ 1 9
„ 10/. „ 201 2
,, 20/. ,, 30/ 3
„ 30/. ,, 50/ 5
,, 50?. „ 100/ 08 6
By sect. 45, the term "banker" means and inchides any corporation,
society, partnership and persons, and eveiy individtial person canying
on the business of banking in the United Kingdom.
The term ' ' bank note ' ' means and includes —
(1.) Any bill of exchange or promissoiy note issued by any banker,
336 BANKS OF ISSUE.
Stamped Bank Notes. — Licensed bankers are prohibited,
by 9 Greo. IV. c. 23, s. 6, from issuing their promissory
notes for payment of money to the bearer on demand on
stamped paper.
Secuntij on Issue of Unstamped Bank Notes. — Bankers
licensed to issue their unstamped paper are required, by
9 Geo. IV. c. 23, s. 7, to give secmity by bond to the
crown, and by sects. 10 and 11 provisions are made to
meet changes in partnership in banks, and requiiing fresh
securities in such cases, and enforcing the renewal of the
bonds.
Composition in lieu of Stamp Duties. — By 9 Geo. IV.
c. 23, s. 7, and 17 & 18 Vict. c. 13, s. 12, country and
other bankers in England, authorized to issue promissory
notes and bills of exchange, may compound for the stamp
duties payable on their notes and bills ; and thereupon they
may issue and re-issue their notes on unstamped paper (s).
The 5 & 6 Vict. c. 82, s. 2, extends this privilege to bankers
in Ireland in respect of their notes («). The Commis-
other than the Governor and Company of the Bank of England,
for the payment of money, not exceeding 100^., to the bearer on
demand :
(2.) Any bill of exchange or promissory note so issued which entitles
or is intended to entitle the bearer or holder thereof, withovit
indorsement, or without any fui-ther or other indorsement than
may be thereon at the time of the issuing thereof, to the pay-
ment of money not exceeding 100/. on demand, -whether the
same be so expressed or not, and in -whatever form, and by
whomsoever such bill or note is drawn or made.
By sect. 4G, a bank note issued duly stamped, or issued unstamped by
a banker duly licensed or otherwise authorized to issue unstamped bank
notes, may bo from time to time re-issued without being liable to any
stamp duty by reason of such re-issuing.
By sect!^ 47 (1). If any banker, not being duly licensed or otherwise
authorized to issue unstamped bank notes, issues, or causes or permits to
be issued, any bank note not being duly stamped, he shall forfeit bOl.
By sect. 47 (2). If any person receives or takes any such bank note in
payment or as a security, knowing the same to have been issued mi-
stamped contrary to law, ho shall forfeit 20/.
(.v) The composition is as follows : —
For every 100/., and also for the frnctional part of 100/., s. d.
of the average amount, a value of such notes or bills
in firculation during every half-year 3 6
FORM OF NOTES WITH PRINTED DATES. 337
sioners of the Treasury may compound with bankers in
Scotland or elsewhere for the stamp duties on promissory
notes, payable to bearer on demand, and on their bills of
exchange. On the composition being entered into, the
bankers are entitled to issue and re-issue their notes and
draw bills on unstamped paper (t). The 27 & 28 Yict.
c. 86, extended this provision to bankers in Ireland in
respect of the duties payable on bank post bills of 5/. or
upwards. The act was originally limited in its operation
to bank post bills issued during three years from the 29th
of July, 1864, but the 30 & 31 Vict. c. 89, has made the
enactment perpetual.
Com2)osition with Banh of England on relinquishing Issue.
— The power of the Bank of England to enter into com-
positions with bankers, on discontinuing the issue of their
own notes, was limited to the 1st of August, 1856 (ii), but
a subsequent statute has extended the period, until parlia-
ment shall prohibit the issue of bank notes, or until the
privileges of the bank shall be determined (x). Banking
copartnerships, surrendering their right to issue their own
notes, by agreement with the Bank of England, do not lose
the privilege of suing and being sued in the name of their
public officer (y).
Form of Notes with printed Dates. — With respect to the
form of bankers' notes, the 55 Geo. III. c. 184, s. 18, pro-
hibited, under a penalty of 50/., a banker issuing any pro-
missory note payable to bearer on demand, and liable to
the stamp duties imposed by that act, with the date 2>rinted
therein. But this enactment has been repealed by the
23 & 24 Vict. c. Ill, s. 19, and there is no such restriction
now existing.
(0 16 & 17 Vict. c. 63, s. 7.
[u) 7 & 8 Vict. c. 32, ss. 23, 24.
(x) 19 & 20 Vict. 0. 20.
Ill) 27 & 28 Vict. c. 32.
G. . Z
338
BANKS OF ISSUE.
Issue of bauk
notes under
5^
Issue of Bank Notes under 61. — Bank notes payable to
bearer on demand for 20s. or above that sum, and less than
5/. were prohibited to be issued or re-issued by the Bank
of England or any banker in England after the 5th of
April, 1829 (s). In Ireland (o) and Scotland (6) such
notes are legal, if issued by bankers who were entitled to
issue their own bank notes prior to the year 1845, and
who have obtained the certificate of the commissioners of
Inland Eevenue, authorizing them to continue to do so.
But these notes must not be for the payment of a fraction
of a pound (c).
Foreign
banks of
issue.
Foreign Banl-s of Issue. — These banks are regulated
in their issue by the laws of the countries in which they
are established {d). The right to regulate the coinage and
issue the paper money of a state is part of its sovereign
prerogatives, recognized by the law of nations, and will be
protected by our Courts, when infringed or invaded.
Certain persons in this country had manufactured docu-
ments purporting to be the notes of a foreign state, the
Court of Chancery, at the instance of the sovereign of the
{z) 7 Geo. 4, c. 6.
(fl) 8 & 9 Vict. c. 37, ss. 8, 26.
{b) 8 & 9 Vict. 0. 38, S9. 1, 18.
((•) 8 & 9 Vict. c. 38, s. 5 ; 8 & 9 Vict. c. 37, s. 15. Promissory notes
or bills of exchange under 20s., which are negotiable or transferable, are
made void and illegal by 4g Geo. 3, c. 88, s. 2 ; if payable, however, to
a particular person, and not to order or to bearer, they would seem to bo
valid. Notes or bills for 206'. or above that siun or less than 5/., or on
which 20s. or above that siun or less than f)L remain undischarged, made,
drawn or indorsed by other parties than licensed bankers, require to be
in a certain form, to be payable twenty- one days after date, and to bo
attested under the provisions of the 17 Geo. 3, c. 30, made perpetual by
27 Geo. 3, c. 16, as to England ; and by 8 & 9 Vict. c. 38, s. 17, as to
Scotland ; and by 8 & 9 Vict. c. 37, s. 25, as to Ireland. The 9 Geo. 4,
c. G5, prohibited the circulation of these notes in England, when issued
in Ireland or Scotland. But the 2(') & 27 Vict. c. 105, s. I, originally
suspended these restrictions as to England and Scotland for three years
from the 28th of Jidy, 1863, and the 27 Vict. c. 20, as to Ireland, for two
years from the 13th of May, ISGl; and those acts have been since
annually renewed by the Expiring Laws Continuance Acts, see 44 & 45
Vict. c. 70.
{(i) Umpcror of Amtrla v. Kossuth, 2 Giff. 628; S. C, on appeal, 30
L. J., Chanc. 090.
LIMITED BANKING COMPANIES. 339
state, alleging that the introduction of such notes into his
dominions would cause great detriment to his subjects,
directed the manufactui-ers to deliver up the notes to be
destroyed, and the plates from which they had been
manufactured, and restrained such persons from manufac-
tiuing such notes (6"). But the Coiu'ts will not interfere
Y/ith the mode in which the sovereign of a foreign state
concedes or grants the right of issuing notes to others (/).
Therefore, where a bill was filed in the Court of Chan-
cery against the Ottoman Bank, its directors, and the
Sultan, alleging that the Sultan's government had granted
to the plaintiffs the exclusive right of issuing bank notes
in Turkey, and had subsequently in derogation of that
grant made a similar concession to the Ottoman Bank,
and prayed for a declaration of the plaintiffs' exclusive
right, and an injvmction against the Ottoman Bank and
its directors : it v/as held, that, inasmuch as the Court had
no jimsdiction on the contract or concession as against the
Sultan, it had none against the bank and its directors (/).
Colonial Banhs of Issue. — Banks of issue in India and in
the Colonies are regulated by local laws {g), or by charters
from the Crown.
Limited Banking Comjyanies. — A- banking company
claiming to issue notes in the United Kingdom is not
entitled to limited liability, but continues subject to un-
limited liabihty in respect of such issue (/?).
The negotiability and payment of bank notes will be
considered in the next Chapter.
(e) Ibid.
(/) Gladstone v. Ottoman Bank, 1 H. & M. 505.
Iff) In New South Wales, by 4 Vict. No. 13, and 5 Vict. No. 24 ; in
Queensland, by 4 Vict. No. 13 ; and in Canada, by the Consolidated
Statutes of Canada, cc. 54, 55.
(h) The Companies Act, 1879 (42 & 43 Vict. c. 76), s. 6.
z2
( 340 )
CHAPTER XXXYIII.
BANK NOTES.
Most questions respecting Bank of England and country
bank notes may be considered together. The right to
issue bank notes and their liability to stamp duty have
been stated in the last Chapter.
Definition of Definition of Bank Notes. — What shall be deemed bank
bank notes. ^^^^^^^ ^^^^^ ^^^ meaning of the Bank Charter Act of
1844, and the ..acts regulating the issue of bank notes in
Ireland and Scotland, as regards the enactments concerning
stamps, has been subsequently defined by the 17 & 18 Vict.
c. 83, s. 11, as follows: —
" All -bills, drafts or notes, other than notes of the Bank
of England, which shall be issued by any banker, or the
agent of any banker, for the pa^nnent of money to the
bearer on demand ; and all bills, drafts or notes so issued
which shall entitle or be intended to entitle the bearer or
holder thereof, without indorsement, or without any f ui"tlier
or other indorsement than may be thereon at the time of
the issuing thereof, to the payment of any sum of money
on demand, whether the same sliall be so expressed or not,
in whatever form and by whomsoever such biUs, drafts or
notes shall be dra\NTi or made, shall be deemed to be bank
notes of the banker by whom or by whose agent the same
shall be issued within the meaning of the 7 & 8 Vict. c. 32,
and 8 & 9 Vict. cc. 38 and 37."
And by sect. 12, all bills, drafts and notes which by or
imder those acts arc declared or deemed to be bank notes,
shall be liable to the duties and composition f(^r stamp
BANK NOTES, WHEN MONEY OR CASH. 341
duties, imposed or payable imder any act or acts in force
upon or in respect of promissory note's for the payment of
money to the bearer on demand ; and all clauses, provi-
sions, regulations, penalties and forfeitures, contained in
any act or acts relating to the issuing of such notes, or for
securing the stamp duties and composition',' or for prevent-
ing or punishing frauds or evasions in relation thereto,
shall be deemed to apply to all such bills, drafts and notes
as aforesaid, and to the stamp duties and composition
payable upon or in respect thereof.
Bank Notes, when Money or Cas/i.—'WheYeYer country Banknotes,
bank notes have once been treated' by the parties to a ^003™°'^*^^
transaction as money, no objection can afterwards be taken
that they are not so per se {a) .
For instance, in an action to recover money lent, the
payment of certain notes having been made to the defend-
ant's credit, and the fact that he had^been told the balance
afterwards, were held sufficient proof that the notes were
paid and had therefore been received by him {b) .
So, a person to whom a smn is payable imder an agree-
ment having once received it in bank notes, without com-
plaint or objection, cannot afterwards allege this not to be
a payment under the agreement (c).
So, if the attorney of a creditor, to whom a bank bill is
remitted by the debtor, writes that he will not receive it,
without a sum for his costs, but does hot return it, it will
amount to payment {d).
A banker stands in no different position than any other
person, as to his own notes ; if he sues, for instance, for
goods sold, the defendant cannot support a plea of tender,
by showing that he had offered the amount in the banker's
(a) Gillard v. Wise, 5 B. & C. 134.
\h) Gillv. Gillinrjham, 1 F. & F. 284.
(r) Shipton v. Cassoii, 8 D. & R. 130.
{(l) Caine v. Coiilton, 1 II. & C. 764.
342 BANK NOTES.
own notes ; he must have recourse to his set-off In respect
of the notes {e) .
Bequests. — Bank of England notes pass as " goods and
chattels," or as cash, in a will(/). Before they were made
a legal tender, they passed by a bequest of " all that shall
be in my house at my death" {g). Country bank notes
will pass mider a similar general bequest (//).
Snhject to Execution. — Bank notes, whether of the Bank
of England or of private banks, may be taken in execution
under a writ of fieri facias (/) ; and, consequently, they
are now looked upon as goods and chattels Avithin the
meaning of the statute against fraudulent conveyances
(the 13 Eliz. c. 5), so that a voluntary or fraudulent gift
of them is void against creditors (/.•).
Tenderer Tender or Payment in. — At common law, a tender iii
paymen in. j^^j^j. q£ E^giaud notes of a debt was a good tender, if th^
creditor did not object to receive notes in payment (/).
The same is settled of provincial banker's notes {ni) .
Country bankers are not liable to an action, if they pay
their notes, upon presentment, with Bank of England notes,
so long as Bank of England notes are a legal tender every^
where except by the Bank of England and its branches ;
but they are liable, if they refuse to pay their own not-es
other"\vise than by other country bank notes, or if they
insist on paying by any other mode than in such money
or cm'rency as constitutes a legal tender, in discharge, of
an ordinary debt {n).
it) Per Parke, B., Foster v. inUn, 12 M. & W. 201.
(/) Chapman v. Jfart, 1 Ves. sen. 271.
Iff) Fopliam V. Zadi/ Aijlcshurif, Ambl. GS.
(/() Malioin/ V. Donovan, 14 Ir. Chane. llcp. 2G2, 388.
(i) 1 & 2 Vict. c. 110, s. 12.
(/•) Barrark v. M'Cii//ack, 20 L. J., Chane. 10.5. '
(/) Griffbi/ V. Oakcs, 2 B. & P. 52C ; JFrir/Iit v. lical, 3 T. Tl.(541;
Anon., 1 Eq. Cas. Abr. 318, 319.
()«) Foff/hais V. Oliva; 2 C. & J. ir,.
(n) G)i/)), in order to be
discharged (::).
As to what is due time to present for payment a banker's
note, after the receipt of it, various cases have been de-
cided. A. sent his servant to a town, fourteen miles from
his residence, to sell cattle ; the servant sold them, and
took country bank notes in payment from B. (this was
about one o'clock on a Friday afternoon), and paid them
over to his master (who had been from home the whole of
Friday) on settling with him on Saturday evening. A.
presented the notes the following Monday morning at the
banking house, when it was found that the bank had
stopped payment on the previous Saturday, between three
and four o'clock. Under these circumstances, the Court
considered that A. was entitled to recover from B. the
amount of the notes, as A. had not been guilty of such
laches, by not presenting the notes on Saturday morning,
as made the notes his own, but intimated that the result
would probably have been different if the servant had been
(x) Sec Von Wort v. WoolUy, 3 B. k C. 116, 117; Tiuimis v. Gib/jliis,
21 L. J., Q. B. 405 ; IS Q. B. 722 ; Woodland v. Fear, 7 El. & Bl. olO.
(,y) Per Lord Lyudhur^^t, C. B., 1 C. & M. 611, C13.
(;) See Ror/ers v. Lanqford, 1 C. (!c M. 637; llcndersoit v. y{j)plt/uii, cited
Id. 642.
PRESENTMENT FOR PAYMENT AT BANK. 3i7
identified with the master (a). It seems if the master had
himself sold the cattle, and taken the notes for them, in
one miinterrupted transaction, he would at once have made
his election to take the notes as payment, according to the
doctrine above stated, so that, independently of the ques-
tion of laches, he must, in that case, have borne the loss.
The Court, if the case is duly reported, does not seem to
have had present to their minds the distinction between
giving bank notes, in completion of a sale, and giving them
in discharge of a precedent debt.
It is quite clear in general, that in case of a country
bank note, made payable at the banking house, there
must be a presentation for payment there, before a right of
action accrues {b), and merely alleging the insolvency of the
house as a reason for nonpresentment is impertinent; nor
will a declaration by the banker, that he will not pay his
notes, dispense with presentment (c) ; the note must be
presented, and a demand of payment made at the banking
house, -unless the banker has discharged the holder from
presentment and demand (c) ; nor is it a sufficient excuse
to say that the banker was from home, had absconded, and
left no effects at the banking house {d).
The stopping payment by a bank which issues notes
payable on demand does not preclude the necessity of
demanding payment in order that interest may become
payable {e) . Therefore, where a banking company stopped
payment and it was wound up, and the debts were being
paid in full, it was held that interest at 5/. per cent, was
payable on all promissory notes, drafts and other negotiable
securities cm^rent at the time of the stoppage, not from the
time of the stoppage, but from the respective times of the
{a) James v. irouhUlcIi, 8 D. & R. 3.
{b) Saundcrson v. Bowes, 14 East, 500 ; Blchenson v. Bowes, 16 East, 110.
[c) Howe V. Boices, 5 Taunt. 30. See, howevei", ante, p. 61, and next
page.
[d) Sands v. Clarhe, 8 C. B. 751.
{i) In re Herefordshire BankiiKj Company, 30 L. J., Chanc. 806. See
ante, p. 61.
348 BANK NOTES.
claims in respect thereof being sent in to the liquidators,
the stoppage of the bank not operating to dispense with
the necessity of making a demand (/).
If bank notes are transferred in payment of a debt, and
it turns out that, at the time of the transfer, though un-
: known to the creditor, the bankers had already stopped
payment and were insolvent, and there was no present-
ment at the banking house and demand of payment, on
the one hand, but, instead, the holder, within a reasonable
time, gave the party handing over the notes, notice of this
fact and offered to return them, which they refused, this
is a sufficient foundation to entitle the transferee to recover
in an action for the original consideration, for which the
notes were transferred {g).
The presentment, if made, must be in a reasonable time ;
there must be no laches, otherwise the holder is considered
as making his election thereby to take to the notes (/i).
In cases between a holder of bank notes, and the party
from whom he has received them (not being the makers) ,
it seems that to go through the form of presentment is
always immaterial, after insolvency and stoppage by the
bankers, provided that within a reasonable period — a
period for this purpose may be reasonable, which, never-
theless exceeds the time within which presentment ought
to have been made — the transferee gave the other party
notice that the notes were valueless, and offered to return
them (?■).
There is, however, a distinction between the situation of
a person with whom notes are deposited, and one to whom
they are paid in discharge of 'an antecedent debt, in the
event of the notes being worlliloss: thus, if A. deposits
notes of a country bank with^uother country bank, taking
(/) In re East of England Banking (Jompanrj, 38 L. J., Clumc. 121.
\g) Ilohxon v. Olhrr, 10 Q. B. 704.
(/() C'amidge v. AUcnbi/, G B. & C. 373 ; Lichjicld Union v. Greene, 26
L. J., Exch. 140 ; 1 H."& N. 884.
(i) I'cr Erie, J., 10 Q. B. 717 ; and gee Jl.igers v. Lnngford, 1 C. & M.
G37, ■where Loi'd Lj-ndlmrst says, " It is possible, if you had returned the
notes ill due time, that might have done iustead of i)reseutment."
NOTICE OF DISHONOUR.
the aeeountalDle receipt of the latter for the sum repre-
sented by the notes, and it turns out that the notes are
worthless, and the bank, as soon as they learn this, give
notice to the depositor and offer to return the notes, but
are refused, neither the bank nor the depositor being aware
at the time of the deposit, that the bankers, who issued the
notes, had then stopped payment; the depositor cannot
have an action against the banking house with whom the
notes were deposited, either for money lent, or money had
and received (A-).
Notice of Dishonour. — The same rule as to notice of
dishonour of bills of exchange, and notice of dishonour of
country bankers' notes, has always prevailed; the rule
is, it must be given by the post which leaves on the day
following that on which the holder gets information of the
fact.
An illustration of this position is afforded imder the fol-
lowing circumstances.
A., being previously indebted to B. in 500/., on a Friday,
about eight or nine a.m., paid to B., at his residence, at
Wantage, 490/. in notes of the Newbiu-y Bank, and 10/.
in a note of the Wantage Bank, B. giving him a receipt
for 500/. on the back of a promissory note, by which the
loan had been secured.
B. immediately sent 450/. of the notes to his bankers at
Wantage, with orders to transmit the Newbmy Bank notes
(which were made payable on demand at the bank of
Newbmy, or at the bank of Messrs. Barnard & Co.,
London) to London, to buy an Exchequer bill. Wantage
is distant from Newbmy about eighteen miles, and was
a two days' post from one place to the other ; the post left
Wantage for London at half-past five o'clock, p.m., every
day, exce^it Saturdays.
When B.'s messenger got to the bank, and delivered his
message, with the above order, one of the partners said it
{h) Timmis r. Gihbins, 21 L. J., Q. B. 403 ; 18 Q. B. 722.
34d
350 BANK NOTES.
would be dangerous to send the notes to London, and,
therefore, declined or refused to send them by post that
evening, but offered to enclose them on the Satm-day
evening, in their packet •which they usually sent in the
course of their business as bankers, two or three times a
week, by the coach, to London, and which packet, he said,
would be in London on Monday. This was ultimately
agreed to, and on the Saturday evening 450/. of Newbury
Bank notes were, by the bankers at the Wantage Bank,
cut in halves, and one set of halves enclosed in their
packet, and transmitted the same evening to London.
They usually sent theii' notes half by the coach, and half
by the post, and the other set of halves was sent by post
on the Sunday evening, addressed to the London corre-
spondents of the Wantage Bank; these halves reached
them between ten and eleven a.m. on the Monday, and the
packet, containing the other halves, was delivered to them
somewhat later the same day.
The Newbmy Bank stopped payment the same mornuig,
but their correspondents in London, Messrs. Barnard &
Co., continued to pay the Newbmy notes the whole of
Monday, but not afterwards, and the notes in question
would have been paid if they had been presented in the
com^se of Monday. When they were presented to Barnard
& Co. on Tuesday they were dishonoured.
Notice of the stopping of the Newbury Bank being
communicated to B. on the evening of Monday, he im-
mediately sent a messenger to A.'s house, who stated it to
A.'s wife, A. hunself having gone to bed ; A., the same
evening, said he would take the notes again, and return
them to the person fi'om whom he had received them. lie
afterwards refused to take back the notes.
In an action against him by B., it was held that B. was
entitled to recover, for that if the notes had been sent
direct by the post to Newbmy, they would not have been
paid as the bank had stopped on the Monday ; and that
sending the half notes to London was a reasonable pre-
BANKRUPTCY OF COUNTRY BANKS. 351
caution, and one which, therefore, B. had a right to
adopt (/).
Exchanging Notes. — It is a custom among country
hankers who reside in the same district to exchange each
other's notes once or twice a week, something after the
same plan as that adopted at the London or county
clearing house with respect to cheques.
This is a great convenience to all parties, and has the
same effect as the practice "with respect to the clearing
house, in lessening the amount of hank notes or gold re-
quired for the circulation of the district ; it also operates
as a check to a redundancy of issues, hy any particular
hank, within the district.
The notes of such hankers as reside heyond the district,
when they come into the hands of the hankers within the
district, are not sent to the issuers of them, but are sent at
once to London, for the purpose of being presented for
payment to the bankers to whom they are addressed, or
upon whom they are drawn.
Bankruptcy of Country Banls. — Where one of two
country banks became bankrupt, each at that moment
having in their hands bank notes of the other, which
together with other securities were reciprocally of nearly
the same amount, and the assignee of the bankrupt house
knowing this presented the notes, and obtained payment
of them from the solvent bank at their London agents, who
were unaware of the relative situation of the two banks,
the money was held to be recoverable by the solvent
bankers from the assignee, it being shown, that, on the
balance of accounts between the bankers, not only was
nothing owing by the solvent bank, but that there was a
sum of 22/. in theii- favour (m).
A country bank consisted of two partners, A. and B.,
(l) Williams v. SmitJi, 2 B. & A. 49G.
(m) Edwards v. Newman, 1 B. & C. 418.
352 BANK NOTES.
B. committed an act of baiikruptcy, and "became bankrupt,
at a time when another bank in the country held bank
notes of theirs, payable at the house of E. & Co., the
correspondents, in London, of the country bank first re-
ferred to. These notes were presented to R. & Co. for
pa;^Tnent, but a part only was paid by E. & Co. out of the
funds of A. and B. in their hands, A. pajdng the residue
by indorsing to the country bankers a bill of exchange,
given by a debtor to the firm of A. and B., for a larger
amount, which they consented to take in payment, and
when due it was paid to the latter bank by the acceptors.
Afterwards A. committed an act of bankruptcy, and a joint
commission issued, and the assignees claimed from the
second country bank the proceeds of the bill, and also the
sum paid on the bank notes by E. & Co., on the ground
that the pai-tnership having been dissolved by the act of
bankruptcy of B., of which A. had notice, he was not
competent to dispose of the partnership property.
The Comi held, that as A. had done no more than
satisfy a claim, which was complete at the time of the
bankruptcy of B., as he was warranted in doing, the action
was premature, until an account had been taken in equity,
and it was ascertained whether there was a balance against
B. or not — that it was impossible to contend that a part-
nership, when one partner commits an act of bankruptcy,
must immediately shut up the house — and that A.'s. having
acted in making the payment, with a knowledge of the
act of bankruptcy of B., made no difference {n).
Messrs. Forsters, bankers at Carlisle, had an agreement
with Surtees, bankers at Newcastle-upon-Tj^ne, by which
Forsters were weekly to transmit to the Newcastle Bank
all the notes of the Newcastle Bank, and certain other
specified banks, which they, Forsters, might have in their
possession ; and the Surtees were, in exchange every week,
to return to the Carlisle Bank ; and any balance on one
(w) IFarvey v. Crkhett, 5 M. & S. 335; IVoodhridfjc v. Swann, 4 B. & Ad.
G33 ; Morgan v. Morgan, 9 Exch. 14o ; 23 L. J., Exch. 21.
BANKRUPTCY OF COUNTRY J5AXKS. 353
side or the otlier "was to be made up by that party drawing
a bill on a banker in London, at twenty days, in favour of
the other party. On these facts, the bank notes so sent by
Forsters were held to constitute a debt from Surtees to
the Carlisle Bank, which Surtees might pay by a return of
bank notes imder the agreement ; but if they made no
such return, or a return short of the amount due, and gave
no bill for the balance, such balance was a debt against
them, which was proveable uuder ^fiat against Siu-tees (o).
The Newton Abbotts Bank advanced to A. 500/. upon
the security of his promissory note, payable on demand,
with interest, and dated 7th November, 1840. On the
17th of July, 1841, the bank stopped payment, at which
time A. held bank notes, and interest notes of the bank, to
the amount (with the interest due on the notes) of 581/. 5^.,
being more than sufficient to have paid and discharged
A.'s promissory note and interest ; in fact, he had collected
such notes expressly for the purpose of taking up, and pay-
ing his promissory note with Newton Bank notes ; and for
these, he alleged, he had given full value.
The bank subsequently, without notice to A., deposited
his promissory note, together with other securities, with
Messrs. Williams, their correspondents in London," for the
pui-pose of securing the repayment of such sums of money
as they might advance to the Newton Abbotts Bank, and
Williams & Co. held, on the whole, securities belonging to
the Newton Abbotts Bank to a greater amount than the
balance due to them from the Newton Abbotts Bank.
Williams & Co. compelled A. to pay the amount of his
promissory note and interest to them, and refused to allow
him to set off the notes of the Newton Abbotts Bank which
he held.
A., in ignorance of the fact that Williams & Co. held
securities to a greater amount than the balance due to
them, afterwards proved under the bankruptcy for the
bank notes which he held.
(«) Forster v. Surtees, 12 East, 605.
G. A A
354 BANK NOTES.
Tlie assignees of tlie Newtou Abbotts bankers paid
Williams & Co. wliat was due to them, after having credit
for the sum paid by A. on the promissory note, and took
from Williams & Co. all the remaining securities.
As A. woidd have had a right of set-off against the
bankrupts, if he had continued in possession of the pro-
missory note, he could not be deprived of that right by his
ignorance of the state of accounts between Williams & Co.,
and the bankrupts, and so the Court held the assignees to
be bound, on his withdrawing his proof, to repay to him
the amount of his promissory note, on his giving up
Newton Abbotts Bank notes to the same amount {p).
Proof. Proof. — With respect to proving in bankruptcy upon
the bank notes of a bankrupt, the following points have
been settled.
It has been questioned, whether a claim founded on
notes of a coimtry banker, payable on demand, when no
demand has been made, would support a fat against the
banker ; but, at any rate, it seems clear, that when such
notes have been given in payment of an antecedent debt,
the creditor may rely on that debt, if the notes are really
worthless {q) .
A partner in a bank, who signs the bank notes "For
A., B., &c." (stating all the names in the firm, and ap-
pending his signatm'e,) cannot, on the bankruptcy of the
paiinership, be liable to proof against his separate estate
on such note (r).
A person buying up bank notes of a firm, after its bank-
ruptcy, cannot prove for them, imless he shows that the
vendors of them were severally entitled to prove in respect
of the notes they sold («) ; but a person owing a debt to a
banking house may, even after they have actually stopped
payment, buy up their bank notes, for the purpose of
{p) Ex2Jarte Siaddon,?, M., D. & Do G. 2oG.
\q) Simpson V. SUccs, 6 M. & S. 29.5, 312.
(;•) J'Jxpario Clarke, 1 Dc Gcx, 1.53 ; 14 M. & W. 1G9.
(s) Ex parte Rogers, Buck, 490; Ex parte Dcluinir, 3 Ir. Eix- li. 573.
LOST NOTES. 355
setting off tlieir amoimt against his debt to them, not
haying at the time notice of an act of hanki'uptcy by
either of the members of the firm {s) ; but he could not
set off notes, taken after he knew of an act of banki'uptcy
by some of the pai-tners {t) .
One person may prove, on behalf of a large number of
creditors, each holding notes of the bank, under similar
cu'cumstanees with himself, provided that he does not
attempt to interfere in the choice of assignees, or with the
ceiiificate («) ; but these modes of proof are only allowed
where necessity or consent is the foundation ; Lord Eldon,
in one case, required the proof to be made in the name of
every one of 500 partners (.r).
Lost Notes. — Bank of England notes cannot be followed
by the legal owner into the hands of a bond fide holder
for good consideration or value without notice ; and the
holder of a Bank of England note is, prima facie, entitled
to prompt payment of it, and cannot be affected by the
previous fraud of any former holder in obtaining it. Pay-
ment, therefore, cannot be refused, when it is presented,
imless the bank can show that he was privy to the
fraud (y).
If A. pays a bank note to B., who pays it in discharge
of a debt to C, who presents it at the Bank of England,
where it is stopped on the ground that it has been frau-
dulently obtained ; and then A. pays the amount to C, in
consideration that his debt, due from B., had not been dis-
charged, partly thi'ough his (A.'s) means ; still A. cannot
recover in trover against the Bank of England (:;). The
(4) Ibid.
[t) Dickson V. Cass, 1 B. & Ad. 343; Ilawlcins v. Whiitcu, 10 B. & C.
217.
(«) Ex parte Gordon, 1 Mont. & A. 282 ; Ex parte Keys, 9 L. J,,
Clianc. 11.
{.«•) Ex parte Bank of England, 2 Glpi & J. 362.
((/) Solomons v. Eank of England, 13 East, 135, n.
(;) Benjamin v. Bank of England, 3 Camp. 417- The bank ia in the
practice of stopping the payment of a note that it has notice has been
stolen, upon receiving an iudcmuity from the applicant, and this has
A a2
356 BANK NOTES.
stopping payment does not appear to be a duty, but is
merely an accommodation rendered to the public (:;) .
A money changer, clianging a Bank of England note,
which had been stolen, but giving full value for it, and
taking it bond fide, not having at the time knowledge that
it had been stolen, was held entitled to recover from the
bank the amount of the note, although he had the means
of knowledge if he had taken proper care of certain notices,
advertising its robbery, which had been previously delivered
to him.
The money changer canied on business in Paris ; he had
received, some time before the transaction, a printed adver-
tisement, stating the note to have been stolen, among
others, from Messrs. A., in Eugland; he nevertheless
changed it bond fide about the middle of the year next
following that in the course of which he had received the
notice : it was held that he was entitled to recover from
the bank the amount of the note {a).
If a bank note is lost, or is stolen out of a letter put
into the post-ofRce, no action lies to recover it, or its value,
at the suit of the loser, against the Postmaster-General {b).
On the trial of an indictment for forgery, the loss of the
bank note alleged to have been forged, is not necessarily
a bar to a conviction ; thus, where a person swallowed the
bank note that he was indicted for having forged, it was
held, that he might have been convicted without the pro-
duction of the bank note (r).
Indemnity on Indemnity 0)1 Loss. — It seems, that the owner of a de'
stroi/ed note could not recover in an action against the
been declared to be a reasonable practice. Miller v. Bacc, 1 Burr. 4 GO ; seo
4 A. & E. 3G.
(r) Ibid.
[a) Raphael v. Bank of England, 2.5 L. J., C. V. 33 ; 17 C. B. 161. See
also Willis V. Bank of England, 4 A. & E. 21 ; Ba)ik of Bengal v. Fagan,
7 Moore, P. C. 72.
{h) Whitfeld v. Lord Le Despenccr, Cowp. 7o4. A deputy postmaster,
however, who has been guilty of neglect in not properly delivering letters
is liable. Jlordern v. Dallon, 1 C. & P. 181 ; Jioirning v. Goodchild, 3
Wils. 443.
(c) Ano), . Bullcr, J., cited 2 Camp. 211.
HALF NOTES. 357
makers ; or, at least, it may be said to bo a question not
wholly without doubt {d), and he was practically obliged
to have recourse to a Court of Equity in most instances.
The production of the note was essential to his right to
recover. But now it is enacted, that in case of any
action founded on a bill of exchange or other negotiable
instrument, it shall be lawful for the Court or a judge
to order that the loss of such instrument shall not be
set up, provided an indemnity is given to the satis-
faction of the Court or judge or master against the
claims of any other person upon such negotiable instru-
ment {e).
A bank note is a negotiable instrument within the mean-
ing of this provision, and a banker, upon an indemnity
being given, will be restrained from setting up the loss as
a defence to an action upon the note (/) .
Half Notes. — The practice of cutting notes in half for
the puqiose of transmission by post is legal {g). If A.
cuts a note in half and sends one half by post to B., retain-
ing the other half, upon a condition which B. does not
perform, the half so sent may be recovered from B {It).
If half of a note was lost, it was the rule, apparently,
[d) Hansard v. Robinson, 7 B. & C. 90.
{e) 17 & 18 Vict. c. 125, s. 87. The benefit of this provision is con-
fined to a plaintiff suing on a lost note in one of the superior Courts of
common law, and does not apply to liis suing- in the County Courts or
other inferior Courts, unless an order in council has extended the statute
to these Coiu-ts. Xoblc v. Bank of England, 2 H. & C. 355 ; 33 L. J.,
Exch. 81.
(/) M'BonncU v. Murray, 9 Ir. Com. Law Rep. 495.
{g) Redmaipic v. Burton, 2 L. T., N. S. 321. In a notice emanating
from the Post Office, of August, 1873, with reference to sending by post
letters containing bank notes, the following ad\-ice is given : — " It is
strongly recommended when bank notes are sent by post that they shoiild
be cut in halves, and the second halves not despatched until it has been
learnt that the first have been received." A person may be indicted for
stealing or embezzling the halves of bank notes sent in a letter. Mix v.
Mead, 4 C. & P. 535. Where a man was indicted at common law for
stealing one half of a Bank of Ireland note for 20? , the indictment was
held bad, the article in question not being the subject of an indictment
for larceny at common law. Reg. v. Murtagh, 1 Crawford & Dix's Irish
Circuit Ciiises, 355.
{h) Smith V. Mundg, 29 L. J., Q. B. 172.
358 BANK NOTES.
not- to allow the owner of tlie other half to recover, if
he could not either produce an entire note, or prove
that the other half had been actually destroyed {i) ; but
the above statute will be equally applicable in this case,
if indeed it would not, independently altogether, be a good
defence for the bankers to show, that they had paid the
amount once to the original owner of the whole note, upon
his presentment of his half ; for although the holder of the
lost half might show that it came to his possession bond
fide, still it is said, that the taker of a half note necessarily
takes it under suspicious circumstances, and he is not
bound to take the half note at all ; he ought to bear the
loss, it seems (/).
Pdghtsof Rights of Finder. — "Where A. had picked up some bank
finder. notes on the floor of B.'s shop, and handed them over to
B. (who was not aware of the notes having been on the
floor) to keep till the owner should appear, and B. caused
advertisements to be inserted in various newspapers, but no
one appeared to claim them, and three years elapsed, and
(i) Mayor v. Johnson, 3 Camp. 324.
{j) Sec Bayley on Bills, 379, 6th edit. Willes, J., in Rcdmaync v.
Burton, 2 L. T., N. S. 321, said, " lly opinion is that bankers would be
liable to pay -without an indemnity, as any person taking half a note
would take it with notice." Query, which halt' of the note? Mr. Morse
upon the loss of a part of a bank note says, " A piece or fraction only
of a bank bill is non-negotiable. Negotiability is an attribute of
the bill as a whole. When it has been severed into parts, this quality
pertains to no one of them. They are not even payable ^^ro tanlo, accord-
ing to the ratio of the size of the part to the Avhole. Any person who
takes a piece, takes it subject to all the equities which burdened it in the
hands of the party transferring it Lord Ellenborough has
expressed an opinion, that the rightful o■n^ler of the whole bill, holding
a half only, could not maintain his action, because the other half might
come into the hands of a bona fide holder who could sue, and so two
recoveries might be had. {^layor \. Johnson, 3 Camp. 321.) But, says
Judge Marcy (in Hinsdale v. Bcnih of Orange, 6 Wend. 378), this implies
the negotiability of the second half. If it is non-negotiable, of course it
can never come into the hands of a bond fide holder, and Lord Ellen-
borough's supposed difficulty can never arise ; that it is non- negotiable
' is as clear to my mind as the proposition is, tliat a part is not equal to
the whole.' Certainly the impression in the coiamuuity is so genci'al to
the same effect, that it would bo difficult to imagine that any person could
in real honesty and good faith receive a lialf of a bank bill as money."
Morso on Banking, pp. 413, 414.
RIGHTS OF FINDER.
then A. requested B. to return tliem, tendering the costis of
the advertising, and offering an indemnity, and B. refused ;
A. was held entitled to recover the notes in trover against
B. (/•).
It is very important, in the case of a loss of bank notes,
to bear in mind the general principle : if a person finds
lost property, and keeps it, having, at ihe time of finding
it, no means of discovering the owner, he is not guilty
of larceny, if he afterwards has means of finding the
owner, and, nevertheless, retains the property to his own
use {I).
If the finder had seen the notes drop from the owner's
pocket ; or, if the notes had had the name of the owner
written upon them; or, if there had been other similar
circimistances, to enable the finder to know who was the
owner, at the moment he inched up the notes, that would
have been different (/).
Even if a finder instantly appropriates the note, animo
furandi, but under such circumstances as to warrant a jury
in finding, that, at the time of the apj^rojjriation, he really
believed that the owner could neither find the note nor be
found himself, such appropriation is not larceny (m).
In the case of a note being marked, or inscribed, so that
the real owner might be found, it seems, there must be
proof that the finder can read these marks, &c., before he
can be convicted of stealing {n), or that he got them read
to him.
Under the law, as formerly expounded, it was con-
sidered, that the rights of the transferee might be affected
by the degree of caution that he used in taking the
note.
But as previously stated the law has been laid down in
different terms, and the Courts have shown a desire to
(/.) Jlridffes V. Haickesworth, 21 L. J., Q. B. 76 ; 1-5 Jur. 1079.
{I) Rcfj. V. Lixon, 25 L. J., M. C. 39.
{m) Reg. V. Thurborn, 1 Den. C. C. 388, 395, 396.
(«) Meg. V. Preston, 2 Den. C. €. 353. See R. v. Moore, 30 L. J., M. 0.
77 ; R. V. Christopher, 28 L. J.-, M. C. 35.
359
360 BANK NOTES.
retrace some of tlie steps that led to previous decisions.
Even gross negligence in taking a note is not now of itself
a reason why a holder for value should suffer. Thus,
six Bank of England notes, for 500/. each, were stolen
in November, 1852, from Brown & Co., in Liverpool,
who immediately published notices of the robbery, and
of the numbers of the notes, in the French and English
languages, and circulated them in England, France, and
other countries ; fresh notices to the same effect were pub-
lished in April, 1853, one of them being left in due
course, in 1853, at the place of business of one St. Paul,
a money changer in Paris ; in June, 1854, a stranger
entered the shop, and asked what was the exchange of
the day, and produced a 500/. Bank of England note ;
the file of notices, kept in the shop, was not looked at,
but the stranger was asked to write his name, and to
produce his passport, and tSt. Paul, finding the name so
written and that in the passport to agree, gave change
for the note, at the current rate of exchange, and then
remitted the note to his correspondent in London, who
presented it at the Bank of England and was refused pay-
ment ; the bank was held bound to pay, on the ground
that a person taking a negotiable instrument bond fide, and
for full value, is entitled to recover on it, although it has
been stolen, and ho took it negligently (;;).
statute of Operation of the Statute of Limitations on Bank Notes. —
limitations. The notcs of the Bank of England until paid by the bank
are not, like a promissory note of a private person payable
on demand, affected by the Statute of Limitations (ry),
notwithstanding the notes may not be presented for pay-
ment, or payment be not made for very many years after
their issue, for tlioy form part of the established currency
of the country. With regard to country and other bank
(;;) Raphael v. Bank of England, 25 L. J., C. P. 33 ; 17 C B. IGl ; Bank
of Bengal v. Macleod, 7 Moore, P. C. C. 3o. See ante, p. 3.)G.
(7) Norton v. Ellam, 2 ]\r. & "W. 4G1. The statute runs from the date
of the note in Huch case, altlioujrh no demand is ever made.
OPERATION OF THE STATUTE OF LIMITATIONS ON. 361
notes of banks having autliority to issue them, a similar
principle governs the law of their circulation and currency.
By the acts regulating the issue of bank notes in Ireland (r),
and in Scotland (s), it is expressly enacted, " that all bank
notes shall be deemed to be in circulation from the time
the same shall have been issued by any banker, or any
servant or agent of such banker, until the same shall have
been actually retm-ned to such banker or some servant or
agent of such banker." The 7 & 8 Yict. c. 32, which
regulates the issue of bank notes in England, does not
contain this provision; but, as we have seen, the 17 & 18
Vict. c. 83, after specifically defining, s. 11 {(), what shall
be deemed bank notes within these acts for the purposes of
issue and stamping, enacts, sect. 12, " that all clauses, pro-
visions, regulations, &c., contained in any act or acts,
relating to the issue of such notes," &c., (and of course
including the above-mentioned acts,) " shall be deemed to
apply to all such notes;" and consequently it follows, as a
necessary consequence, that until they are returned to, or
paid, cancelled or redeemed by, the banker issuing them,
mere lapse of time does not affect their circulation or value
any more than it does Bank of England notes {u) .
{)■) 8 & 9 Vict. c. 37, s. 17.
(«) 8 & 9 Vict. c. 38, s. 8.
{() Ante, p. 336. These acts are in the Appendix.
(«) Mr. Morse, in his Treatise on Banks and Bankino-, put the non-
liability of bank notes to the operation of the Statute of Limitations on a
higher and ditierent principle. He says, pp. 403, 404, " A bank note is
not subject to the running of the Statute of Limitations, as anj^ other
simple indebtedness, or promise to pay, would be, although the bill is
not distinguishable in fomi from such a promise. Its purpose of circu-
lation necessarily involves this result. Every time that it is re-issued by
the bank the promise is renewed, and it must usually be impossible in the
case of any particiUar bill to say how often it has passed into, and again
has been paid out by, the bank, or when it was last so paid out. But
even if in any individual case it could be sho^Aai that the last issue was
at a time so long past that the period of the statute has since elapsed, yet
another objection, which goes to the root of the matter, still remains
behind. For lapse of time, in the case of these instruments, affords no
presumption of their having been paid. On the contrary, their existence
in other hands than those of the bank, is at least prinid facie evidence of
non-payment, since they are never paid, and, generally speaking, pay-
ment can never be enforced upon them at law, unless they arc surren-
dered to the promisor. Fiu'ther, as already shown, a new contract and
362 BANK NOTES.
Forgery. Fovgcnj. — As regards forging and passing bank notes,
knowing them to be forged, it is enacted by 24 & 25 Yict.
c. 98, s. 12, that whosoever shall forge or alter, or shall
offer, utter or dispose of, or put off, knowing the same to
be forged or altered, any note, or bill of exchange, of the
Bank of England, or of Ireland, or of any other body cor-
porate, company, or person carrying on the business of
bankers, commonly called a bank note, a bank bill of ex-
change, or a bank post bill, or any indorsement on, or
assignment of any bank note, bank bill of exchange, or
bank post bill, with intent to defraud, shall be guilty of
felony {x).
A conditional uttering partakes of the criminal qualities
of any other uttering ; thus, where a person gave a forged
acceptance, knowing it to be so, to the manager of a bank,
where he kept an account, saying he hoped this bill would
satisfy the bank as a security for the balance he owed
them ; this was holden a sufficient guilty uttering (y).
When the authority of a banking company to draw and
issue notes is recognized by statute, it is not necessary to
prove it by the charter or otherwise (s).
On an indictment for disposing and putting off forged
bank notes, knowing them to be forged, the prosecutor
a new cause of action is created by each transfer, so that the statute
could beg'in to run only from the time when the last holder came into
possession." In an ai-ticle in the Money Market Review for November 9,
1867, page 482, the foUo^^^ng remarks occur with reference to this sub-
ject, " Country bank notes, as well as the notes of the Bank of England,
are promissonj notes paijahlc to the hearer on demand, and as to them, the
promise to pay may be regarded as a promise which is renewed from time
to time, and evenj time the note chanrjes handx, and may tlius be subsisting
for any number of years, until the note is either cancelled or paid. The
Statute of Limitations must be specially i^lcadcd, and the banker or
maker of the note, in pleading the statute, would have to plead that he
had not made the promise at any time within the six years, and he could
not prove that plea against the evidence of the note in the hands of the
bearer, which became a new and distin(!t promise to him the moment he
became the holder or bearer of it."
[x) By the above statute the punishment on conviction is penal servi-
tude for life, or for a term not exceediug five years ('27 & 28 Vict. c. 47,
8. 2), or imprisoimaent not exceeding two years, with or without hard
labour, and with or without solitary confinement.
(v) Jteg. v. Cooke, 8 C. & P. 582.
(r) Hex V. Al'Keay, 1 Mood. C. C. 130.
OBTAINING MONEY OR GOODS BY FOKGED NOTES. 363
has a right to give in evidence the fact of other forged
notes having been uttered by the prisoner, for the purpose
of proving his knowledge of the notes in question being
forged also (a) ; and delivering to another person a forged
bank note, to be put off or passed by the latter, is a " dis-
posing of and putting off" within the statute {h).
Purchasing or receiving forged bank notes, knowing
them to be so, is felony {e).
E»rj)'aving Plates for Bank Notes. — It is also felony to
engrave plates for the notes of the Bank of England or
of Ireland, or of bankers, or to manufacture or sell paper
resembling the paper used by the Bank of England or
Ireland for their notes or bills, or their watermarks, with-
out authority {d).
Larceny. — As regards the stealing of bank notes, where
a person intercepts notes at a post office, which are in
course of transmission from one branch of a banking
company to another (at which they had been issued), he
may be found guilty of the larceny of the notes described
as money, though they were not in circulation at the
time (e).
Obtaining Money or Goods by means of forged or wortJtless
Notes. — If a person gives forged country bank notes in
payment for goods, and, when the seller objects to receive
them, assures him they are good, knowing them at the
time to be valueless, he is indictable for cheating and
defrauding the seller of the goods; but the evidence to
show the notes to be bad and worthless must be clear and
full. In a case where there was some evidence to show
{a) Hex V. TFylic, 1 N. R. 92.
(i) Jicz V. T(i!mcr, 1 N. E,. 96. See li. v. Giles, 1 Moo. C. C. 16G.
(c) 24 & 25 Vict. c. 98, s. 13.
(d) lb. ss. 14—18.
(V) TiCff. V. West, 26 L. J., M. 0. 6 ; -7 Cox, C. C. 183.
364 BANK NOTES.
that the bank, of which the paper in question purported to
be the notes, had stopped seven years previously, and the
notes appeared to have been exhibited under a commission
of bankruptcy against that bank, and the words importing
the memorandum of exhibit had been attempted to be ob-
literated, but the names of the commissioners remained
on each of them, and the notes had never been presented
for payment at the bank, or at Sir J. Esdaile's, in London,
where they were made payable, the judges held the evi-
dence insufficient to show the notes to be bad {/).
So, it is not sufficient to show the bankruptcy of two
out of three partners in a bank, and the shutting up of the
house ; for the third being solvent, the note, if presented
to him, may perhaps be paid [g). So, even where the
bank had ceased business twenty years previously, and the
note uttered was old, discoloured and dated many years
before the time of giving it, and had been regularly can-
celled and withdrawn from circulation, the makers having
traced a large cross over the face of it, but the proceedings
in bankruptcy against the bankers were not produced, it
was held that the prisoner, though he gave a false address
when asked, could not be convicted of a false pretence, as
there was no evidence of his knowing the note to be
cancelled and unavailable at the time he uttered it {h).
A person passing a note of a country bank for 5/., pay-
able on demand, as a good note, and as of the value of 5/.,
knowing at the time that the bank is insolvent and has
stopped payment and cannot pay the note in full, may be
indicted for obtaining money by false pretences (/).
A person fraudulently offered a 1/. Irish bank note as a
note for 5/., and obtained change as for a o/. note ; though
the prosecutor could read, and the note upon its face
clearly afforded the means of detecting the fraud, it M'as
(/) Hex V. Flint, R. & R. 4G0.
\g) Rex V. Spenser, 3 C. & P. 420.
(A) lier/. V. dh)-/:, 2 Riiss. C. & M. 29G, n.
(/) Ii■) 29 & 30 Vict. c. 2.'), 8. 7.
(/) Can. Ord., March, 18G1, 7 Jur., N. S. 58, Tart I.
Iff) 29 Vict. 0. 25, ss. 9, 10, 11, 12.
I'/i) Id. s. 3.
(() /(/. 8. 5.
{/c) Id. 8. 17.
(0 Id. s. 8.
(/«) Id. s. 14. A Hijniliu' provision i.s containod in the -IS Geo. 3, c. 1,
H. 18, ami in 24 Vict. c. 5, s. 12.
(/() /(/. H. IG.
EXCHEQUER BILLS AND BONDS.
is to be given to repay tlie money, in case the bill should
be afterwards produced (»).
Forging or counterfeiting an exchequer bill or a coupon,
or an indorsement, or tendering a forged bill in payment of
a debt, is felony (o). So is the manufacturing of paper,
plates or dies in imitation of those in use for exchequer
bills (7;). Having the possession of such paper, plates or
dies unlawfully is a misdemeanor {q). An exchequer bill
or bond is the subject of larceny, as being a valuable
security for the payment of money (r).
The 17 & 18 Yict. c. 23, and 29 Vict. c. 25, s. 30,
authorize the issue of exchequer bonds for advances made
by the Bank of England to her Majesty.
hi) 29 Vict. c. 25, s. 16.
(o) 29 Vict. c. 25, s. 15 ; 24 & 25 Vict. c. 98, s. 8.
(p) 29 Vict. c. 25, s. 20 ; 24 & 25 Vict. c. 98, s. 10.
{q) 29 Vict. c. 25, 8. 21 ; 24 & 25 Vict. c. 98, s. 11.
(r) 24 & 25 Vict. c. 96, s. 1.
369
G. B B
( 370 )
CIIAPTEE XLI.
couroxs.
Coupons are sometimes deposited with bankers, as securi-
ties for advances to tlieir customers, but more frequently to
collect the interest due on them. Coui^ons of foreign and
colonial bonds, and railway debentures payable to bearer,
are negotiable instruments, and pass by delivery {a) . The
fact, that the custom to -pass fore /'(jn securities in the country
where they are made by delivery is of recent origin, would
not seem to make them other than negotiable instruments
so long as the custom itself is established ; though in the
case of inland secmities the custom must have existed by
the law merchant {h) . The interest, though payable half-
yearly, accrues de die in diem, and is therefore apportion-
able(c). Being securities for money, they may be taken
under a writ of execution, or attached in the hands of a third
person. Colonial and foreign bonds or debentro-es, issued
since the 3rd of June, 1862, for money raised or borrowed
in this coimtry upon their security, are subject to a stamp
duty of one-eighth per cent, upon the principal amount
for which the bonds are respectively given (r/), except upon
a bond not exceeding 25/., when the duty is 8(/. {e).
Foreign or colonial bonds issued in this country, prior to
this period, did not require to be stamped (/). Coupons
(«) Gorrjier v. MicviUc, 3 B. Sc C. 15 ; rricc v. Great TJ'cstcni Ilalhray
Conipanij, 16 L. J., Exch. 87; ITazeltine v. Su/i/crs, 18 L. J., Ex. 166;
Jones V. reppcrcoDw, 28 L. J., Ch. 158 ; Goodwin v. Roberts, L. R., 10
Ex. 76.
{b) Crouch v. Credit Fonder of Enijland, L. R., 8 Q. JB. 374. See Eum-
lallw. Met. Banlc, 2 Q. B. D. 191.
(<■) In re Itorjcrs, 30 L. J., Chanc. 153.
{d) Stamp Act, 1870, and 34 Vict. c. 4, s. 2; Fislier's Stamp Acts,
p. 170.
((•) 31 & 32 Vict. c. 121, s. 10, since the 30th July, 1868.
(/) Yrisnri v. Clement, 2 C. & P. 223.
COUPONS.
are, liowever, free from stamp duty {g). The liolders of
consols and of India stock are enabled to convert their
stock into certificates of a like amount, with coupons
annexed, representing the annual dividends (//).
[(j) By the Stamp Act, 1870, Sclied. tit. Bill of Eschajtge, Exemp-
tions, a coupon or warrant for interest attached to and issued with any
security is specially exempted from duty.
(/() See ante, p. 308.
371
\^ 15 2
( 372 )
CHAPTER XLII.
REMITTANCES.
As regards questions respecting the transmission of money,
by the intervention of bankers, from one part of England
to another, many points have been noticed, arising in
cases which have been referred to principally for other
purposes, and will be found in parts of the work where
discounts, commission, and the relations between banks in
one town, and their branches^ or correspondents in London,
or elsewhere, are stated.
A. & Co., in America, remitted to B. & Co., in Liver-
pool, bills of exchange, for the purpose of taking up other
bills of nearly the same amount which were maturing and
payable at Liverpool. A. was a partner with B. at Liver-
pool, but in a totally different partnership. B. had depo-
sited these bills with a Liverpool bank, to meet advances
which the bank had made for the firm of B. & Co., and he
did not appropriate the proceeds as directed by A. & Co. :
it was held, that the holders of the bills, to take up which
the second set had been transmitted to England, were
entitled to recover as against the bank the amount of the
proceeds of such bills, the bank having had notice of such
intended appropriation (a) .
A merchant piu-chased from the New Orleans bank a
bill drawn by them upon the bank of Liverpool, and was
informed by the persons representing the New Orleans
bank at the time of the purchase that the Liverpool bank
had, or would have, funds of the New Orleans bank suffi-
cient and applicable to meet the bill, and appropriated for
the purpose. Before the bill was presented for acceptance,
(a) Thniier v. Li^tn; SO L. J., Chanc. 4'27.
KEMITTANCES. 373
the New Orlecaus bank stopped payment, and the Liver-
pool bank declined to accept the bill on presentation, or
to pay it at maturity, on the ground that though they had
in their hands sufKcient funds of the New Orleans bank
to meet the bill, none of such funds were specifically appro-
priated to the payment of it. The course of business
between tlie two banks was for the Orleans bank to remit
to the Liverpool bank bills for collection, and to draw
bills against the remittances, taking care to keep them
always in funds to meet the bills drawn upon them : the
Court held, that there was no specific appropriation of the
funds of the New Orleans bank in the hands of the bank
of Liverpool to meet the bill, and that the statement made
to the purchaser of the bill amounted to no more than a
representation of the course of business of dealing between
the two banks, and did not create any equitable lien on the
funds in his favour {h).
Bankers at Lima established a credit agency with the
general company in London, and agreed to send remit-
tances within ninety days to cover drafts. The general
company, being in difficulties, obtained an advance of
money from the Peruvian Bank, to be repaid out of ex-
pected remittances from the Lima Bank to cover bills then
current, and the Peruvian Bank employed as agents to
receive and to select from the expected securities the
managing director of the Greneral Company and tlieir own
managing director, who had been two years previously the
manager of the General Company, and was cognisant of
and party to the arrangement with the Lima Bank. The
secmities were selected by and handed over to the Peru-
vian Bank upon their arrival, and the following day the
General Company stopped payment and was wound up : —
Held, that the Lima Bank had no title to recover the
securities from the Peruvian Bank (c).
Where a debtor remits to his creditor a bank note or a
(/>) Thompson v. Simpson, 39 L. J., Chanc. 857; L. R., 5 Ch. Go9.
(r) J^ftiico de Lima v. yinr/lo-Fcrurian Bcuilc, L. E,., 8 Ch. D. IGO ; 38
L, T. 130.
374 REMITTANCES.
bill of exchange, by a mode of conveyance dii-ected by the
creditor ; or, if be transmits by the post, as being tbe usual
mode of transmission, in tbe absence of orders from tbe
creditor prescribing tbe mode, and tbe bill or note is lost or
stolen, tbe loss falls upon tbe creditor {d).
Foreign. Foreign. — Witb respect to tbe transmission of money
between England and foreign countries, it may be desirable
to notice some of tbe decisions, especially as regards tbe
subject of tbe course of oxcbange.
A., in London, drew a bill on B., in Paris, wbicb, having
been negotiated tbrougb Amsterdam, was presented for
acceptance to B., wbo refused to accept it, but promised
tbat tbe bill should be paid at maturity. Before, bow-
ever, the bill was due, the French Government prohibited
the payment of any bills drawn in countries at war with
France, which Great Britain was at that time, and on that
account the bill was not paid by B. Under these circum-
stances A. was held liable to the payees, not merely for
the whole value, that he originally had received for the
bill, with interest, and tbe expenses of protesting, but for
tbe amount of the re-exchange, by the cii'cuitous course
of Amsterdam, tbat being a consequence of the bill not
having been paid (e).
When a bill drawn and indorsed in England, and pay-
able abroad, is dishonoured by tbe acceptor's nonpapnent,
the holder is entitled as against the drawer to the amount
of the re-exchange, that is, the value at the rate of ex-
change on tbe day of tbe dishonour of the sum expressed
on the face of the bill, in the cmTcnoy of the country where
it is payable, with interest and expenses (_/').
The acceptor of a bill is, in crpiity at least, liable for
re-exchange (17).
(f?) IfarwicJc v. KoaJccs, Peabo, 67.
(c) Mellisih\. Simeon, 2 H. Bl. 378; and see De Tastcty. Baring, 11
East, 265.
(/) Suse V. Pompe, 8 C. B., N. S. 538 ; 30 L. J., C. P. 75.
{g) In re General South American ComiAOi;/, 7 Ch. D. 637 ; and sec Frehn
V. iiotjal Hank of Liverpool, L. II., 5 Ex. 92.
( 375 )
CHAPTER XLIII.
JOINT STOCK BANKS.
It now becomes necessary to state in wliat respects the
legislature lias interfered, to qualify or regulate the general
law with respect to bankers, in cases where a number of
persons combine or unite for the purpose of carrying on
a banking establishment.
By the 39 & 40 Greo. III. c. 28, s. 15, as has been pre-
viously stated («), it was forbidden to establish any corpo-
rate bank whatever, or any bank where the number of
bankers in partnership should exceed six, so as " to bon-ow,
owe, or take up any sum or sums of money, on their bills
or notes, payable on demand, or at any less time than sis
months fi"om the boiTOwing thereof," during the con-
tinuance of the privileges secured to the Bank of England,
by former acts of parliament.
And again by the 7 Greo. lY. c. 46, the formation under
deeds of settlement of banking copartnerships consisting
of more than six persons was only permitted provided
they did not carry on business within the distance of
sixty-five miles from London, and had not any of their
banking establishments in London. Every member was
also responsible for the payment of all bills and notes
issued, and for all sums of money borrowed, owed or taken
up, by the copartnership. These restrictions and con-
ditions were imposed by the first section of the act.
How these tv/o statutes became in course of time modi-
fied by subsequent acts, and how far banks can at the
present day issue notes payable on demand, has been
abeady considered at some length {b). The following
{,/) Ante, p. 320.
{h) Ibid.
37G
JOINT STOCK BANKS.
concise summary on tlie law on the subject, however, as
stated in Mr. Justice Lindley's Law of Partnership (p. 186),
may be usefully cited here : —
(1) The Bank of England can alone issue in London or
within three miles notes payable to bearer on demand.
(2) Beyond that limit such notes may be issued by
bankers who were lawfully issuing them before May, 1844,
under a licence, but by no other bankers ; and not, there-
fore, by any banking firm of more than six persons cany-
ing on the business of bankers within sixty-five miles of
London. In other words there are three limits ; (a) Lon-
don and thi'ee miles round, in which the Bank of England
has an exclusive monopoly ; (b) the district more than
three, but within sixty-five miles of London, in which the
monopoly is divided between the Bank of England and
banking firms of less than six members, lawfully issuing
notes before May, 1844 ; (c) the district more than sixty-
five miles from London, in which the monopoly is divided
between the Bank of England and banking firms of six or
more or less members, lawfully issuing notes before May,
1844.
Rotum of Return or Account of JSfamcs of Members and Puhlic
names of Officers. — Another restriction on banking partnerships is
nieuiDcrs and '' .
officers. imposed by the 7 Geo. IV. c. 46, sect. 4, with respect to
the retm'ns such partnerships are bound to make : —
Before any sucli corporation or copartncrsliiji, exceeding tlie
number of six persons in England, shall begin to issue any bills or
notes, or borrow, owe or take up any money on tboir bills or notes,
an account or return shall be made out, according to the form con-
tained in the schedule marked (A.), wherein shall be set forth tho
true names, title or fii-m of such intended or existing corporation or
copartnership, and also the names and places of abode of all tho
members of such cor2:)oration, or of all tho partners concerned or
engaged in such copartnership, as the same ros2iectively shall ap-
pear on tho books of such corporation or cojiartnership, and tho
name or firm of every bank or banks established or to be established
by such corporation or copartnership, and also tho names and
RETURN OF NAMES OF MEMUERS AND OFFICERS. 377
places of abode of two or more jiersons, being members of such
corporation or cojiartncrsliip, and being resident in England, wbo
sball have been appointed public officers of such corporation or
copartnersbip, together with the title of office or other description
of every such public officer respectively, in the name of any one of
whom such corporation shall sue and bo sued, as hereinafter pro-
vided (c), and also the name of every town and place where any of
the bills or notes of such corporation, or coiDartnershii) shall be
issued by any such corporation, or by their agent or agents ; and
every such amount or return shall be delivered to the Commissioners
of Stamps, at the Stamp Office in London, who shall cause the same
to be filed and kept in the said Stamp Office, and an entry and
registry thereof, to be made in a book or books, to be there kept for
that puri^ose, by some joerson or persons to be appointed by the
said commissioners in that behalf, and which book or books any
l)erson or persons shall from time to time have liberty to search and
inspect, on payment of the sum of one shilling for every search.
This section lias become immaterial in one respect, viz.,
as regards that part of it which makes compliance with it
a condition precedent to the power of issuing notes, be-
cause, since the 19th of July, 1844, by the 7 & 8 Vict.
c. 32, s. 10, no new bank can issue notes ; but it is neces-
sary to retain it in other respects, because, as to them, it
is still law.
A retm'n or an account, omitting the words justice of tJie
peace, is receivable in evidence, it being proved that the
person signing the verification was, in fact, a justice of the
peace [d).
A certified copy of the return is evidence of the facts
pertinently stated in it ; it is not necessary to prove that
the affidavit verifying it was made by the public registered
officer of the company (c).
On the other hand, the retm-n is not the only evidence
of these facts, for they may be proved aJiumlc {/). An
(c) I. e., by a public officer. See post, Chapter, Public Officer.
(d) Bosanquet v. Woodford, 5 Q. B. 310.
(e) Bosanquet v. Woodford, 5 Q. B. 310. If it purports to be signed by
the "cashier" it will siiffice. Harvey v. Scott, 11 Q. B. 92, 102.
(/) Edwards v. BitcJianan, 3 B. & Ad. 788 ; Rex v. James, 7 C. & P.
553 ; Reg. v. Carter, 1 Den. C. C, 65.
378 JOINT STOCK BANKS.
annual general retiu'u for March, 1848, lias been held
admissible in evidence, to show a person to be a member
on the 24th of January, 1848 {rj).
By sect. 4, the return is made evidence, that all persons
named therein, as members of the corporation or copart-
nership, were such at the date of the account or retimi.
On the other hand, however, when certain proprietors of a
company were sued upon a judgment against the public
officer, the enmneration of proprietors in such a return, to
the Inland Revenue Office, was not receivable in evidence
against the plaintiff, to show that at the time they were
not proprietors (//).
It is said to be the rule not to admit the retiu'u in evi-
dence, unless it has been filed within the time limited by
the statute (i).
The fact of the return having been made, is not a con-
dition precedent to the public officer's right to sue on
behalf of the company (/.•) .
Annual Annual Return. — The continuance of the retm'us is thus
provided for by sect. 5 : —
That such account or return shall be made out bj^ the secretary or
other person being one of the public oflBcers appointed as aforesaid,
and shall bo verified by the oath of such secretary or other jiublic
officer, taken before any justice of the peace, and which oath any
justice of the peace is hereby authorized and empowered to admi-
nister, and that such account or return shall, between the 28th of
Fehruarii and the 2oth of March in every year, after such corporation
or copartnership shall be formed, be in like manner delivered by such
secretary or other public officer as aforesaid, to the Commissioners of
Stamps, to be filed and kept in the manner and for the inirposos as
hereinbefore mentioned.
This is one of the pro\isions of the legislature, which it
(f/) Bosanquct v. Sltortriclge, 4 Exch. 699.
(h) Trcscott V. Buferij, 1 C. B. 41.
(;) 2 Taylor on Evklcucc, 1491, 4th edit.
(/,) Bown-x. Mitchell, 5 Exch. 415; 19 L. J., Exch. 302, decided on
similar provisions in the Scotch Banking Act, 7 Geo. 4, c. C7.
ANNUAL llETURN. 379
is usual to call directorij ; it does not seem to be obligatory
to file the retiu^n within the specified period of the j-ear (/).
Then sect. 6 enacts, that certified copies of such returns
shall be evidence (w).
It is manifest, that register books, in wliicli the names
of members are inscribed, and from which the returns are
to be copied, cannot be altered or varied bv the dii-ectors,
or the company, especially jmst litem motam, except for
the pm-pose of a merely verbal correction (//).
The Board of Inland Revenue is dii-eeted, for a fee of
ten shillings, to give certified copies of the retmiis or ac-
comit, sect. 7.
An account of the names of persons appointed officers,
persons ceasing to be members, of persons newly becoming
members, &c., is to be made/ro/;i time to time, as occasion
requires, sect. 8.
These returns are also required to be made by banking
companies carrying on business within sixty-five miles of
London (o) .
By 7 & 8 Yict. c. 32, s. 21, every banker in England and
Wales must on the 1st of January in each year, or within
fifteen daj's afterwards, make a retm-u to the commissioners
of Inland Revenue of his name, residence and occupation,
and, in case of a company or copartnership, of the name,
residence and occupation of every member, with other
particulars.
The commissioners had also to publish such retmns in
certain newspapers, but by 43 & 4-t Yiet. c. 20, s. 57, it is
enacted that commissioners shall no longer be obhged to
publish in any newspaper any return made to them by any
banking company which is duly registered under 6 Geo. IV.
c. 42, 7 Geo. IV. c. 46, 7 Geo. IV. c. 67, and the Com-
panies Acts or any of them.
(?) P«- Parke, B., Steward y. Bimu, 12 M. & W. G63.
(;«) See as to the form and requisites of the return, Bosan^uct v. Short'
ridi/e, 19 L. J., Exch. 221.
(«) Shortridqe v. Bosnuqud, 16 Beav. 90.
{ij) 2.3 & 20 Vict. c. 89, s. 205, 3rd Schedule, Part IL
380 JOINT STOCK 13ANKS.
Co)i tracts. — Copartnersliips formed under 7 Geo. IV.
c. 46, not being constituted corporations, contracts wliicli
tliey may enter into within the scope of their business do
not require to be under seal, but may be signed or executed
by their manager {p).
Actions and Suits. — No more than one action or suit for
the recovery of one and the same demand can be brought
against these copartnerships, in case the merits have been
tried in such action or suit {q).
The mode prescribed by 7 Geo. IV. c. 46, s. 9, for these
copartnerships to sue and to be sued, is by a pubhc officer,
and being applicable to other banking companies by
subsequent legislation, it will be more useful to consider
the whole subject under one title (r).
{p) In Swift V. Wintcrhotliam (L. R., 8 Q. B. 2U, 2o0), Mr. Justice
Quain, in delivering the considered jiidg-ment of the Court, made the
following observations upon the constitution and character of one of these
banking copartnerships: "It appears that the Gloucestei-shire Banking
Company is a copartnership, formed under 7 Geo. 4, c. 4G, for the pur-
pose of carrpng on the business of bankers at places more than sixty-five
miles from London. The companj' is not a corporation, and has, there-
fore, no common seal. It is a copartnership created by deed or articles
of copartnership for a particular purpose, with certain statutable privi-
leges. It can sue and be sued only in the name of one of its public
officers, and in all litigious business the company is repi'esented by one of
its public officers who must be a member of the company ; and individual
members cannot be sued in respect of transactions with the company
till a judgment or deci'ce has been first obtained against the company
through one of its public officers. In I'uir/ri v. I'dffc (3 C. B. 16), a com-
pany established under this act was considered a quasi-corporate body, so
as not to be affected by what may have been known to any individual
member.
" The act contains no provision as to the manner in which the company
shall make or sign deeds, contracts, or documents of any description. It
confers no authority on the imblic officer to bind the comjiany, but makes
him the representative of the bank only for litigious i)urposes ; and
although he must be a member of the company, he may have nothing to
do with the management of its affairs. It seems obvious, therefore, from
the nature of its constitution as a fluctuating and numerous body, that
the company cannot affix its signature to documents otlicrvvise than by
the hand of some individual or individuals wlio, by the articles of co-
partnersliip, are appointed to represent the general body in such
matters."
{//) 7 Geo. 4, c. 4G, s. 10, and 1 & 2 Vict. c. 9G, s. 2, made perpetual by
5 & 6 Vict. c. 85.
(>•) Sec jjost, Chapter, Public Officer.
EFFECT OF JUDGMENTS, DECREES AND ORDERS.
Set-off hettcccn Cojmrtnenhip and Members. — With
respect to this right it is enacted («), —
That no claim or demand which any member of any such co-
partnership may have in respect of his share of the capital or joint
stock thereof, or of any dividends, interest, profits or bonus, pay-
able or apportionable in respect of such share, shall be capable of
being set off, either at law or in equity, against any demand which
such copartnership may have against such member on account of
any other matter or thing whatsoever ; but all proceedings in re-
spect of such other matter or thing may be carried on as if no claim
or demand existed in respect of such capital or joint stock, or of
any dividends, interest, profits or bonus, payable or apportionable
in respect thereof.
Where a member of a banking copartnership kept an
account with them as his bankers, and became bankrupt,
indebted to the bank on the account, the company, being
largely indebted to other persons, has a right of proof
against the bankrupt in respect of the balance due to them
on his account (/).
Effect of Judgments, Decrees and Orders. — Then there is
a provision, that decrees in equity, made or obtained against
the imblic officer, shall take effect against the company («),
and so with respect to judgments in actions {u).
The 7 Geo. IV. e. 46, s. 13, provides a mode of realiz-
ing the fruits of a judgment obtained against the public
officer, in case there are no pai-tnership assets to meet it,
by an exhaustive process of execution against members,
either collectively or individually. This process is by
issuing a \mt of scire facias, by leave of the Com-t in
which the judgment is obtained, in order to make them
parties to the judgment, and so liable to execution {x).
This mode of proceeding, however, against members,
(s) 1 & 2 Vict. c. 96, s. 4, continued by 2 & 3 Vict.c. 68, and 3 & 4
Vict. c. Ill, and afterwards made perpetual by 5 & 6 Vict. c. 85, App.
{t) Ex parte Davidson, 2 M., D. & De G. 368.
(m) 7 Geo. 4, c. 46, ss. 11, 12.
{x) Eansfordv. Bosanquct, 2 Q. B. 972; Hodgson v. Scott, 2 Exch. 469;
Hani; of England v. Johnson, 3 Exch. 598 ; Barlrr v. Buftresn, 7 Beav. 143.
381
382 JOINT STOCK BANKS.
wlien execution against the public officer proves to be
fruitless or ineffectual, would seem to have been entirely
superseded by the power gi^-en to a company, unable to
meet its liabilities, or to creditors whose claims are un-
satisfied, of obtaining a winding-up order under the Com-
panies Act of 1862, and thus to stay all legal proceedings
against the company or its members {y) . The procedure
by scu'e facias is therefore practically obsolete. It may
be observed, that when execution issues upon a judgment
against the public officer, no scire facias is necessary, as he
is a party to the judgment and previously liable thereon (;;).
Execution cannot issue against parties after they have
ceased to be members for three years (f?). But members
satisfying an execution against them are entitled to
reimbursement out of the fimds of the copartnership, or to
contribution from the other members, as in the case of an
ordinary partnership [h). The law applicable to the wind-
ing-up of banldng copartnerships, and the liability of
shareholders to contribution, will form the subject of a
separate consideration.
Regido'tng Judgments against Mcmhcn. — If a judgment
is recovered against the public officer, and it is sought to
charge the real estate of a member of the copartnership at
the date of the judgment, the Court of Common Pleas
has no jurisdiction over the senior master, to order him to
receive the memorandum, in order to register the judg-
ment pursuant to the 1 & 2 Vict. c. 110, s. 19, and 3 & 4
Vict. c. 82, s. 2. It is entirely in his direction to receive
the memorandum (c).
Where, however, a creditor obtained a judgment against
the official manager of a banking company, and registered
(y) 25 & 26 Vict. c. 89, ss. 199, 201, aiid ss. 80, 87, 89.
Iz) Hnnrood v. Lair, 7 M. & W. 203.
\a) Barker v. Buttre-'in, 7 Beav. 134.
[b) 7 Geo. 4, c. 40, s. 14.
(V) Rr parte iV^.w, o D. k L. 330 ; 5 C. B. ir,.'> : 2 &- 3 Vict. o. 11, n. 8.
UNDEK THE 7 & 8 VICT. C. 113, 383
the judgment against tlio real estate of a former share-
holder without the leave of the Court, the Irish Court
of Chancery gave relief against such registration and
ordered it to bo removed, as being a cloud on his title to
his lands [d). The registration of judgments or decrees in
equity, in order to charge the lands of shareholders, will
now be rarely resorted to, as the means of obtaining
satisfaction of judgment debts will be more efficacious
and expeditious under proceedings to wind up the com-
pany.
The 7 Geo. IV. c. 46, unrepealed. — fSueh are the several
provisions relating to the constitution and regulation of
these copartnerships ; and they are still in force as to all
such copartnerships which have not registered themselves
under the Joint Stock Banking Companies Act of 1857 (f),
or under the Companies Act of 18G2 (/), or have not
obtained letters patent incorporating them under the 7 & 8
Vict. c. 113.
Joint Stock Banks under the 7 (^ 8 Vict. c. 113. —
Banking copartnerships could not be formed by deeds of
settlement, under the 7 Geo. IV. c. 46, after the 6th of
May, 1844. The 7 & 8 Vict. c. 113, which was passed in
the year 1844, for regulating joint stock banks in England,
prohibited the formation of banking companies consist-
ing of more than six persons, unless by virtue of letters
patent granted according to its provisions {g). It enabled
banking companies of more than six persons, either formed
or carrying on business before the 6th of May, 1844, to
[d) Eone v. 0' Flahertle, 9 Ir. Chanc. Rep. 119, 497; see Ilarris v.
Itoyal British Bank, 27 L. J., Exch. 1.
[e) 20 & 21 Vict. c. 49.
(/) 25 & 26 Vict. c. 89. The 6 Geo. 4, c. 42, as to Irish banks, is still
in force.
{(j) See Wirjan v. Fowler, 1 St. 459 ; Perrinq v. Dunston, E,y. & M. 426.
The 9 & 10 Vict. c. 75, repealed by 20 & 21 Vict. c. 49, s. 12, and 25 _&;26
Vict. c. 89, s. 205, was a siniilar enactment for the regulation of joint
stock banks in Iroland and Scotland.
384 JOINT STOCK BANKS.
obtain letters patent incorporating- them (//). This act was
subsequently repealed, as we shall afterwards see, but it is
necessary to refer to the provisions of the act as governing
the companies which may have been formed under it.
A body of persons intending to become a joint stock
banking company under this act petitioned the Queen in
council, according to a prescribed form (?) ; and, on the
report of the Board of Trade that the statutory require-
ments had been complied with, a charter was granted (A-) ;
a deed of settlement containing certain specified provi-
sions (/), which, however, have been materially altered in
one respect by subsequent legislation, to be mentioned
hereafter, so as to admit of the re-election of outgoing
directors (;;?), was then executed by the holders of at least
one-half of the shares (/), and the Queen by the letters
patent incorporated the company {ii), but so that the
liability of the shareholders was not limited (o), and actions
might be brought by or against the company, or share-
holders, reciprocally (;;), every judgment, decree or order of
any Court of justice against the company being enforceable
against the company, and against shareholders and fonner
shareholders {q), and execution against the company,
proving ineffectual, might be had against any shareholder,
and if unproductive, then against any person who might
be a shareholder at the time when the cause of action
arose, witli a limitation of three years after ceasing to be a
shareholder (r) ; such shareholder being entitled to reim-
bursement out of the effects of the company, or, in default,
to contributions from the other shareholders (s).
A creditor, obtaining a judgment against the company,
ma}- proceed by scire facias on the judgment against the
shareholders, and is not limited to the remedy given by
{h) 7 & S Vict. c. 113, s. 45. {o) 7 & 8 Vict. c. 113, s. 7.
(/) Id. s. 2. (p) Id. s. 8.
(/.) Id. s. 3. () Id. 8. 9.
(/) Id. s. 4. (/•) Id. a. 10.
{in) See infra, p. 390. (s) Id. ss. 11—15.
hi) Id. s. 6.
UNDER THE 7 & 8 VICT. C. 113. 385
execution (/). The letters patent incorporate the body
for the piu'poses of banking, and empower it to purchase
and hold lands of such annual value as expressed in the
letters patent ; but these are granted for a term of years,
not exceeding twenty years (ii) ; and the incorporation
does not limit the liability of the shareholders, as before
observed. Within three months after the grant of the
letters patent, and before the company begins business, a
memorial, setting forth the title or name of the company,
the names and places of abode of all the members, and of
the directors, managers and other like officers, and the
names and places of every bank or banks established by the
compau}', and the name of every towai or place where the
business is carried on, is to be made out {x), — this to be
repeated every year between the 28th of February and the
25th of March, as long as they carry on business as bankers,
— and delivered to the Inland Revenue Office, there to
be filed, and an entry or a register made in a book is open
to search for a fee of one shilling ; and a printed list of
the registered names and places of abode is to be made
out from time to time and kept in a conspicuous place in
the company's principal place of business (y) ; a like
memorial is to be made out from time to time, as occasion
requires, and delivered to the above office, according to a
prescribed form (;:), containing the above particulars of
every new director, manager or other like officer, and the
names of all persons who have become members, either in
addition to or instead of any former member, and the name
of every new town in Avhich the company carries on business,
and the names of all w^ho have ceased to be members ; and
such further account is to be filed and registered at the
stamp office {a) ; these memorials require to be signed by
{t) Cleve V. Ilarwar, 1 H. & N. 873. See Morriusc v. The licnjul Bnlish
Bank, 1 C. B., N. S. 67.
- (m) 7 & 8 Vict. c. 113, s. 6.
{x) Id. Sched. A.
(V) Id. 8. 16.
(;) Id. Sched. B. 1.
(«) Id. s. 17.
G. C C
386 JOINT STOCK BANKS.
the manager, or one of the directors, and verified b}^ his
dedaration before a magistrate {b), and the persons whose
names ajipear in the then last-deHvered memorial are from
time to time the existing shareholders (c).
Certified copies of these memorials, under the hand of
the commissioners of stamps and taxes, are receivable in
evidence as proof of their contents {d), and are obtain-
able on the payment of a fee of ten shillings (e) .
A shareholder, whose name is properly inserted in the
last-delivered memorial, remains liable to execution, al-
though he has subsequently bona fide transferred his shares,
and the transfer has been duly executed by the transferee
and registered (/). But if a shareholder dies before a
judgment is obtained against the company, although his
name appears in the memorial, which was existing at the
time of his death, his executors could not be proceeded
against by a judgment creditor (g).
The Courts will not interfere with the company in the
performance of the duty of making these returns, as regard
the form in which they are made.
The capital stock of the company can in no case be less
than 100,000/. ; the means by which it is raised, the
amount paid up at the date of the petition to the Queen for
the grant of letters patent, and where and how such paid-
up capital is at that date invested, must be set out in such
petition (//). Before a company commences business,
one-half at least of the capital subscribed for is required
to be fully paid up (//). But the omission to comply with
this provision does not render the company illegal or re-
lieve the shareholders from the pa^inent of its debts or
(b) 7&8 Vict. c. 113, s. 18.
(c) Id. s. 21.
(d) Id. 8. 19.
{e) Id. s. 20.
(/) Fri/ V. EhsscU, 3 C. B., N. S. CGo ; 27 L. J., C. P. 153. See
Dossctt V. Hardiuff, 1 C. B., N. S. 524; Danicll \. Boyal British Bank, 1
H. &N. 681.
{ti) Puwis V. Butler, 4 C. B., N. S. 469 ; 27 L. J , C. P. 249.
(//) 7 & 8 Vict. c. 113. .ss. 2, 5.
UNDER THE 7 & 8 VICT. C. 113. 387
liabilities (i). In tlie petition to the Queen for the grant
of letters patent, the persons proposing to become a bank-
ing company set out the proposed number of shares ; the
shares not to be less than 100/. each; tlie actual amount
of each of the shares into which the proposed capital stock
is divided must also be stated (/.•). The deed of partner-
ship must contain also specific provisions for preventing
the company from purchasing any shares, or making
advances of money or securities for money, to any person
on the security of a share or shares in the partnership
business (/). Subject to the regulations of the act, and
to the provisions of the deed of settlement, every share-
holder may sell and transfer his shares by deed duly
stamped, in which the consideration is to be triily stated,
such deed to be according to a given form (;«), or to the
like effect ; such deed, after execution, to be delivered to
the secretary of the company, to be kept by him, and a
memorial thereof entered by him in the register of trans-
fers ; the entry is to be indorsed on the deed, at a fee for
every such entry and indorsement, of not exceeding 2s. Gd.,
payable to the company.
Until such transfer is delivered to the secretary, the
buyer is not entitled to dividends, or to vote, in respect of
such share («).
No share can be transferred until all calls, for the time
being due on it, and every other share the owner of it held
is paid (o).
The register of transfers is to be closed by the du-ectors
for not more than fourteen days previously to each ordi-
nary meeting; they may fix a day for the closing, of
which seven days' notice is to be given in the London
{)) In re London and Eastern Banlcing Corporation, Ex parte Longworth,
1 De G., F. & J. 17 ; 29 L. J., Chanc. 55.
{k) 7 & 8 Vict. c. 113, s. 2.
(0 Id. s. 4.
{m) Id. Sched. C.
(«) Id. s. 23.
(o) Id. s. 24.
cc2
388 JOINT STOCK BANKS.
Gazette (;>) : any transfer made within sneli fourteen
days is to be considered as being made subsequently to
such, ordinary meeting, as between tbe company and tbe
transferee {q).
Wlien shares come to any one by the death, bankruptcy
or insolvency of a shareholder, or by the marriage of a
female shareholder, or by other legal means than by the
above mode of transfer, the claimant is not entitled to
receive dividends, or to vote in respect of them, until such
transmission of them is authenticated by a declaration in
^vl'iting, stating the manner how, and to whom they
pass, to be made and signed by a credible person before a
magistrate (/•).
This declaration is to be left with the secretary, who
thereupon is to enter the name of the person entitled on
the register book of shareholders, at a fee of not exceeding
2s. 6d., payable to the company (s).
Where persons are jointly entitled to shares, all notices
required to be given to shareholders must be given to the
person whose name stands first in the register of share-
holders, which is to be notice to all of them (/).
When the shareholder is a minor, idiot or hmatic, the
receipt for any money payable to him of the guardian, in
case of a minor, of the committee, in case of an idiot or
lunatic, shall be sufficient {u) .
The company is not boimd to regard trusts to which any
shares may be subject (x).
The receipt of the person in whose name a share stands
in the books of the company discharges the company, in
[p) In sect. 25, the words used are, "notice shall be given by adver-
tisement iu some newspaper as after mentioned," but the only newspaper
mentioned subsequently is the Londou Gazette, sect. 38.
{rj) 7 & 8 Vict. o. 113, s. 25.
{)•) Id. s. 26. The directors may require such other form as they may
think fit.
(s) Jcl. 8. 26. The transmission of shares by will, intestacy or on mar-
riage of a female shareholder, is provided for by sect. 27.
(t) Id. 8. 28.
(u) Id. 8. 29.
(.r) Id. a. 30.
UNDER THE 7 & 8 VICT, C. 113. 38^
respect of any dividend or other sum paj^able iu respect
of sucli share, notwithstanding any trust attaching to the
share (x).
The Kability of shareholders is unlimited (//) ; they may
be sued by, and may sue, the company (s), and judgment,
decrees and orders against the company may be under
certain circumstances enforced against them individually,
whether they are members at the time the cause of action
accrues, or have been members within tlu-ee years (s) .
A creditor cannot maintain an action against a share-
holder for his debt, his remedy is against the com- .
pany(r/).
From time to time the directors may make such calls
on the shareholders, " in respect of the amount of capital
stock respectively subscribed by them," as the directors
shall think fit {b). ^Vhenever execution upon any judg-
ment against the company shall have been taken out
against any shareholder, the directors, within twenty-
one clays next after notice served upon the company of
the payment of any money by such shareholder, his
executors or administrators, in or toward satisfaction of
such judgment, shall make such calls upon all the
shareholders as will be sufficient to reimbm'se such share-
holder, his executors or administrators, and every share-
holder must pay every call to the persons at the times
and places from time to time appointed by the direc-
tors (c).
Besides being liable to pay calls, shareholders may forfeit
their shares by leaving calls unpaid, if the directors at any
time after six calendar months from the day appointed for
the payment of such calls declare them to be so forfeited ;
{x) 7&8Vict. c. 113, s. 30.
(y) Id. s. 7.
(s) Id. ss. 8—10. See post, pp. 392, 393, as to tliia liability.
(a) Fell V. Bnrchctt, 7 El. & Bl. 537 ; 26 L. J., Q. B. 223.
(b) 7 & 8 Vict. c. 113, s. 31.
(c) Id. Interest at bl. per cent, per annum on calls impaid is recoverable
under sect. 32. And sects. 33 — 35 provide for the enforcement and proof
of calls in an action.
390 JOINT STOCK BANKS.
the shareholders still remaining liable for the calls due
before the forfeiture (d).
But in order to authorize the sale or forfeiture of such
shares, the declaration must be confirmed at some general
meeting, held at least two calendar months from the day
the notice of intention to declare was given (e).
And on payment of the arrears of calls due on such
shares and the interest and expenses being made before
actual sale, they revert to the original owner (/). The
deed of partnership of every joint stock banking company
imder this statute, prepared according to a form approved
of by the Board of Trade, in addition to any other pro-
visions contained in it, must include specific provisions for
the management of the affairs of the bank, and the election
and qualification of directors (g).
As regards re-election of retii-ing directors, no deed of
settlement of any company, established since the 29th of
July, 1856, under the 7 & 8 Yict. c. 113, need contain
any proviso for preventing the re-election of retiring di-
rectors, either absolutely or for any limited period ; and,
in every banking company, being at that date established
under that act, the directors retiring at any general meet-
ing henceforth will be eligible for re-election, (if duly
qualified in other respects,) notwithstanding the proviso in
the 4th section, that the deed of partnership should contain
a specific proviso for the retii'ement of at least one-fom-th
of the directors yearly, and for preventing the re-election
of the retiiing du'cctors, for at least twelve calendar months :
this proviso having been repealed by the 19 & 20 Yict.
c. 100, ss. 1, 2.
Any one of the directors is empowered to sign bills of
(d) 7 & 8 Vict. c. 113, s. 37. Notice of the intention to declare must
be first served, sect. 38 ; if the addi-ess of the proprietor is not known, it
must be published in London Gazette, sect. 38.
(e) Id. a. 39. Evidence of forfeiture, sect. 10. Title to such shares of
buyer, sect. 10. By sect. 11, no more shares to be sold than sufficient to
satisfy calls and costs.
(/) Id. a. 42.
(ff) Id. s. 4.
UNDER THE 7 & 8 VICT. C. 113. 391
exchange or promissory notes on behalf of the compan}^
provided it is therein expressed to be made, accepted or
indorsed by him on behalf of the company ; and he is not
to be liable on such bills or notes, otherwise than he would
have been on any other contract, signed by him on behalf
of the company (h). A manager, or other officer to per-
form the duties of a manager, must be appointed imder
this statute [i).
The duties of the manager, who is not personally hable
on contracts signed by him on behalf of the company, are
the following only, as limited by the statute.
Bills of exchange or promissory notes on behalf of the
company may be made, accepted or indorsed, in any
manner specified in the deed of partnership, provided
they are signed by the manager (or one of the dii-ectors),
and by him expressed to be so on behalf of the com-
pany {k). Services of notices, \aits, or other proceedings
at law or in equity, or otherwise, on the manager or any
director, by lea^dng them at the principal office of the
company, or if the company has suspended or discontinued
business, by servmg personally the manager or director,
or by leaving the same with some inmate at the usual or
last abode of the manager, is good service on the com-
pany (/). There must be holden once at least every year,
at an appointed time and place, an ordinary general meet-
ing of the company {m).
Extraordinary general meetings must be held upon the
requisition of nine shareholders or more, having in the
whole, at least twenty-one shares {m). The deed of part-
nership must contain provisions for the yearly audit of
the accoimts by two or more auditors chosen at a general
meeting of the shareholders, and not being directors (di).
The deed of partnership must contain provisions for the
(/i) 7 & 8 Vict. c. 113, s. 22.
(i) Id. s. 4.
(k) Id. 8. 22. .
(/) Id. s. 43.
{m) Id. s. 4.
y02 JOINT STOCK BANKS.
publication once at least in every month of the assets and
liabilities of the company, and for the yearly communica-
tion to every shareholder of the auditor's report, of a
balance sheet, and profit and loss account {in).
These are the several regulations prescribed by the
Act of 1844, and apply still to banks fonned imder its
provisions, except so far as they may be affected by regis-
tration, as afterwards mentioned.
3 & 4 Will. Joint Stock Banks n-ithin Sixty-five Miles of London. —
IV. c. 98. ^,j^^ o ^^ 4 -^Yiii, iY_ e. 98, s. 3, as already shown («),
enabled banking companies of more than six members to
carry on business within sixty-five miles from London,
but they were not empowered by any Act of Parliament
to sue or to be sued by a public ofiicer. The 7 & 8 Vict.
c. 113, therefore, conferred upon these companies, which
were established on the Gth of May, 1844, tlie powers and
privileges of suing and being sued in the name of a public
officer, and enacted that judgments, decrees and orders
might be enforced, as under the 7 Geo. IV. c. 40, with
respect to banking companies carrying on business beyond
sixty-five miles from London, provided they made out and
delivered the several accounts required by tliat act {o) .
The act, however, was repealed in 1857 {])), but the last-
mentioned x^ro^isions as to banking companies existing
within sixty-five miles of London, suing and being sued,
and making the returns, were re-enacted in 1862 (q).
20 & 21 Vict. Registration of Joint Stock Banks.— In 1857, the com-
''• ^^- panics formed under the 7 & 8 Vict. c. 113, were required
to be registered under the Joint Stock Banking Companies
Act of that year (r) ; and legal proceedings commenced
(»i) 7 & 8 Vict. c. 113, s. 4.
(«) Ante, p. 330.
(o) 7 & 8 Vict. c. 113, 8. 47.
(p) 20 & 21 Vict. c. 49, s. 12.
{(/) 25 & 20 Vict. c. 89, s. 205, Third Schedule, Tart 2.
(r) 20 & 21 Vict. c. 49.
REGISTRATION. 393
by or against a company when registered, or public officer,
might be continued as if registration had not taken place,
but execution was not to be issued against the effects of
individual shareholders or members upon any judgment,
decree or order obtained against the company (s) ; for, in
the event of the property and effects of the company being
insufficient to satisfy sucli judgment, order or decree, an
order might be obtained for winding-up the company (s).
The jDrocedm-e prescribed by the 7 & 8 Vict. c. 113, s. 9,
for obtaining execution against individual members was
practically abolished, and the right of contribution from
all the shareholders by proceedings against the company
was established and enforceable.
If these companies neglected to register before the 1st of
January, 1858, they were incapacitated from suing either
at law or in equity, though they might be sued, nor could
any dividend be payable to their shareholders, and the
dii'ectors or managers incmTcd a penalty of 5/. for every
day the registration was delayed {t) . The omission to
register did not however render the company illegal {t).
The act also enabled banking companies, which were not
formed mider the 7 & 8 Yict. c. 113, consisting of seven
or more persons, having a capital of fixed amount and
divided into shares also of fixed amount, and legally
carrying on the business of banking at the time of the
passing of the act, to register themselves, having first
obtained the assent of a majority of their shareholders (i/).
When registered, the provisions contained in any act of
parliament, letters patent, or deed of settlement, consti-
tuting or regulating these companies when inconsistent
with the Joint Stock Companies Acts of 1856 and 1857,
or with the act itself, were no longer to apply to them («).
Eegistration was not to take away or affect any powers
previously enjoyed by the companies of banking, issuing
(.■;) 20 & 21 Vict, c, 49, 8. 10.
{t) Id. 8. 5.
(«) Id. 8. 6.
394 JOINT STOCK BANKS.
notes payable on demand, or of doing any other tiling {u).
A banking company constituted imder the 7 Greo. IV.
c. 46, became insolvent, and stopped payment, but no
resolution was passed for dissolving it. It was registered
under the 20 & 21 Vict. c. 49, in pursuance of a resolu-
tion come to after the stoppage of the bank. Lord Justice
Turner held, that the registration was valid, for that, in
order to bring a company wthin the 6th section of that
statute, it was not necessary that it should continue to
carry on business up to the time of its registration (ip).
Upon these companies being registered, the articles of
Table B., prescribed by the Act of 1856, relating to shares,
theu' transmission and forfeitm-e, numbered one to nine-
teen, were, subject to the power of alteration conferred
by the Acts of 1856 and of 1857, to be deemed the regula-
tions of these companies (//) . The act also repealed the
7 & 8 Vict. c. 113, as to banking companies to be formed
after the 17th of August, 1857 (s).
With respect to the formation of new companies it
provided, that seven or more persons, associated for the
pm-pose of banking, might register themselves other than
as a limited company, subject to the condition that the
shares into which the capital of the company was divided
were not to be of a less amount than 100/. each; but that
more than ten persons after the 17th of August, 1857,
should not form themselves into a partnership for the
purpose of banking, or, if so formed, carry on the business
{u) 20 & 21 Vict. c. 49, s. 6.
[x) In re KorthumherlaHd and Durham Bintrkl Banking Companij, 2 Dc
G. & J. 357 ; 27 L. J., Chanc. 356. In au actiou by a banking- companj-,
registered under the 20 & 21 Vict. c. 49, s. G, the Court allowed the de-
fendant to plead a traverse of the registration of the company ; that the
company was carrying on business until registration ; that before regis-
tration the company had stopped payment, and ceased to carry on busi-
ness, and uul tiel corporation ; but disallowed a plea, that before regis-
tration the company bad lost its reserved fund, and more than onc-hfth
of its paid-up capital, whereby the bank had ceased to carry on legally
its business. Liverpool UuroiK/Ii Bank v. McUor, 3 II. & N. 551.
(y) 20 & 21 Vict. c. 49, s. 12.
\z) Id. 8. 12. The section repealed the 9 & 10 Vict. c. 75, as to Irish
and Scotch banking companies, and sect. 4 reqmrcd them to register
imder the act.
UNDER THE COMPANIES ACT, 1862.
of banking unless registered as a company under that
act (a).
Limited Banks. — Before treating of limited liability
banking companies, wbicb, on account of the novelty of
the princij)les under which they may be established, de-
mand a separate consideration, the legislation affecting
the companies mentioned in this Chapter remains to be
noticed.
Joint Stock Banks under the Comjmm'es Act, 1862. —
All banking companies which were, or were required to
be, registered under the 20 & 21 Vict. c. 49, except those
having the liability of their members limited by act of
parliament or by letters patent, are to register imder this
act (b) . Until registration, they cannot sue, although
they may be sued, nor can they pay dividends, and the
directors or managers are liable to a penalty of not less
than o/. per diem [c).
Upon complying with the directions of this act, as to
registration, they are entitled to become an incorporated
company {d) , and a certificate of incoi-^^oration to which
the company is entitled, will be conclusive evidence that
the requisitions of the act in respect of registration have
been complied with {d). The provisions contained in any
act of parliament, deed of settlement, or letters patent,
constituting or regulating these companies, are still to
apply to them (e) .
The Companies Act of 1862 repeals the 20 & 21 Vict.
c. 49, but re-enacts the provision of the 12th section of
(«) 20 & 21 Vict. c. 49, s. 13.
{b) 25 & 26 Vict. c. 89, ss. ITo, 176, 178, 179.
[c) Id. ss. 209, 210.
(d) Id. ss. 191, 192. The certificate of registration is conclusive evi-
dence that all the requirements of the act relative to registration have
heen complied with, and the incorporation of the company cannot after
the grant of the certificate be impugned, even on the ground of miscon-
duct of the registrar in reference to the registration. In re Barncd^s
Banldnq Company, 36 L. J., Chanc. 757.
{e) id. s. 196.
396 . JOINT STOCK BANKS.
that act, legalizing private banking firms of not more tlian
ten members. Private banks may consequently consist of
ten partners (/), or of any less number.
With respect to the foi-mation of new companies, it ex-
pressly enacts, that no company, association or partnership
consisting of more than ten persons shall be formed after
the 2nd of November, 1862, for banking purposes, unless
it is registered as a company under the act, or is formed
in pursuance of some other act of parliament or of letters
patent [g) . It provides, however, that seven or more per-
sons may, by subscribing their names to a memorandum
of association and complying with the requisitions of the
act in other respects as to registration, form an incorporated
banking company with or without limited liability (//).
Since the facilities given to form companies upon the prin-
ciple of hmited liability, and the popularity which such
companies have nov/ attained, it is not likely that banking
companies will henceforth be established with unlimited
liability. It is therefore deemed unnecessary to enter into
the law applicable to their formation.
We now proceed to consider the subject of limited
banking companies.
(/) 2o & 26 Vict. c. 89, s. 205, Thkd Schedule, Tart 2.
iff) Id. s. 4.
(/() Id. a. 6.
( 397 )
CHAPTER XLIV.
LIMITED BANKTXG COMPANIES.
Prior to the year 1858, banking companies could not be
legally formed with limited liability except by special acts
of parliament {a) , or by royal charters, or by letters patent,
imder the 7 Will. IV. & 1 Yict. c. 73 {b). In 1858, the
21 & 22 Vict. c. 91 repealed so much of 20 & 21 Vict. c. 49,
as prohibited banking companies from being registered
■with limited liability, and first authorized the formation
and registration of banking companies of seven or more
persons with limited liability.
Converting Unlunited into Limited Liability under 21 l^ 22 21 & 22 Vict.
Viet. c. 91. — The latter act also enabled existing unlimited
banking companies to register themselves as limited bank-
ing companies (c) . But banking companies claiming to
issue notes in the United Kingdom were not entitled to
limited liability in respect of such issue, their liability re-
maining unlimited (c) . Previously to a company obtaining
a certificate of registration with limited liability under this
act, it was necessary to give notice to its customers, or
otherwise the certificate of registration, as to them, was
wholly inoperative and unavailable. Before commencing
business, and also on the 1st of February and the 1st
of August in each year of its operations, every banking
company, registering as a limited banking company, was
bound to publish, in a prescribed form, a statement of its
(ff) The Bank of England is an instance. The liability of the stock-
holders is limited to the amount of theii- subscriptions or shares: see
5 & 6 WiU. & M. 0. 20, s. 26.
(*) Sect. 4 enables the crown to restrict by the letters-patent or chai-ters
the liability of the members to the amount of their .shares.
(c) 20 & 21 Vict. 0. 49.
LIMITED BANKING COMPANIES.
liabilities fiud assets {h). In 18G2, tlie 21 & 22 Yict. c. 91
was repealed by tbe Companies Act of that year (c) ; but
its provisions have been substantially re-enacted by the
latter act.
Convciiing into Limited Liahility under Companies Act,
18G2. — By sect. 179, banking companies, consisting of
seven or more members, whose liability is unlimited, may
become limited banking companies by registering under
the provisions of the act. Before registering as limited
banking companies they must fii'st obtain the assent of a
majority of the members present or represented by proxy
at a general meeting summoned for the purpose {d).
The following documents must also be delivered to the
Eegistrar of Joint Stock Companies (e), viz. : —
1. A list showing the names, addresses and occupations
of all persons who, on a day named in the list, which must
not be more than six clear days before registration, were
members of the company, v/ith the addition of the shares
held by each member, distinguishing each share by its
specific number.
2. A copy of the deed of settlement, royal charter, letters
patent or other instrument constituting or regulating the
company.
3. This list and copy must be accompanied by a state-
ment of the following particulars, viz. : The nominal
capital of the company, and the number of shares into
which it is divided ; the nimiber of shares taken, and the
amount paid on each share ; and the name of the company,
(b) 20 & 21 Vict. c. 49.
\c) 25 & 26 Vict. c. 89, s. 205, Third Schedule, First Part. By the
Bame act it is made lawful for any number of persons, not exceeding ten,
to carry on the business of banking in the same manner and ujion the
same condition as any company of not more than six persons could before
the act (Schcd. 3, Part 2).
{d) Id. 8. 179. Eegistration of existing limited banking companies
under the act, is made compulsory ; and until registration they are liable
to certain pecuniary penalties and subject to disabilities (sects. 209, 210).
{,) Id. s. 18:5.
LIMITED LIABILITY UNDER COMPANIES ACT, 1862. 399
with the addition of the word '" limited," Jis the last word
thereof.
Where the whole or a portion of the capital has been
converted into stock, the company must, instead of a state-
ment of its shares, deliver a statement to the registrar of
the amount of its stock, and of the names of the persons
who were holders of stock, on some day to be named in
the statement, not, however, being more than six clear
days before registration (./). The list and particulars must
be verified by a statutory declaration of the directors of
the company, or of two of them {g) .
A banking company may, for the purpose of obtaining
registration with limited liability, change its name by the
addition of the word " limited " {h).
A banking company, registering as a limited banking
company, must, at least thirty days previously to obtain-
ing a cei-tificate of registration with limited liability, give
notice that it is intended so to register, to every person
and partnership firm having a banking accoimt with the
company, and the notice must be given either by delivering
the same to such person or firm or leaving the same or
putting the same into the post, addressed to him or them
at such address as shall have been last communicated or
otherwise become known as his or their address to or by
the company (?).
In case the company omits to give this notice, the act
provides, " that as between the company and the person or
persons only who are for the time being interested in the
account in respect of which the notice ought to have been
given, and so far as respects such account and all varia-
tions thereof down to the time at which the notice is given,
(/) 25 & 26 Vict. c. 89, a. 185.
{g) Id. s. 186. By tlie Stamp Act, 1870, a statutory declaration made
under the provisions of the 5 & 6 Will. 4, c. 62, requires to be stamped
with a duty of 2s. 6d.
{h) Id. s. 190.
{i) Id. s. 188.
400 LIMITED BANKING COMPANIES.
but not further or otlierwlse, the certificate of registration
with limited liability" is to be inoperative.
Banking companies issuing notes in the United King-
dom are not entitled to limited liability in respect of such
issue {I). These companies continue subject to unlimited
liability in this respect, and, if necessary, the act provides,
that the assets shall be marshalled for the benefit of the
general creditors and the members liable for the whole
amount of the issue, in addition to the sum for which they
would be liable as members of a limited company (/).
Upon these provisions being complied vnth., the company
Tvill become an incorporated limited bankmg company,
having a common seal and a perpetual succession, with
power to hold lands (m) . In the case of a banking com-
pany in Scotland, it becomes, by virtue of the registration,
a bank incorporated, constituted or established by or imder
act of parliament {})i).
The cei-tificato of incorporation, when obtained, will be
conclusive evidence of the company having complied with
the provisions of the act in respect of registration, and of
being authorized to be registered as a limited company.
The date of incorporation mentioned in the certificate will
be considered as the date of its incorporation (;?).
IJff'ecf. of Rccjkti'cition loidcr Ad of 1862. — On regis-
tration, the provisions in the act of parliament, deed of
settlement, letters patent, or other instrument constituting
or regulating the company, will apply to the limited com-
pany, as well as the provisions of the Companies Act of
18G2, and to the members, contributorics and creditors,
as if the company had been originally formed under that
act (o).
{/) 25 & 26 Vict. c. 89, s. 182.
{m) Id. fl. 191. The section also prescribes the fees payable on regis-
tratiou of uiiliiaitcd banking companies. See Table of Fees, post, 400, n.
{») Id. s. 192. But see sect. 188.
(.>) Id. 8. 19G.
LIMITED LIABILITY UNDER COMPANIES ACT, 1879. 401
All the property of the compaii}^ its interests and rights
existing at the date of its registration, pass to and vest in
the incorporated company (p). Registration is not to affect
or prejudice the liabiKty of the company to have enforced
against it, or its right to enforce, debts, obligations or con-
tracts entered into by, to, with or on behalf of such com-
pany previously to such registration (q) . Actions and suits
and other legal proceedings pendiiig against the company,
or its members or the public officer, at the time of its
registration, may be continued. Execution, however, is
not to issue against the effects of an individual member
upon any judgment, decree or order ; but, in the event of
the property and effects of the company being insufficient
to satisfy these liabilities, an order may be obtained for
winding up the company (r) . The mode of winding up,
and the liabilities of its members, will form the subject of
a separate Chapter.
Coinrrfiiig info Limited Liabilitij under Comjxinies Act, Act to be
1879 (.s). — This act, so far as is consistent with the tenor ^th 2T& 2G
thereof, is construed as one with the Companies Acts, 18G2, Vict. c. 89,
' 30 & 31 Vict.
1867, and 1877 (0- c i3i, aud
By sect. 4 it is enacted that, subject to what is men- ^°<,'^'*^ ^^^'^*-
tioned in the act, any company registered before or after Registration
its passing as an unlimited company may register under ^^«^^ °* '=*^™"
the Companies Acts, 1862 to 1879, as a limited company, 25 & 26 Vict.
c. 89, 30 & 31
[p) 25 & 26 Vict. c. 89, s. 193.
\q) Id. s. 194. This section does not apply to the case of a pui-e con-
trlhuton/. And if a company originally unlimited, but subsequently
limited," is wound up, member.s of the unlimited company cannot be made
liable as contributories beyond the limit of their shares for debts con-
tracted before the company became limited. Aliter, under the Act of
1856, see sect. 116. Sheffield mid HaUamshire, ^r. Societij, Fountahi's
case, 34 L. J., Ch. 593 ; Garneit Mining Company v. Sutton, 34 L. J., Q. B.
118. Quecre, whether they could not be made liable on the obligation
attaching to the partnership at common law. Lanyon v. Smith, 2 N. E,.
118. See Buckley, 341.
(r) Id. s. 195. See Lmujon v. Smith, ante.
{s) 42 & 43 Vict. c. 7.
(0 Sect. 3. The act does not apply to the Bank or England (sect. 2).
G. I> D
402 LIMITED BANKING COMPANIES.
Vict. c. 131, or any company already registered as a limited company
c^26 ^2 &^43 ''^^y I'e-i'egister under the provisions of the act.
Vict. c. 76. The registration of an unlimited company as a lunited
company in pursuance of this act is not to affect or preju-
dice any debts, liabilities, obligations, or contracts inciuTed
or entered into by, to, Avith, or on behalf of such company
prior to registration, and such debts, liabilities, contracts,
and obligations may be enforced in manner provided by
25 & 26 Vict. Pai-t VII. of the Companies Act, 1862, in the case of a
^' ' company registering in pm'suance of that part {ti).
Reserve By sect. 5, an unlimited company may, by the resolution
company* passed by the members when assenting to registration as a
how provided, limited company under the Companies Acts, 1862 to 1879,
25 "^26 Vict. Qj^^ fQj. ^]^Q purpose of such registration or otherwise,
c. o9, 30&31 . , .,,.
Vict. c. 131, increase the nommal amoimt of its capital by mcreasmg
c^'T6 W&°43 ^^6 nominal amount of each of its shares.
Vict. c. 76. Pro\dded always, that no part of such increased capital
shall be capable of being called up, except in the event of
and for the purposes of the company being woimd up.
And, in cases where no such increase of nominal capital
may be resolved upon, an unlimited company may, by
such resolution as aforesaid, provide that a portion of its
uncalled capital shall not be capable of being called up,
except in the event of and for tlie pm-poses of the company
being wound up.
A limited company may by a special resolution declare
tliat any portion of its capital which lias not been ah'eady
called up shall not be capable of being called up, except in
the event of and for the purpose of the company being
wound up ; and thereupon such portion of capital shall not
be capable of being called up, except in the event of and
for the purposes of the company being wound up (x).
25 & 26 Vict, By sect. 6, section one hundred and eighty-two of the
re^cal^d^and Companies Act, 1862, is repealed, and in its place it is
liability of enacted as follows : — A bank of issue registered as a
(«) See ante, p. 101.
(.r) Sect. 5.
LIMITED LIABILITY ITXDER COMPANIES ACT, 1879. 403
limited company, either before or after the passing of this bank of issue
act, shall not be entitled to limited liability in respect of ^,p™t*o^ ^^
its notes ; and the members thereof shall continue liable in i^otes.
resjDect of its notes in the same manner as if it had been
registered as an unlimited company ; but in case the
general assets of the company are, in the event of the
company being wound up, insufficient to satisfy the claims
of both the note-holders and the general creditors, then
the members, after satisfjing the remaining demands of
the note-holders, shall be liable to contribute towards pay-
ment of the debts of the general creditors a sum equal to
the amoimt received by the note-holders out of the general
assets of the company.
For the purposes of this section the expression "the
general assets of the company" means the funds available
for payment of the general creditor as well as the note-
holder.
It shall be lawfid for any bank of issue registered as a
limited company to make a statement on its notes to the
effect that the limited liability does not extend to its notes,
and that the members of the company continue liable in
respect of its notes in the same manner as if it had been
registered as an unlimited company {//).
(y) The following pro^-isions are inserted respecting tlie auditing of
accounts of banking companies. By sect. 7 (1), Once at the least in
every year the accounts of eveiy banking company registered after the
passing of the act as a limited company shall be examined by an auditor
or auditors, who shall be elected annually by the company in general
meeting.
(2.) A director or officer of the company shall not be capable of being
elected auditor of siich company.
(3.) An auditor on quitting office shall be re-eligible.
(4.) If any casual vacancy occurs in the office of any auditor the sur-
viving auditor or auditors (if any) may act, but if there is no siu'viving
auditor, the directors shall forthwith call an extraordinary general meet-
ing for the purpose of supplying the vacancy or vacancies in the auditor-
ship.
(5.) Every auditor shall have a list delivered to him of all books kept
by the company, and shall at all reasonable times have access to the books
and accounts of the company ; and any auditor may, in relation to such
books and accounts, examine the directors or any other officer of the
company : Provided that if a banking company has branch banks beyond
the limits of Eiu-ope, it shall be sufficient if the auditor is allowed access
to such copies of aiul extracts from the books and accounts of any such
ud2
404
LIMITED BANKING COMPANIES.
Application
of 25 & 26
Vict. c. 89,
30 & 31 Vict.
c. 131, and
40 & 41 Vict.
c. 26.
25 & 26 Vict.
0. 89, 30 & 31
Vict. c. 131,
40 &41 Vict.
c. 26, and
42 & 43 Vict,
c. 76.
Privileges of
act available
notwithstand-
ing constitu-
tion of com-
pany.
By sect. 9, on the registration, in pursuance of tlie act,
of a company wliicli has been abeady registered, the registrar
shall make provision for closing the former registration of
the company, and may dispense with the delivery to him of
copies of any documents with copies of ^^'hich he was fur-
nished on the occasion of the original registration of the
company ; but, save as aforesaid, the registration of such a
company shall take place in the same manner and have the
same effect as if it were the first registration of that com-
pany under the Companies Acts, 1862 to 1879, and as if
the provisions of the acts under which the company was
previously registered and regulated had been contained in
different acts of parliament from those under which the
company is registered as a limited company.
By sect. 10, a company authorized to register under the
act may register thereunder and avail itself of the privileges
conferred by this act, notwithstanding any provisions con-
tained in any act of parliament, royal charter, deed of
settlement, contract of copartnery, cost book regulations,
letters patent, or other instrmnent constituting or regu-
lating the company.
Limited Banks under the Companiefi Act of 1862. — As
already stated, banking firms consisting of seven or more
persons may register under the act with limited liability.
branch as may have been transmitted to the he;id office of the banking
company in the United Kingdom.
(0.) The auditor or auditors shall make a report to the members on the
accoimts examined by him or them, and on every balance-sheet laid
before the company in general meeting during his or their tenure of
office; and in every such repoi't shall state whether, in his or their
opinion, the balance-sheet referred to in the report is a full and fair
balance-sheet properly drawn up, so as to exhibit a true and correct view
of the state of the company's affairs, as shown by the books of the com-
pany, and such report shall be read before the company in general
meeting.
(7.) The rcmimcration of the auditor or auditors shall be fixed by the
general meeting ajipointing such auditor or auditors, and shall be paid by
the company.
And by sect. 8 every balance-sheet submitted to the annual or other
meeting of the members of every banking company registered after the
passing of the act as a limited comjiany shall be signed by the auditor or
auditors, and by the secretary or manager (if any), and by tlie directors
of tlio romjiaTiy, "r tlirec of such directors at tlie least.
UNDER THE COMPANIES ACT, 1862. 405
Since the 2iid of November, 1862, when the Companies
Act of that year came into operation, limited banking
companies can only be legally formed and registered under
its provisions. It is the act at present in force on the
subject {>/).
When, tlierefore, it is proposed to establish a banking
company in England, Ireland or Scotland, on the principle
of having the liability of its members limited to the
amount of theu* shares, or, in the words of the statute, a
eomiiany limited by shares (z), seven persons at the least
must subscribe a memorandum of association {a), containing
the following particulars : —
1. The name of the company, with the addition of the
word " limited " at the end of the name.
2. The part of the United Kingdom, whether England,
Scotland or Ireland, in which the registered office of the
company is situate.
3. The objects for which the company is established.
4. A declaration of the liability of the members being
limited.
5. The amount of its capital divided into shares of a
fixed amount.
Each subscriber cannot take less than one share, and
must write his name opposite to tlie number of shares
which he takes {b).
The memorandum must be stamped as a deed, and
signed by each subscriber, in the presence of a witness,
who must attest his execution {b).
A company may modify or alter the memorandum, if
authorized by its regidations or by special resolution, so as
to increase the capital by the issue of new shares, or to
consolidate and divide the capital into shares of larger
(«/) The Companies Act, 1879, provides for the re-registration of com-
panies formed and registered under this act. See ante, p. 401.
(z) 25 & 26 Vict. c. 89, s. 8.
{a) Id. s. 6. See a form of a memorandum of association of a limited
hank in Shelford's Law of Joint Stock Companies, 1st edit. p. 481.
{b) Id. 8S. 8, 12.
40G LIMITED BANKING COMrANIES.
amount than tlie existing shares, or to convert the paid-
up shares into stock {c). With these exceptions, and of
changing the name, as mentioned hereafter, the act pro-
vides, that no other alterations shall be made by any com-
pany in the conditions contained in the memorandum (c).
In the case of a limited banking company, the memo-
randum is usually and necessarily accompanied with articles
of association prescribing and defining the constitution,
business and capital of the company, the amount, allot-
ment, transfer and forfeitui-e of shares, the calls, the meet-
ings of members, the number of their votes, the appoint-
ment, qualification, remuneration, powers and duties of
du-eetors and of officers, auditing the accounts, and such
other regulations as the subscribers of the memorandum
may deem expedient (c/). The company may adopt,
modify or exclude all or any of the provisions of Table A.
given by the Companies Act{d). These provisions are
usually embodied in the articles. The articles must be
separately paragraphed and numbered arithmetically {d),
printed and stamped as a deed, and signed by each sub-
scriber in the presence of a witness (e) . The memoran-
dum and articles must be delivered to the registrar for
registration (./") . Upon registration they bind the company
{(■) 25 & 20 Vict. c. 89, s. 12. On this section, sec the notes thereto in
Buckley, p. 10 ; and Irvine v. Unio)/ Bniik of Anstralla, 2 App. Ca.
3GG ; 46 L. J., P. C. 87 ; Ashbim/ v. Eiche, L. R., 7 H. L. 0-33 ; Ander-
son'' s case, 7 Ch. D. 75; MaxircWs case, L. E., 20 Eq. 585; M'Kewan's
• rase, 6 Ch. D. 447. By the Compiinics Act, 1867, s. 9, a company limited
by shares may, by special resolution, so far modify the conditions con-
tained in its memorandum of association, if authorized so to do by its
regailations as originally framed, or as altered by special resohition, as to
reduce its capital ; but an order of the Court is necessary for its con-
firmation.
(fl) Id. s. 14. See a form of articles of association of a limited banking
company in Shelford's Law of Joint Stock Companies, page 483, 1st edit. ;
and Vroskcy v. Bank of Wales (Lunilcd), 4 Gift'. 314; and an epitome of
a deed of settlement of an uiilinutcd banking company in Wordsworth's
Mining, Banking and Insurance Companies, Appendix of Forms, 202,
Gth edition. Sec a form in the Appendix to this work.
(e) Id. s. 16.
(/) Id. ss. 10, 17. Sect. 17 prescribes, in Table B., the fees paj'ablo
on registration of the memorandum and articles, ^-iz. : —
For registration of a company whose nominal capital docs £ s. d.
not exceed 2,000/., a fee of 2
UNDER THE COMPANIES ACT, 1862. 407
and its members as if eacli member bad executed tbese
instruments as deeds {g) . The registrar thereupon grants
a certificate of the incorporation of the company by the
name contained in the memorandum of association, as a
banking company, limited, whose members, in the event
of its being wound up, will be liable only to the anioimts
remaining unpaid upon their respective shares. The cer-
tificate is conclusive as to the fact of the company having
complied vath. the requii'ements of the act with regard to
registration {/i).
The company may, by passing special resolutions in
general meetings, from time to time, add to or alter the
regulations contained in its articles, and these regulations
are to be deemed of the same validity as if they had been
originally in the articles of association. These regulations
may be altered or modified by subsequent special reso-
lutions (i).
For registration of a company whose nominal capital ex- £ s. d.
ceeAs 2,000?., the fee of 2/., with the following additional
fees, regulated according to the amount of nominal
capital ; (that is to say,)
For every 1,000/. of nominal capital, or part of 1,000/.,
after the first 2,000, up to 5,000/ 1
For every 1,000/. of nominal capital, or part of 1,000/.,
after the fii-st 5,000/., up to 100,000/ 5
For every 1,000/. of nominal capital, or part of 1,000/.,
after the first 100,000/ 1
For registration of any increase of capital made after the
first registration of the company, the same fees per
1,000/., or part of 1,000/., as would have been payable if
such increased capital had formed part of the original
capital at the time of registration.
Provided that no comjaany shall be liable to pay in re-
spect of nominal cajiital on registration, or afterwards,
any greater amount of fees than 50/., taking into account
in the case of fees payable on an increase of capital after
registration the fees paid on registration.
For registration of any existing unhmited banking com-
pany, the same fee as is charged for registering a new
company.
For registering any document reqiiired or authorized to be
registered, other than the memorandum of association . . 5
For making a record of any fact authoidzed or required to
be recorded by the registrar, a fee of 5
[fj) 25 & 26 Vict. c. 89, s. 16.
[h) Id. s. 18.
((') Id. s. 50; Ashhurtj Compcavj v. Itiche, L. K., 7 H. L. 653; 44
408 LIMITED BANKING COMPANIES.
It would seem a power to borrow may be given by
special resolution (/.•), but it is otherwise as to issuing
preference shares {/).
A copy of the memorandum, Avith the articles of asso-
ciation, must be forwarded to every member at his request,
on the payment of Is., or a less sum, if prescribed by the
regulations of the company, for the copy. If the company
neglects to forv/ard a copy, it will incur a penalty not ex-
ceeding one pound (in).
Name. Xamc. — A banking company must not assume or adopt
the name, or what is practically the name, of an existing
company, or be registered in a name identical with the
name of an existing company. If by inadv'erteuce a com-
pany is so registered, it may, with the sanction of the
registrar, change its name, and the registrar is to enter the
new name on the register, and issue a certificate accord-
ingly («). Should a banking company wish to change its
name after incorporation, provision is made for enabling it
to do so by passing a special resolution, and obtaining the
approval of the Board of Trade (o).
Special provisions are made for the widest possible pub-
lication of the name. The company must paint or affix,
and keep painted or affixed, its name on the outside of
every office or place in which it carries on business, in a
conspicuous position, in letters easily legible, and must
have its name engraven in legible characters on its seal,
and its name mentioned in legible characters in all notices,
advertisements and official publications, and in all bills of
L. J., Ex. 185; A/idcn:o/i''s case, 7 Ch. D. 75, 78; Teasdalc^s case, L. R.,
9 Ch. App. 51 ; Hope v. International Society, 4 Ch. D. 327, and notes to
sect, in Buckley, p. HO; Lronfield SUkstone Coal Companii, 17 Ch. D. 76.
(/•) Ihjron V. Metropolitan Saloon Omnibus Companii, 3 J)e G. & J. 123.
(/) Jlutton V. Hearhoronqh Hotel Company, 13 W. 11. 1059.
{»0 25 & 20 Vict. c. 89, s. 19.
(;/) Merchant Bunking Company of London v. Merchant Joint Stock Bank,
W. N., 1878, ICO; Lawson v. Bank of London, 18 C. B. 81; Hendricks v.
Montague, 17 Ch. D. G38.
(o) 25 «fc 2G Vict. c. 89, s. 13. i5ee Shackleford ^- Company v. Danger-
field, L. R., 3 C. P. 407.
CAPITAL. 409
exchange, promissory notes, indorsements, cheques and
orders for money, purporting to be signed by or on behalf
of the company, and in all its receipts and letters of
credit {p).
A penalty not exceeding 5/. will be incurred by a com-
pany for non-publication of these particulars in the mode
prescribed (q) .
A director, manager or officer, or any person on the behalf
of the company, using any but its engraved seal, or issuing
any notice, advertisement, or official publication, or signing,
on behalf of the company, any bill of exchange, promissory
note, indorsement, cheque, order for money or letter of
credit, in which the name of the company is not mentioned,
will incur a penalty of 50/. He will also be personally
liable to the holder of such bill, note, cheque or order for
the full amount, unless duly paid by the company (r) .
Registered Office. — The company must also have a
registered office of business. A company not having one
will incur a penalty not exceeding 5/. for every day busi-
ness is carried on (s). Notice of the situation of the
registered office, as well as of an}' change, is to be given
to the registrar, and recorded by him. Until such notice,
the company will not have complied with the act (/).
Capital. — The shares of the members are personal estate,
transferable according to the regulations of the company,
and distinguishable by appropriate numbers {u) . But shares
of deceased members may be transferred by their personal
representatives, although not themselves members (.r).
Notice of an increase of the registered capital of the com-
{p) 25 & 26 Vict. c. 89, s. 41.
[q) Id. s. 42.
[r) Ibid.
{s) Id. s. 39. See British Fon-ign Gas Compauy, 13 W. R. G49 ; Fur-
tune Mining Company, L. R., 10 Eij. 390 ; 40 L. J., Ch. 43.
(0 Id. s. 40.
{ii) Id. s. 22. See notes thereto in Buckley, p. 18; TJ'cston's case^
L. R., 6 Eq. 238; Gilbert's case, L. R., o Gh. "559 ; 39 L. J., Ch. 837;
Moffat V. Farqukar, 7 Ch. D. 591 ; 47 L. J., Ch. 355.
{x) Id. s. 34. See London and Provincial Telegraph Compamj, L. R., 9
Eq. 653; 39 L. J., Ch. 419.
410 LIMITED BANKING COMPANIES.
pany, whether the shares are converted into stock or not,
must be given to the registrar within fifteen days after the
resolution authorizing the increase {y). The registrar is
to record the amount of the increase (//).
So a company that has consolidated or divided its capital
into shares of larger amount than its existing shares, or
converted any portion of its capital into stock, is required
to give notice thereof to the registrar (s). A company
which neglects to give notice of increasing its capital
within the time mentioned, and a director or a manager
authorizing the same, will incur a penalty not exceeding
bl. for every day of the default {a). Notice of trusts, ex-
pressed, implied or constructive, cannot be entered on the
register, or be receivable by the registrar {h).
A certificate under the seal of the company of the shares
or stock held by a member will be prima facie evidence of
his title (c).
Members. Mcmhcn. — The act defines the members to be subscribers
of the memorandum of association, and every other person,
who has agreed to become a member, and whose name is
entered on the register required to be kept by the com-
pany icl). The articles of association generally prescribe
that a -wTitten application for shares, followed by an allot-
ment, shall be deemed an acceptance of the shares. An
aecei^tance in this form will be binding, and a sufficient
authority for placing the name of an allottee on the re-
gister. A person, who is induced to sign the articles upon
a promise that is not fulfilled, or to take shares by decep-
tion, is still a shareholder, and his remedy vaW be against
.those who deceived him, and not against the company (e).
[y) 25 & 2G Vict. c. 89, s. 34.
[z) Id. 8. 28.
(a) Id. 8. 34.
\b) Id. 8. 30. See notes to section in Bucklej^, p. 72.
(f) Id. s. 31.
. {d) Id. s. 23 ; Buckley, p. 35.
(c) Fdqatc's case, 11 L. T., N. S. 613; 2 Do G., J. & S. 456; ChalUs's
case, L. E., 6 Ch. 266; 40 L. J., Ch. 431 ; lUshoj/s casr, L. K., 7 Ch.
296 ; 8ee, also, Oakes v. Tioqi'.aitd, L. K., 2 II. L. 325 ; and Biaqcss^s case,
loCh. D. 513.
ANNUAL LIST OF MEMBERS. 411
The liability of members as contributories will be sepa-
rately considered.
Register of Members. — The register required to be kept Register,
by the company must contain the following particulars (/),
viz. : —
(1.) The names and addresses and the occupations, if
any, of the members of the company ; a state-
ment of the shares held by each member, dis-
tinguishing each share by its number ; and the
amount paid or agreed to be considered as paid
on the shares of each member :
(2.) The date at which the name of any person was
entered in the register as a member :
(3.) The date at which any person ceased to be a
member.
A company, director or manager acting in contravention
of these provisions mil incm* a penalty not exceeding bl.
for every day of non-compliance [g).
When any portion of the shares of the company has
been conveiied into stock, the register must show the
amount of stock held by each member instead of shares {g) .
The register will be prima facie evidence of its con-
tents [h).
Annual List of Members. — An annual list of all persons,
who are members on the fourteenth day succeeding that
on which the first of the ordinary general meetings of the
company is held, must be made out, containing their
names, addresses and occupations, and the number of
shares held by each, and the follo\^'iug summary of par-
ticulars («), viz. : —
(1.) The amount of the capital of the company, and the
number of shares into which it is divided :
(/) 25 & 26 Vict. c. 89, s. 25.
[g) Id. s. 29.
(A) Id. s. 37.
(i) Id. 8. 26. See Sirmz/er^s case, L. E,., 4 Ch. 475 ; Kaiice^s case, L. R.,
6 Ch. 104 ; 40 L. J., Ch. 277 ; Si/fce's case, L. R., 13 Eq. 255.
412 LIMITED BANKING COMPANIES.
(2.) The number of sliares taken from the commence-
ment of the company up to the date of the
summary :
(3.) The amount of calls made on each share :
(4.) The total amoimt of calls received :
(5.) The total amount of calls paid :
(6.) The total amount of shares forfeited :
(7.) The names, addi-esses and occupations of the per-
sons who have ceased to he members smce the
last list was made, and the number of shares held
by each of them.
This list and summary must be in a separate part of the
register, and completed within seven days after the day
mentioned for its being made out ; and a copy forthwith
forwarded to the registrar (/.•) . A company neglecting to
forward the list or summary will incur a penalty not
exceeding 5/. for every day, and a director or manager
permitting the same a similar penalty (/) .
Where any of the shares of the company have been
converted into stock, the list must show the amoimt of
stock held by each member instead of the amount of his
shares {iii).
Beef if// in (J Reejifitcr. — In case of any errors or misstate-
ments being introduced into the register, provision is made
for their correction. If the name of any person is entered
in or omitted from the register (//), or default is made, or
unnecessary delay takes place in entering the fact of any
person having ceased to be a member, the person or
member aggrieved, or any other member, or the company
itself, may apply to a superior Court of law or equity for
an order to rectify the register. The Court may refuse
the application with or without costs ; or, if satisfied of
its justice, may order a rectification of the register, the
(A-) 25 & 2G Vict. c. 89, s. 20.
(0 Id. a. 27.
(in) Id. 8. 29.
(>i) Id. s. 35. Sec Buckley, S0--113.
ISSUING NOTES AND BILLS. 413
company to pay the costs and any damages the party
aggrieved may have sustained (n).
The Com-t may also decide questions relating to the
title of the applicant, or arising between two or more
members or alleged members {n). When the Court orders
the register to be rectified, notice must be given to the
registrar of the amendment or alteration (o).
Inspection of Uegister. — A register of members, com-
mencing from the date of the registration of the company,
must be kept at its registered office for inspection by the
members gratis, and by other persons on the payment of
Is., or a less sum if prescribed by the company, for each
inspection. A member or any other person may require
a copy of the register, or of the list of members or sum-
mary of particulars on the payment of QcL for every hun-
dred words copied. Should an inspection or a copy be
refused, the company, director or manager will incur a
penalty not exceeding 2/., and an additional penalty not
exceeding 21. for every day the refusal continues {})).
In addition to these penalties, a judge at chambers may
order an immediate inspection. The company may, by
giving notice in any newspaper circulating in the district
where its registered office is situate, close the register for a
period not exceeding thii-ty days in each year {j)).
Issuing Proniisiionj Notes and Bills of Exchange. — With
respect to these instrmnents, the act provides that they are
to be deemed to have been made, accepted or indorsed on
behalf of the company, if made, accepted or indorsed in the
name of the company by any person acting under the
authority of the company, or if made, accepted or indorsed
by or on behalf or on account of the company by any per-
son acting under the authority of the company (y). A bill
(^0 25 & 26 Vict. c. 89, s. 35. See Buckley, 80—113.
(o) Id. s. 36.
{p) Id. ss. 32, 33.
{q) Id. s. 47.
414
LIMITED RANKING COMPANIES.
Statement of
assets and
liabilities.
of excliange addressed to a company and signed " A. B.,
C. D., directors of the company," was held to bind the
company, and not the directors (r) . Bnt where a pro-
missory note was signed by persons describing themselves
as directors of a limited company, and countersigned by
the secretary of the company, as follows : —
"London, December 31, 1856. — Three months after
date we jointly promise to pay Mr. Frederic Shaw or
order 600/. for yakie received in stock, on account of the
London and Birmingham Hardware Company, Limited : "
it was held, that the directors who signed it were not per-
sonally liable on the note (s) . A person advanced money
for the purposes of a company in which he was a share-
holder, and received a promissory note in the following
form : " "We, the directors of the Isle of Man Slate and
Flag Company, Limited, do promise to pay to Mr. J.
Dutton 1,600/., with interest at the rate of 6/. per cent,
per annum until paid." It bore the seal of the company
and was signed by foin- directors. The lender had stated
that he would advance the money to the directors only,
and the Court held that the directors who had signed the
note were personally liable upon it (/).
Statement of Assets and Liabilities. — As a protection to
creditors and others, the act imperatively requires the
publication of a statement of its capital, assets and liabili-
ties twice a year, and a register of the company's mort-
gages to be kept. With respect to the statement, tlie act
enacts, that every limited banking company shall, before
it commences business, and also on the first Monday in
February and first Monday in August in every year, make
a statement in a form prescribed (/^), or as near thereto
(>•) Olull V. Clun-lrs, 31 L. T. 822.
(a) Ziiidus V. Melro.<:c, 3 H. & N. 177 ; 27 L. J., Exoh. 326.
{/) Dill/on V. Marsh, 40 L. J., Q. B. \7'). Sec, also, CoriauhJ \. San-
ders, 1") W. K. 90G ; Ex parte Af/ra Bank, L. E., Eq. 725.
(u) Eonn (B.), Avliicli is as follows: —
The capital of the company is , divided into shares of
each.
•REGISTER OF MORTGAGES. 415
as circumstances will admit. A copy of tlie statement is to
be put up in a conspicuous place in the registered office,
and in every brancli or place where the business of the
company is carried on. If default is made in compliance
with these provisions, the company is liable to a penalty
not exceeding 5/. for every day of default ; and a director
or manager permitting the same incurs a similar penalty {^v).
Members and creditors are entitled to a copy of the state-
ment on payment of a sum not exceeding sixpence (x).
Bcgisfer of Mortgages. — All mortgages and charges sjjc-
ciJicaUy affecting property of the company must be kept in
a register. A short description of the property, the amount
of the charges created and the names of the mortgagees
or persons entitled to the charges must be entered. If
these entries are not made, every director, manager or
other officer, who Inioicinghj and n-UfulJij (g) authorizes or
permits the omission, will incm' a penalty not exceeding
60/. (s). It would seem then the above section is du'ectory
merely, and non-registration will not invalidate the mort-
gage («).
The iiiimber of shares issued is .
Calls to the amount of pounds per share have been made, under
which the sum of pounds has been received.
The liabilities of the company on the first day of January (or July)
were —
Debts owing to sundiy persons by the company : —
On judgment, £
On specialty, £
On notes or bills, £
On simple contracts, £
On estim.ated liabilities, £
The assets of the company on that day were : —
Government securities \_siating them'], £
Bills of exchange and promissory notes, £
Cash at the bankers, £
Other securities, £
A deposit company is also boimd to make the above statement,
(.r) 25 & 2G Vict. c. 89, s. 44.
(y) Borough of Haclcneg Xeuspaper Compaynj, 3 Ch. D. 669.
(z) 25 & 26 Vict. 0. 89, s. 43 ; In re Borough of Hackneg Newspaper
Company, 3 Ch. D. 669.
(«) Ex parte Valpy, L. E., 7 Ch. App. 289. As to their right to avail
themselves thereof as against creditors, see International Palp Company,
Krmdes Mortgage, 6 Ch. D. 55G ; 46 L. J., Ch. 625 ; Wynn Hall Coal
416 LIMITED BANKING COMPANIES.
A company deposited deeds with bank as collateral
security for bills under discount, but the deposit was not
accompanied with the formalities required by its articles
of association upon making a charge or a mortgage, nor
was the security registered. At the time of the winding
up of the company it was indebted to the bank for a bill
of exchange which had been discounted for the company,
but which had been deposited with the bank to secure ad-
vances made to various persons. The secmities comprised
in the deeds had been realised; these remained in the
bank's hands, after satisfying the bill which had been
discounted for the company itself ; it was decided that the
deposit of the deeds constituted a valid mortgage, and
that the bankers, not being officers of the company within
the meaning of the Companies Act, 1862, s. 165, were
not bound to see that the formalities required by the
articles of association had been complied with (/>).
Shareholders who have mortgages made to them by the
company are not bound to see that they are registered (c).
This register is to be open to the inspection of creditors
and members at all reasonable times. Should an inspection
be refused by any officer, director or manager, a penalty
not exceeding 5/. is incm-red, and a further penalty not
exceedmg 21. for every day of continued refusal. A judge
at chambers may order an immediate inspection of the
register {d).
Mcet'nujH and Minutes. — A general meeting of the com-
pany must be held once at the least in every year {e).
The minutes of all resolutions and proceedings of general
Company, L. R., 10 Eq. 515; Kative Iron Ore Company, 2 Ch. D. 345;
Ex parte National Bank, infra; In re f'iouth Durham Iron Company, 11 Ch.
D. 579; 48 L. J., Ch. 4X0.
(i) Ex parte National lSa}il\ L. R., 14 Eq. 507; 41 L. J., Ch. 323. As
to what is sufficient registration, sec Native Iron Ore Company, 2 Ch. D.
345; 45 L. .1., Ch. 517. And as to company's power to mortgage, see
I'atent File Company, L. R., G Ch. 83 ; liat/i's ease, 8 Ch. D. 334,
(c) General South American Company, 2 Cli. D. 337.
(rf) 25 & 2G Vict. c. 89, s. 43.
(e) Id. s. 49.
SPECIAL RESOLUTIOXS. 417
meetings of the company, and of tlie directors or managers,
must be duly entered in books provided for the purpose (/).
These minutes, if purporting to be signed by the chairman
of the meeting at which the resolutions were passed or
proceedings had, or by the chairman of the next meetings,
will be receivable as evidence in legal proceedings (/).
These minutes, when made, will be prima facie evidence
of the due holding of the meetings, passing of the resolu-
tions and proceedings, the appointment of directors, and
the validity of their acts, notwithstanding the discovery of
any defects in their appointments or Cjualifications after-
wards (/).
Special Hefiolutioiis. — A resolution is special when passed
by a majority of not less than three-fourths of the members,
entitled according to the regulations of the company to
vote either in person or by proxy, at a general meeting,
of which notice to propose the resolution has been given,
and confirmed by a majority of such members at a
subsecjuent general meeting, held at an interval of not
less than fourteen daj's nor more than a month from the
first meeting (y). Unless a poll is demanded by at least
five members, a declaration of the chairman at the meeting-,
that the resolution has been carried, is conclusive evidence
of the fact, vathout proof of the number or proportion of
the votes recorded in favour of or against the resolution.
Notice of meetings will be deemed duly given, and the
meetings duly held, whenever the notice has been given
and the meetings are held in the manner prescribed by
the regulations of the company. In computing the ma-
jority when a poll is demanded, reference is to be had to
the number of votes to which each member is entitled by
the regulations of the company (g).
A copy of every resolution in force must be annexed
to or embodied in every copy of the articles of association
if) 25 & 26 Vict. c. 89, s. G7.
(ff) Id. s. 51.
G. E E
418
LIMITED BAN'KTXG COMPANIES.
Notices and
legal pro-
ccedinsrs.
issued after the passing of tlie resolution (//). A company
making default will incur a penalty not exceeding 1/. for
each copy so issued ; and a director or a manager know-
ingly and wilfully authorizing or permitting the issue will
incur a similar penalty (/?).
Registry of Spccicd Resolutions.— K copy of every special
resolution must be printed, and forwarded to the registrar,
in order to he recorded by him. If a copy is not forwarded
within fifteen days after the confirmation of the resolution,
the company mil incm- a penalty not exceeding 27. for
every day afterwards ; and a director or a manager will
incur a similar penalty (/).
Notices and Legal Proceedings. — Notices, summonses,
and other documents may be served by delivering, leaving
or posting the same, in prepaid letters addressed to the
company at their registered office (/.•) .
A writ of summons cannot be so served upon the com-
pany or a director, but only upon the manager or secretary
of the company (/). Proof that the notices were posted in
time, properly addressed and stamped, will be sufficient {m).
A summons, notice or other docmnent requiring to be
authenticated by the company, may be signed by any
director, secretary or other authorized officer; and it is
not necessary to be under the seal of the company, and
may be in writing or in print, or partly in writing and
partly in print {n).
In actions or suits brought by the company against any
member, to recover calls or moneys due from such member
in his character of member, it will not be necessary to set
forth the special matter, but it will bo sufficient to allege
{h) 25 & 2G Vict. c. 89, s. 54.
(0 Id. s. 53.
[k) Id. 8. G2.
(/) Toicne v. London and Lhncnck Steamship Compami, 5 C. B., N. S. 730.
(w() 2.') & 26 Vict. c. 89, s. 6.'J.
(>0 Id. s. G4.
EXAMINATION OF AFFAIRS BY INSPECTORS. 419
that the defendant is a member of the company, and is
indebted to the company in resjteet of a call made or other
moneys due whereby an action or suit has accrued to the
company (o) .
If it appears in such action, by any credible testimony,
that there is reason to believe that if the defendant be
successful in his defence the assets of the company will be
insufficient to pay his costs, a judge may require security
for costs to be given by the company, and stay all pro-
ceedings until security is given {])).
The pecuniary penalties imposed by the act may be
summarily recovered before justices of the peace (q).
Examination of Afalrs hij Inspectors. — An examination
into the affairs of a banking company maj^ often be desir-
able, in cases of rumours of losses or delinquencies of
directors. The act gives power to the Board of Trade,
or to members, to appoint inspectors for the piu'pose of
reporting thereon. In the case of the Board of Trade, the
application must be made by members holding not less
than one-third of the entire shares of the company (r).
It must be supported by such evidence as the Board of
Trade may require, for the pm'pose of showing that the
applicants have good reason for demanding the investiga-
tion, and that they are not actuated by malicious motives
in instituting the inquiry. The Board of Trade may
require secm-ity for costs to be given before appointing the
inspectors (s) .
It will be the duty of the officers of the company, on
the inquiry, to fm-nish the inspectors -with all information
(o) 25 & 26 Vict. c. 89, s. 70.
\p) Id. s. 69. See Moscow Gns Company v. Inteniational Financial
Society, L. E.., 7 Ch. 225; Xorthampion Coal Company \. Midland Waggon
Company, 7 Ch. D. 500.
{q) Id. s. 65.
[r) Id. s. 56.
(«) Id. s. 57.
E E 2
420 LIMITED BANKIXO COMPANIES.
ill tlieir power, and to produce their books and documents,
and the officers may be examined on oath (t).
If an officer should refuse to produce the books or docu-
ments, or to answer questions relating to the affairs of the
company, he will incur- a penalty of not less than 61. for
each offence (t).
Upon the conclusion of the examination the inspectors
are to report their opinion, which may be either waitten or
printed, to the Board of Trade (u). A copy of the report
is to be forwarded l)y the Board of Trade to the registered
office of the company, and to the members at whose in-
stance the inspection was demanded, if they require it.
These persons will have to defray the expenses of the in-
vestigation, unless the Board of Trade otherwise directs
them to be paid out of the assets of the company {>().
In the case of a company being authorized by a special
resolution, it may appoint inspectors to examine into the
state of its affairs (.r) ; the inspectors being clothed with
the same powers and entrusted with the same duties as the
inspectors appointed by the Board of Trade, with this ex-
ception, that their report is to be made in such manner
and to such persons as the company in a general meeting
of its members directs. Their officers will incur similar
penalties by refusing to produce books or documents, or to
answer questions, as under an examination conducted by
the inspectors of the Board of Trade {.r).
A copy of the report, authenticated by the seal of the
company, will be admissible in legal proceedings as evi-
dence of the opinion of the inspectors in relation to any
matter contained in the report {//).
(0 2o & 2G Vict. c. 89, 8. o8.
(m) Id. 8. 59.
{x) Id. s. 60.
(y) Id. s. Gl.
( I'-'l )
CHAPTER XLY.
CHARTERED BANKS.
Banks may be formed under the 7 AVill. IV. & 1 Viet. 7 Will. iv. &
c. 73, by royal charters or letters patent. The charters are ^ ^^^^' ^' ""^'
obtained by petitioning the Queen in council. The petition
and draft of the proposed charter are left at the Council
OfSce and afterwards referred to the Board of Trade.
The Colonial Office and India Office are also referred to if
the proposed company falls within their departments. If
it is determined that a charter shall be granted, it issues
under the great seal {a) . The liability of the members is
usually limited by the letters patent to the amount of their
respective shares {b), and legal proceedings by or against
the companies are directed to be taken and prosecuted in
the name of a public officer appointed for the purpose (c).
The charters are generally for limited periods, but they are
renewable (d). Previously to an application to the Board
of Trade for a charter, notices must be inserted in the
Gazette and other newspapers (e). A bank incorporated
under this act cannot be registered under the Companies
Act of 1862 as an unlimited company (_/'), or, when regis-
tered as a limited company, alter any provision contained
in the letters patent relating to the company-, without the
sanction of the Board of Trade {[/). Of recent years it has
not been the policy or the practice of the government to
advise the Queen to grant charters for the establishment of
banking companies in the colonies or in India, preferring
to leave these matters to the free action of the Colonial or
Indian governments themselves.
(a) Wordsworth's Joint Stock {(/) 1,1. s. 29.
Companies, page 235, 6th edition. {>■) Id. a. 32.
(//) 7 Will. 4 & 1 Vict. c. 73. {f) Id. s. 179.
(r) Id. 8. 3 (y) Id. s. 19G.
( 422 )'
CHAPTER XLYI.
IRISH AND SCOTCH BANKS.
With respect to Irish Banks, tlie 6 Geo. IV. c. 42, which
is still in force as to banking copartnerships or societies
established in Ireland under its provisions, enables them
to sue and to be sued in the names of theii^ public officers,
and requires a return of their members to be made to the
Stamp Office. That act has not repealed the Act of the
Irish Parliament, 33 Geo. II. c. 14 {a). The Irish act does
not relate exclusively to persons carrying on the business
of banking in the way of banks of issue, but to all bankers
in Ireland (i). A memorandum accompanying a deposit
of deeds made as a security for a debt, and made by a
person carrying on the ordinary business of a banker is
Avithin the statute, and ought to be registered to be avail-
able as against creditors under a trust deed executed
pursuant to the provisions of the act (/;). A deposit of
deeds as security for a debt, accompanied by a memoran-
dum specif}dng the purpose of such deposit, constitutes a
conveyance under that statute, and might, and ought to,
have been registered, even though the stoppage of pay-
ment by the banker took place within one month after its
date (b) .
la) Contrary to the opinion of L<;rd 8t. Leonards, expressed in (/Fla-
herty v. 31'JJoweU, 6 H. L. Cas. 185. Coplaml v. Bavks, 3 Ir. Eq. R. 31 ;
L. R., 5 H. L. Cas. 358 ; 21 W. R. 1. The act is unrepealed, except as
to" such specific matters contained in it as have been the suhjcct of special
Ico-islation. The previous uuperial acts of parliament atl'ecting banking-
institutions in Ireland are the 8 Geo. 1, c. 14; 33 Geo. 2, c. 14;
21 & 22 Geo. 3, c. IG ; 40 Geo. 3, c. 22; 1 & 2 Geo. 4, c. 72; and
5 Geo. 4, c. 73. The provisions of the 1 & 2 "Vict. c. 96, made perpetual
by 5 «& 6 Vict. c. 85, apply to banking copartnerships established in
Ireland under the G Geo. 4, c. 42. Wiicre judgment was obtained in
Ireland against a public officer, a Avarrant of attorney, luider 6 (ico. 4,
c. 42 s. 12, to confess judgment in England for a less sum than that for
whicii judgment was obtained in Ireland, is a nullity. Walker v.
M'Jhnrall, 3 Jur., N. S. 1078. The G Geo. 4, c. 42, above mentioned, is
similar to' the 7 Geo. 4, c. 4G, regulating English banking copartnerships.
Ih) CopUnid V. Thirks, L. R., 5 H. L. Cas. 358 ; 21 W. R. 1.
IRISH AND SCOTCH BANKS. 423
The 8 & 9 Vict. e. 37, s. 30, enables banking com-
panies established within fifty miles of Dublin to sue and
to be sued in the name of their public officer.
The 7 Greo. IV. c. 67, enabled banking copartnerships
established in Scotland to sue and to be sued by public
officers, and the returns of the names of theii' firms,
members and officers are required to be made to the
Stamp Office by these copartnerships. An omission to
make these retm^ns does not, however, disentitle them to
sue in this coimtry {c).
In 1846, the provisions of the 7 & 8 Vict. c. 113, giving
the crown powers to grant letters patent of incorporation to
English joint stock banks for a term of years not exceeding
twenty, were extended by the 9 & 10 Vict. c. 75, to both
Irish and Scotch joint stock banks.
Subsequently the 19 & 20 Vict. c. 3, fm-ther extended
the provisions of the English statute in favour of Scotcli
joint stock banks existing before the 9th of August, 1845,
by enabling the crown to grant to them letters patent of
incorporation, in perpetuity, in lieu of a liniited maximum
of twenty 3^ears only. But by 17 & 18 Vict. c. 73, s. 1,
banks formed under these acts, as to Scotland, the right
of retention or lien over shares of partners was not to be
affected, and banks may, by sect. 2, sell shares acquired
by virtue of lien. By sect. 3, bills or notes were not to be
signed in the manner prescribed by the 7 & 8 Vict. c. 113.
In 1857, banks, which had been formed in Scotland or in
Ireland under these statutes, were required by the 20 & 21
Vict. c. 49, to register under that act, and, in default of
registration, they were subject to certain penalties and
disabilities (f/). That act also repealed the 9 & 10 Vict.
c. 75, and prohibited the future formation of banking
companies either in Scotland or in Ireland, except under
its provisions. In 1858, limited banking companies might
be formed in Scotland or in Ireland mider the 21 & 22
{(■) Bomn- V. Mitchell, 5 Exch. 41.3 ; 10 L. J., Exch. 302.
[d) 20 & 21 Vict. c. 19, s. 5.
424 IRISH AND SCOTCH BANKS.
Yiot. 0. 91. In 1862, this act was afterwards repealed
Ly the Companies Act, 1862(e). The latter act im-
peratively requires banking companies, formed under the
provisions of the repealed act, to register under the new
act (/).
The issue of bank notes in Ireland is regulated by the
8 & 9 Yict. c. 37, and in Scotland by tlio 8 & 9 Yict. c. 38,
as abeady mentioned (g).
As the provisions of the new act for the formation, regu-
lation and registration of banking companies of limited or
unlimited liability in Scotland and in Ireland are the same
as in England, it will be only necessary to refer the reader
to the previous Chapters on these subjects.
{e) 25 & 26 Vict. c. 89, s. 20.3, Third Schedule, First Part.
(/) Sects. 180, 209, 210.
(ff) Ante, p. 326. The statute is set out in Appendix.
( 425 )
CHAPTER XLYII.
COLONIAL, INDIAN AND FOREIGN BANKS,
Banking institutions are generally establislied in the
colonies and in India by virtue of charters from the crown,
or under the authority of local laws, corresponding in a
great measure with the English laws on the subject. By
an act of a colonial legislatui-e, it was provided that a
banking company should sue and be sued in the name of
its chairman, and that execution on any judgment against
the company might be enforced against the property of any
member for the time being, in like manner as if the judg-
ment had been obtained against such member personally.
In an action against a member in this country, on a judg-
ment obtained in the colony against the chairman, it was
decided that the colonial legislature had authority to pass
the act, and that there was nothing repugnant to the laws
of England or to natural justice in enacting that actions
on contracts made by the company in the colony, instead
of being brought against the members individually, should
be brought against the chairman whom they had appointed
to represent them, and that a judgment recovered in such
an action, after service of process on the chairman, had the
same effect beyond the territorial limits of the colony
which it would have had if the defendant had been per-
sonally served with process, and, he being a party to the
record, the judgment had been personally against him («).
So, by an act of the Indian legislature, a banking
company established at Calcutta might be sued in the name
of its secretar}', and a judgment against him was to have
(«) Bank- of AKslralasia v. yias, 16 Q. B. 717; Bank of Australasia v.
Harding, 9 C. B. 661. See Henderson \. Henderson, 6 Q. B. 288 ; Dc Cosse
Brissac v. Rathhonc, 6 H. & N. 301.
426 COLONIAL, INDIAN AND FOREIGN BANKS.
the same effect against the property of the bank as if reco-
vered against all the members as parties on the record; and
it was provided that, if an execution issued against the pro-
perty of the bank proved ineffectual, execution should issue
against the members successively, and if that were also
ineffectual, then against any person who was a member
at the time when the contract sued upon was entered
into, but no execution was to be issued against any other
person than the actual party to the suit without the leave
of the court and notice given to the person to be charged :
a creditor, having recovered a judgment in India against
the secretary of the bank for a breach of contract entered
into by the company there, took no further proceedings in
India, but immediately brought an action against a mem-
ber who was so at the time the contract was entered into,
and recovered judgment in this country on the judgment
and the contract, and it was held that he was entitled to
do so, and to recover in respect of both causes of action {b).
" It has been ui-ged," said the Court in delivering judg-
ment, " that, when the defendant consented to be bound
by a judgment recovered, not against himself in his own
name, but against another who represented him, he
should be considered as having consented only on condi-
tion that proceedings on the judgment were pursued in tlie
manner appointed by the act. But he must have known
that that act would have no effect in this country. He
therefore consented to be sued in the name of the public
officer in India, and to be liable to all the consequences
which might arise out of it in tliis country " (c).
The production of bankers' books with the entries of the
items constituting the demand, kept according to the
established custom of mahajuns in India, is not of itself
sufficient evidence to establish such a claim, strict proof of
the debt being required {d).
(b) Kehall v. Marshall, 1 C. B., N. S. 2 tl ; 26 L. J., C. P. 10.
(f) Id., 26 L. J., C. P. 23, per Crcsswell, J.
[d) lUii Sri Kiir!li>i V. r„!rnt, 1 1 M. (S: W. 1 1 ; 1 1 L. J., Exeli. 375.
{l>) Sec auto, 1). 111.
BHAXCH BANKS. 429
clieque except at that branch where he keeps his account (o) .
The following cases will illustrate this rule. The holder
of a promissory note presented it at the head office of the
bankers of the makers for payment. They sent it to their
liranch at the place where the note was payable, where the
clerk cancelled the signature, wrote "paid" on the note,
and transmitted a draft in respect of it to the head office.
Held, that the head ofiice and branch were for this pm--
pose one and the same bank, and that the act of the clerk
in transmitting the draft did not operate to charge the
bank with money had and received to the use of the
holder (d). But where a bill of exchange was indorsed to
a Branch Bank of the National Provincial Bank of Ens'-
land established at Port Madoc, who sent it to another
branch established at Pwllheli, who indorsed it to the head
establishment in London : it was held, in an action upon
the bill by the indorsee against the drawer, that each of
the branch banks was to be considered as an independent
indorsee, and each entitled to notice of dishonour (f).
So, where there was a banking company having branches
at many places, amongst others at Grlastonbury and Bridg-
water, and each branch had a separate manager, and kept
sej)arate accounts with its respective customers, whom each
supplied with cheque books headed with the name of the
place at which it respectively carried on business, and a
customer, who kept an account with the Glastonbury
branch, made a payment of a debt, which he owed the de-
fendant, by giving him a cheque for the amount of it on
that branch, which he presented the same day at the
Bridgwater branch, where he was known and where he got
cash for it, and it was sent by that branch by the first post
to the former branch, and delivered to them next day,
but in the meantime the customer's balance with them had
been drawn out, and the cheque was accordingly refused
{c) Prince V. Oriental Bank Corporation, 3 App. C'a. 325 ; 47 L. J., P. C.
42.
(d) Und.
(<•) Clodc V. Bayhi/, 12 M. k W. 51 ; aucl linnoi v. Lnndun and Xorih
Western Baihvay Company, 4 B. & S. SoO. 337.
430 BRANCH BANKS.
payment, and notice of dishonour given to the defendant,
who was obliged to refund in an action for money had and
received brought against him by the public officer of the
banking company ; it was held that the drawer of the
cheque did not stand in the relation of customer to the
Bridgwater branch, that the giving cash for the cheque
did not amount to a purchase of the cheque by that
branch, but only amounted to changing it, and that the
cheque was not drawn on the company generally (/).
In the absence of any special agreement or arrangement
there is no obligation on a banking company to honour
the cheque of a customer presented at one of its branches
where he has a balance standing to his credit, v/hen he has
overdrawn his account at another branch to an amount
greater than such balance, so that the company is not in
fact indebted to him upon the whole account. Neither is
there any obligation on a banker to give notice to his
customer, that he intends to transfer a balance against the
customer from an account at one branch to an account at
another branch (r/).
"Where a firm paid a cheque into a branch bank in
India to their current account after the stoppage of the
parent bank in England, but before the branch had any
notice of the stoppage, and afterwards, on the same da}',
the branch received notice of the stoppage of the bank in
England, and stopped itself, an application by the firm to
be paid the amount of the cheque was refused ; but per-
mission was given for a renewal of the application, if the
firm should find that the cheque had not been cashed until
after the branch had received notice of the stoppage of the
bank in England (//).
The subject of brancli banks established by tlie Bank of
England has already been considered (/).
(/) Woodland v. Fear, 7 El. & El. TjIO ; 26 L. J., Q. B. 202.
(V/) Garndt v. M'Kexvan, 42 L. J., Excli. 1 ; L. R., 8 Exch. 14; ante,
p. 199.
(/*) In re Aqra and Masterinan's B/oiI:. F.x parte TFariiif/, 30 L. J., Chaue.
161; W. N. 1800, j). :?09.
. ((■) Antp, p. 300.
( 431 )
CHAPTER XLIX.
SHARES, CALLS AND SHAREHOLDERS.
S/utres. — The shares of the momhers of banking copartner-
ships or companies, whether formed under deeds of settle-
ment or under articles of association, are personal property,
and are generally subject to all the legal incidents which
attach to personal property.
The shares of a banking copartnership, established in
conformity with the 7 Gfeo. lY. c. 46, the property of
which consisted in part of freehold and of copyhold es-
tates, and mortgages for terms of years, have been held,
both at law {a) and in equity (a), to be personalty and not
realty, and to be legally bequeathable to charitable pm*-
poses, within the Mortmain Act, 9 Geo. II. c. 86. The
shares or interests of members in companies formed under
the Companies Act of 1862 are expressly declared to be
personal estate, transferable in the manner provided by the
regulations of the companies, and not real estate (b). The
shares in all banking copartnerships are usually numbered,
as they should be before being issued or allotted by limited
banking companies (b) ; and the shares are represented by
certificates corresponding with the numbers and amounts
of the shares.
A. purchased some shares in a banking company, and
had them transferred into the joint names of herself and
B. B. survived A., and there was clear evidence to
show that A. intended the shares for B. absolutely. By
the regulations of the company, however, there was no
benefit of survivorship between shareholders. It was
{a) Myers v. IWujal, 2 De G., Mac. & G. COO ; 11 C. B. 90 ; AMon v.
Lord Lanqdale, 4 De Gex & Sm. 402.
(4) 25 & 2G Vict. c. 89, s. 22.
432 SHARES, CAT.I.S AND SHAKEHOI.DERS.
nevertheless held that the legal title was complete in B.,
and that she was entitled to them by survivorship (c).
Equitable Mortgage. — Certificates for shares may be de-
posited or pledged with bankers for advances (f/), but
notice must be given to the company to guard against the
risk of losing their lien in the event of bankruptcy ; shares
not being choses in action within the Bankruptcy Act,
1869 [e). See further on this subject, p. 161,
Scrip Certificate. — As to the nature of and law respecting
scrip certificate, see p. 167.
Sale of shares. Purchase or Sale of Shares. — By 30 Vict, c, 29, s, 1, a
contract or an agreement for the sale or transfer of shares
in any joint stock banking company in the United King-
dom, constituted under or regulated by the provisions of
anv act of parliament, royal charter or letters patent,
issuing shares or stock transferable by deed or written in-
strument, Vv'ill be null and void, unless the contract or
agreement shall set forth and designate in writing such
shares or stock by the respective numbers by which they
are distinguished at the making of the contract or agree-
ment on the register or books of the banking company, or
where there is no such register of shares or stock by dis-
tinguishing numbers, then unless the contract or agree-
ment shall set forth the person or persons in whose name
or names such shares or stock shall at the time of making
the contract stand as the registered proprietor thereof in
the books of the banking company; and every person,
whether principal, broker or agent, who wilfully inserts in
the contract or agreement any false entry of the numbers
of the shares or stock, or any name or names other than
(c) Garrick v. Taijlor, 29 Bear. 79; 30 L. J., Clianc. 211; affinned ou
appeal. 31 L. J., Chanc. G8. See Hill's case, L. R., 20 Eq. 585.
{d) Ex parte fiargent, L. R., 17 Eq. 273.
(e) Ex parte Union Bunk of ^Lauchester, L. R., 12 Eq. 351 ; 40 L. J.,
Bank. 57.
PURCHASE OR SALE OF SHARES. 433
that of the person or persons in whose name they stand,
vdll be guilty of a misdemeanor.
Joint stock banking companies are bound to show their
lists of shareholders to any registered proprietor during
business hours, from ten to four o'clock. These provisions
do not apply to shares or stock of the Bank of England
or of Ireland (,/').
A contract for the sale of shares in a banking company
is not a contract for the sale of " goods, wares or mer-
chandise," within the 17th section of the Statute of Frauds,
so as to require a written memorandum {g) . But a note
or memorandum of the contract for the sale or purchase of
such shares, when to the amount or value of 51. or upwards,
requires a penny stamp {/i). A person who is induced to
become a purchaser of shares in a banking company under
false or fraudulent representations made by the directors
or others, as to the financial position and circumstances of
the bank, may refuse to perform his contract (/). But if
he has accepted the shares, or registered the transfer, and
the bank afterwards fails, he cannot repudiate his liability
as a shareholder, unless in the meantime he has avoided
the contract or done that which is equivalent to avoiding
it before (/). His remedy will be against the parties
deceiving him for the recovery of the purchase-money and
the calls which he has paid (/r). When shares, however,
have been fraudulently sold by a banker vnth. whom they
have been deposited for secmity, and a forged transfer
regularly executed and registered, the owner has a right to
have the shares delivered up to him by the purchaser, and
(/) This act is printed in the Appendix.
iff) Hnmblc v. Mitchell, 11 A. & E. 205.
(h) Stamp Act, 1870, Sched., tit. Contract Note. By sect. 69 (1), the
stamp may be denoted by an adhesive stamp, which is to be cancelled by
the person by whom the note is first executed. A broker cannot recover
his commission imless the contract note is so stamped.
(j) Ex parte Mchol, 3 De G. & J. 387; 38 L. J., Chanc. 2.57; Oakes v.
Turquand, L. K., 2 H. L. 325 ; Venezuela BaUwa'i Conipain/ v. Kisch,
L. R., 2 H. L. 99 ; Stone v. Cifij and Comitij Bank, "S C. P. JD. 282 ; 47
L. J., C. P. 681. See also Arlrnght v. Kewbold, 17 Ch. D. 301.
[k] Scott V. Dixon, 29 L. J., Exch. 62, n. ; Felrjatc's case, 11 L. T., N. 8.
613 ; 2 De G., J. & S. 456 ; Oakcs v. 'furquaiid, supra, and ante, p. 410.
G. F F
434 SHARES, CALLS AND SHAREHOLDERS.
the transfer and entry of it in the company's "books can-
celled (/)•
A power of attorney to sell shares does not, without
express words, give authority to pledge (/»). By the regu-
lations of most banking copartnerships, the consent of the
directors is necessary before a shareholder can transfer his
shares to a purchaser (»).
It follows, therefore, when such is the case, that no con-
tract can be made between a shareholder and the intended
purchaser for the sale of shares, except conditionally, that
is to say, the contract must be made, either in terms or
impliedly, contingent on the event of the directors consent-
ing to the proposed transfer; also the deed of transfer
must be considered to be executed provisionally ; and the
purchase-money can only be safely paid to the vendor after
the transfer is registered (o) .
But when the shares are bought through a stockbroker,
the practice is for him to pay for the shares before that
event, and he may recover the amount and stamps and
commission from his employer, though the bank stops pay-
ment in the interval (p).
Transfer of Shares. — The 7 Geo. IV. c. 46 does not pre-
scribe any form of transfer of shares. Shares in co-part-
nerships established under the provisions of that statute
are transferable only according to the particular mode
pointed out by the deeds of settlement (^7) . Shares in bank-
ing companies, formed under the 7 & 8 Vict. c. 113, are
(1) Johnston V. JReafon, L. R., 9 Eq. 181 ; 39 L. J., Chanc. 390.
(w) Duncuft V. Alhrccht, 12 Sim. 199.
(«) Ex parte Walton, 2G L. J., Chauc. 545, 518. Wlicre the consent of
the directors is required it must nfit bo improperly ■withliekl, Jlobiiison v.
Chartered Hank of India, L. R., 1 Eq. 32. See Kv parte Pinney, L. R.,
8 Ch. 446. Qiarij, who has to procure the consent, the vendor or vendee,
see Bcidcrman v. Stone, L. R., 2 C. P. 504. It is the duty of the pur-
chaser to register, Coles v. Bristotve, L. R., 4 Ch. 3. Sec Marsteadv. Fu'we,
L. R., 6 Ex. 132.
(o) Taylor v. Stray, 26 L. J., C. P. 185, 287.
\p) Stray v. Rusacll, 1 El. & Bl. 888.
Iq) Bosanquct v. Shortridgc, 4 Exch. 699.
MEMBERS OR SHAREHOLDERS. 435
transferable by a deed duly stamped, and in a given form,
as already shown. Shares in banking companies, formed
or registered under the 20 & 21 Vict. c. 49, or the 21 & 22
Vict. c. 91, on registration imder the Companies Act of
1862, are transferable in the manner hitherto in use, or in
such other manner as the companies may direct (r). But
shares in limited banking companies, formed and registered
under the Companies Act of 1862, are transferable ac-
cording to the regulations prescribed by the articles of
association. The form usually prescribed is a deed attested
by witnesses.
Members or Share/ioldcrs. — Let us next inquire who are
meant by members or shareholders. With respect to
banking companies formed under articles of association,
the Companies Act of 1862 defines members to be the
subscribers of the memorandum of association and all
persons who have agreed to become members and whose
names are entered on the register of members {s). This
register will be prima facie evidence of membership (t).
The register, though informal, is prima facie evidence
that a person whose name appears on it is a shareholder {u).
The returns of theii- members which banking companies
in England and Wales are required by the 8 & 9 Vict.
c. 32, s. 21, to make annually to the stamp office (x), will
be also admissible in evidence to establish the fact. The
articles of association generally provide that proof shall be
furnished to the satisfaction of the directors of the title of
persons claiming shares on death, on bankruptcy and on
marriage of females. Until this proof is produced, a
transfer cannot be made or enforced. In copartnerships,
established under the 7 Greo. IV. c. 46, the deeds of settle-
ment define the persons who are or may be shareholders,
(r) 25 & 26 Vict. c. 89, s. 178.
(s) Id. 8. 23. See tlie notes to this section in Buckley, pp. 35 — 69.
{t) Id. s. 37. See ante, pp. 410, 411.
(m) Henderson v. Moijal Britiih Bank, 20 L. J., Q. B. 112, ante, p. 411.
(.r) See ante, p. 332.
F f2
436 SHARES, CALLS AKD SHAREHOLDERS.
and prescribe certain modes and forms by wliich tbey are
to become so. Therefore, where the deed requires that a
transferee of shares shall be approved of by a board of
directors, the approval certificate, although signed by a
proper proportion of directors, is insufficient, if not given
at a board, and the transferor still remains a share-
holder {y) .
Where the deed of settlement of the company requires
certain acts to be done by persons marrying female share-
holders, and certain other acts to be done by the executors
of deceased shareholders, before they can respectively be-
come members of the company, it is necessary that they
should be shown to have performed the prescribed acts (~).
The general principle, as established by numerous cases,
is, that where the deed of settlement prescribes certain for-
malities for effecting a transfer of shares, yet, notwith-
standing the omission of these formalities, a transfer may
be held binding, provided some act is done by or on behalf
of the company, by which a transferee is recognized and
treated as a shareholder instead of the transferor [a).
But where by the deed of settlement and tlie charter of
a banking company, it was provided that, upon a transfer
of shares taking place, seven days' previous notice in
writing of the proposed transfer should be given to the
directors before any transfer could be made, and that,
after the consent of the directors had been given, the
transfer should be executed and delivered to the secretary
to be registered, whereupon a new cei-tificate, sealed with
the seal of the company, was to be delivered to the trans-
feree, and the company had departed from this form, and
had allowed the practice to grow up for the secretary to
deliver out a blank foim of transfer without any previous
notice, which was returned, after having been filled up and
((/) Bosanquet v. Shortrld(/c, 4 Exch. G99.
(s) Lodgson v. Bell, 5 Exch. 9G7 ; iNm v. Armstrong, 4 Exch. 21; Kess
V. Bertram, id. 19o ; Ness v. Anijas, 3 Exch. 805.
(rt) Mai/]tcw''s case, 5 De G-., Mac. & G. 837 ; Gordon's case, 3 De G. «&
S 249 ; Mafiuirv'scasc, 3 DcG. & S. 31 ; Watson v. Hales, 26 L. J., Chanc.
3(il ; Minra,, v. Hush, L. R., G 11. L. 37 ; 12 L. J., Ch. 586.
HUSBAND AND -SVIFE, 437
executed, and laid before the court of directors, and on
their giving their consent to the transfer, the transfer was
registered in the proper book, and the registration indorsed
on the deed of transfer, and the seal affixed to the new
certificate, which was delivered to the transferee, and
certain shareholders had executed transfers of their shares,
but the transfers had not been registered, it was considered
that the practice above njentioned operated to waive the
seven days' notice only, but not the consent of the directors,
and that therefore these intended transferors were still
shareholders {b).
Under the Companies Act, 1862, executors of a deceased Executors.
holder, so long as the shares remain untransferred, are
liable to be made contributories as executors (c), and are
also liable as executors for calls in respect of the shares
held by the deceased {d).
By the Companies Act, 1862, s. 24, also, it is enacted
that a transfer of a deceased member's share in a company
formed under that act, made by his personal representative,
is to be of the same validity as if he had been a member at
the time (c).
Husband and Wife. — Where a wife having separate Husband and
estate contracts to take shares in her own name and on the
credit of such separate estate, and there is nothing in the
company's deed of settlement to exclude married women
becoming shareholders, she will, on the company being
woimd up, be liable to be placed on the Kst of contribu-
tories in her o^^^l right, so as to bind her separate estate (./').
It would seem, however, that the husband also would be
liable to be put on the list, unless by the company's rules
the husband is excluded from being a shareholder in
(J) Ih re Roi/al British Bank, 26 L. J., Chanc. 545.
(e) See BaircVs case, L. R., 5 Ch. 725.
(d) See Baird's case, supra; Souldswortk v. Evans, L. E., 3 H. L. 2G3.
See sect. 76, Table A. (12.)
[e) See London and Provincial Telegraph Company, L. E., 9 Eq. 653.
(/) In re Leeds Banking Company, Ilathewman'' s ease, L. R., 3 Eq. 789.
See, however, Pugh's case, L. E,., 13 Eq. 566 ; 41 L. J., Ch. 5S0.
438
SHARES, CALLS AND SHAREHOLDERS.
As to a mar-
ried woman's
property in a
joint-stock
company.
respect of the shares held by his wife, and the wife has,
with the knowledge of the company, been accepted as
shareholder without any intervention on the part of her
husband {(j) . A husband may also be made liable where
his wife has purchased shares, even although he was not
aware of the purchase, and declined all along to sanction
ii{h).
By the Married Women's Property Act, 1870, s. 4 (/),
" Any married woman, or any woman about to be married,
may apply in writing to the directors or managers of any
incorporated or joint-stock company that any fully paid-up
shares, or any debenture or debenture stock, or any stock
of such company, to the holding of which no liability is
attached, and to which the woman so applying is entitled,
may be registered in the books of the said company in the
name or intended name of the woman as a married woman
entitled to her sej)arate use, and it shall be the duty of
such directors or managers to register such shares or stock
accordingly, and the same upon being so registered shall
be deemed to be the separate property of such woman, and
shall be transferred and the dividends and profits paid as
if she were an unmarried woman ; provided that if any
such investment as last mentioned is made by a married
woman by means of moneys of her husband without his
consent, the Court may, upon an application under section
nine of this Act, order such investment and the dividends
and profits thereon, or any part thereof, to be transferred
and paid to the husband."
Spiritual
persons.
Spiritual Persom. — With regard to persons who may be
members of banking companies ; the trade or business of
banking was held to be witliin the 57 Greo. III. c. 99,
"w^hich restrained spiritual persons from being occupied in
[g) Sec ZiKird's case, 1 D. F. & J. 633 ; Xcss v. Angas, 3 Ex. 805 ;
Buckley, p. 66 ; but see In re Loudon, Bombay and Jlaliierranean Bank,
18 Ch. D. 581.
(/() Svarsbrick'scasc (Eur: Arb:), L. T. 137.
(<•) 33 & 34 Vict. 0. 93.
CALLS. . 439
any trade or dealings; and in the ease of Hall v.
Franlilyn (J), this disability was held to extend to banking
partnerships under 7 Greo. IV. c. 96, in which two of the
partners happened to be clergymen.
Contracts with banking copartnerships, however, of more
than six persons were rendered valid, although there might
be clergymen among the shareholders or partners, by an
act (A-) which was shortly afterwards repealed, but was
substantially re-enacted by the 4 Vict. c. 14, by which
clergymen may be members, partners, or shareholders in
these copartnerships, but cannot be directors, or managers,
or take part in person in the business. But the law
remains the same with regard to the disability of clergy-
men being partners in private banks.
Calls. — The deed of settlement constituting a banking
company, and the articles of association, provide for the
making of calls by the directors. The particular provi-
sions in this respect should be strictly observed, or other-
wise the calls may be invalid and incapable of being
enforced. It is a usual provision that shares cannot be
transferred while the calls remain unpaid on the shares.
Payment of a deposit on an application for shares, or an
allotment, is not a call. A call cannot properly be made
until shares have been allotted (/). A call made in pur-
suance of a deed of settlement of a banking company,
under the 7 Geo. IV. c. 4G, was held payable before the
simple contract debts of a testator {m). And under sect. 16
of the Companies Acts money due by way of calls is to be
deemed to be in the natm-e of a specialty debt (n).
{J) 3 M. & W. 259, 268. The 57 Geo. 3, c. 99, was repealed by 1 & 2
Vict. c. 106, s. 1 ; but the prohibition against clergymen trading is re-
enacted by sect. 29.
(k) 1 Vict. c. 10.
{l) Croskcy v. Bank of Wales, Limited, 4 Giff. 314 ; 9 Jur., K S. 595.
[in) Henderson v. GUeJnist, 17 Jiir. 570.
(«) 25 & 26 Vict. c. 89, s. 16. See Snek v. Eobson, L. R., 10 Eq. G29,
631 ; 39 L. J., Ch. 821. Priority of specialty debts in the administration
of assets of a deceased person is now abolished, see Judicature Act, 1875,
s. 10.
440 SHARES, CALLS AND SHAREHOLDERS.
Where the deed of settlement of a banking company
defined a shareholder and member to mean the owner of a
share or interest in the capital of the company, and pro-
vided that the shares should be transmissible to personal
representatives, but that no executor should, as such, be a
member, but that every executor might either sell his
testator's shares, or constitute himself a member in respect
of them by a mode pointed out by the deed, and that the
directors might declare the shares forfeited, in case execu-
tors did not constitute themselves members, and the deed
provided for the payment of calls by shareholders, and a
transferee of shares, having covenanted in the transfer deed
with the trustees of the company to perform the stipula-
tions of the deed of settlement, died, and his executor took
no step to become a member : in a suit in equity against
the executor, it was held that the company was entitled to
prove as creditor in respect of a call made after the
death ; for, that under the provisions of the deed, executors
were placed in the position of holders of shares in the
company, although not having all the rights which be-
longed to an owner of shares (o) .
"Where shares were specifically bequeathed to infants,
and were transferred into the names of the executors of the
will, and several years afterwards a call was made, it was
held that it must be paid by the legatees, and not out of
the testator's residuary estate (;j). The question whether
a specific legatee of shares or the residuary estate is liable
to calls depends iipon whether the calls are actually made
before the shareholder's death. A testatrix bequeathed
shares in a banking company ; before her death three calls
were authorized at stated intervals, but she died before two
of the periods : it was held, under the circumstances and
from the practice of tlie company, tliat tlie calls were not
to be considered as really made, until a call letter had been
(o) Ilciiard v. V'hcalln/, 3 Dc G., Mac. &: G. G28. Sec Baird's casej
L. B., 5 Ch. 725; Uonldsworth v. Evav^, L. R., 3 H. L. 263.
(;;) Armdrong v. Bimictt, 20 Bcav. 421 ; 21 L. J., C'hauc. 173.
CHARGING SHARES. 441
sent to the shareholders, and as to those sent after her
death, the specific legatee, and not the residuary legatee,
must bear the calls ((/). But it has been said, that the
right principle is, that if any payments were necessary at
the testator's death to constitute him a complete share-
holder, they must be borne by his estate ; but if he was a
complete shareholder, all calls made after his death ought
to be borne by the specific legatee (;■).
A shareholder in a banking company, established under
the 7 Geo. IV. c. 46, devised his real estates and appointed
an executor. The dividends were paid to the executor, and
the shares continued in the name of the testator. After
the lapse of eleven years, the company being in com^se of
winding up, the testator's estate, including his devised
realty, was held liable for the amount of unpaid calls (s).
Charging Shares. — Shares in a banking copartnership
are shares in a public company, chargeable by a judge's
order, on a judgment being recovered against the pro-
prietor of them, within the 14th section of the 1 & 2 Vict.
c. 110, which empowers a judge at chambers to grant an
order charging shares in public companies, whether incor-
porated or unincorporated, provided that no proceedings
shall be taken to have the benefit of such charge, imtil
after the expiration of six calendar months from the date
of the order. The effect of the charge by the order is the
same as if the judgment debtor had himself charged the
shares {t).
3 & 4 Vict. c. 82, s. 1, enacts, that the provisions of the
previous act shall be deemed to extend to the interest of
any judgment debtor, " whether in possession, remainder
{q) Adams v. Fcrich, 26 Beav. 384 ; 28 L. J., Chanc. 514.
\r) Baxi V. Bay, 1 Drew. & Sm. 261 ; 29 L. J., Chanc. 466, per Kin-
dersley, V.-C. See Bevan v. Waterhead, 3 Ch. D. 752.
(a) Turquand v. A'irl»/, L. R., 4 Eq. 123.
[t) 1 & 2 Vict. c. 110, s. 14; per Parke, B., Graham v. ConncU, 19
L. J., Exch. 362.
442 SHARES, CALLS AND SHAREIIOLDEllS.
or reversion, and whether vested or contingent "(?^), as
well in any such stocks or shares as aforesaid, as also in
the dividends, interest, or annual produce of such stock,
&c. {v).
In an action, under 1 & 2 Vict. c. 110, s. 15, for per-
mitting the transfer of shares after notice of a charging
order nisi, and before the making of it absolute, it is a good
answer to show that the judgment debtor in whose name
the shares stood had no beneficial interest in them («•) .
A charging order when made absolute operates as from
the date of the order nisi, and binds the stock charged as
from that date (.r).
Shares may be charged by a judge's order, under the
1 & 2 Yict. c. 110, s. 14, with a judgment debt, although
the deed of settlement of the company provides, " that the
shares should not be transferable, except by the consent of
the directors :" and " that if any order or decree was
made against any proprietor, by which his shares became
charged, they should be forfeited to the company." This
appears, from a case where the company was empowered
to sue and to be sued by a public officer, vmder the 7 & 8
Yict. c. 113, s. 47, and where the Court of Exchequer,
holding it to bo somewhat doubtful, whether the body
was a "public company" witliin the meaning of the
1 & 2 Vict. c. 110, s. 14, refused to set aside the order
which had been made (y). However, the same company,
the Union Bank of London, has since been held by Lord
Cranworth, V.-C, to be a public company, within the
(«) See Craffff v. Taylor, L. E., 2 Ex. 131, as to wliat lias been held a
contingent interest within this enactment, and see also JJakcr v. Ti/iitc, 2
E. &E. 897.
(i') An order under these acts may be made by any divisional court or
any judge, Jud. Acts, Ord. XLVI. r. 1, who must also for tlic future
recognize equitable rights incidentally appearing, Jud. Act, 1873, s. 21,
subs. 4.
(«•) GUI V. Continental Gas Cowpamj, L. E,., 7 Ex. 332 ; Coates' case, 35
L. T. G17.
(x) Hale V. Barn/, L. R., 3 Ch. 452.
(V) Gra/iam v. Council, 19 L. J., Exch. 364 ; 1 L., M. & P. 438,
CHARGING SHARES. 443
1 & 2 Vict. c. 110, s. 14 {z), and it may bo considered
to be clear, that shares in similarly-constituted com-
panies are chargeable with judgment debts of the pro-
prietors.
Hence shares in all copartnerships, formed under the
7 Geo. IV. c. 46, are chargeable; for the 7 & 8 Vict,
c. 113, s. 47, which is still in force (a), dii-ects all judg-
ments, orders and decrees to be enforced in like manner as
is provided with respect to such companies carrying on
business hcyond sixty-five miles from London, and the
shares of companies carrying on business u-ithin sixty-five
miles from London have been decided to be chargeable, it
is evident the others are so also ; or, in other words, all
shares in these co-partnerships are chargeable. The regis-
tration of banking companies under the Companies Act
of 1862, constitutes them as well public as incorporated
companies, and consequently the shares of the proprietors
will be chargeable under the 1 & 2 Vict. c. 110, s. 14, and
3 & 4 Vict. c. 82, s. 1 (^').
{z) M'Intijre v. Connell, 1 Sim., N. S. 225; 20 L. J., Claanc. 284; 15
Jur. 529 ; see XichoUs v. Eoseivarnc, 6 C. B., N. S. 480.
(«) 25 & 26 Vict. c. 89, s. 205, Tliircl Schedule, 2nd Part.
[h] As to a banker's lien on shares, and as to the law relating to shares
deposited with him by way of equitable mortgage, see pp. 163 ct scq.
( 444 )
CHAPTEH L.
DIRECTORS.
Qualification. — It is frequently prescribed in the articles
of association of a company that the taking of a minimum
number of shares shall be necessary to entitle a person to
hold the office of director ; and questions frequently arise
as to how far the acceptance of such an office amounts to
evidence of an agreement to take shares under section 23
of the Companies Act, 1862. The following passage, taken
from Mr. Justice Lindley's book on Partnership [a), will
help to summarize the law on this subject : — " Where,"
he says, " by the constitution of the company a quali-
fication is necessary to enable a person to hold the office
of director, the acceptance by a person of that office,
with knowledge that a qualification for it is necessary,
justifies the inference that he has agreed with the com-
pany to obtain the shares necessary to qualify him to fill
the office ; and if he has not obtained such shares from
some other quarter, and shares necessary to qualify him
have been registered in his name, he will be a contri-
butory in respect of them, although he may not actually
have applied for them, or known of their allotment to
him. Moreover, a person who accepts the office of director,
and acts as such, must be taken to know whether any
qualification for the office is necessary or not ; and such a
person cannot, therefore, repudiate shares allotted to him
and registered in his name in order to qualify him" {a).
But where, on the other hand, he neither knows of the
existence of any such qualification, and does not act as
{a) See p. 1387 ; Miller's case, 3 Cli. D. GGl ; EincarcVs case, L. R., 11
Eq. 192; Fouicr's case, 14 Eq. 316; Ilarwanl's case, L. R., 13 Eq. 30;
41 L. J., Ch. 283 ; sec Buckley, p. 40. Tlioro is no presumption of law
however, that a director knows the contents of the books of the company.
llallmark'n case, 9 Ch. Div. 329.
POWERS. 445
director, or take shares, lie is not as a general rule liable
as a contributory (/>).
Powers. — In inquiring as to tbe authority, powers, and
liabilities of directors of a banking copartnership, it will
be proper, in the first place, to premise that, in construing
a deed of settlement or articles of association of one of
these copartnerships or companies, the Court will, while
collecting the extent of the authority intended to be con-
ferred on the directors, construe it with reference to the
nature of the business to be transacted, and the purposes
contemplated, in order to judge what powers and authori-
ties the law will imply from the nature of the office, and
how far those powers and authorities are enlarged or re-
stricted by any of the provisions of the instrument (c).
A company is bound by the acts of its directors, pro-
vided such acts are within the scope of theu" real or
apparent authority. All persons dealing with banking
companies must ascertain the limitations imposed by the
deed of settlement, statute or articles of association, but
they are not bound to draw any but direct or obvious
inferences from the provisions they find there, nor is there
any obligation cast upon them to see that such directors
have been properly appointed, or that they have acted
exactly in accordance with the manner prescribed there-
in (^). Should the person, however, have knowledge of the
irregularity, the company, it need hardly be said, will not
be bound {e).
Where the deed of settlement of a banking company
expressly invested the directors with full power and autho-
(5) Lindley, p. 1387. Marquis of Abercorn'' s case, 4 De G., F. & J, 78 ;
Brown's case, L. E., 9 Ch. 102.
{c) jBa)ik of Australasia V. Breillat, 6 Moore, P. C. 190; 12 Jur. 189.
See also, as to the general principles governing the powers of directors,
Spackman v. Eimns, Xi. R., 3 H. L. 171, 244.
{d) Eoijal British Bank v. Tnrqmml, 5 E. & B. 240 ; 6 E. & B. 327 ;
County Life Assurance Companij, L. R., 5 Ch. 288 ; Mahoney v. East Holy-
ford Miniug Compan}/, L. E.., 7 H. L. 8G9 ; Bank of Australasia y. Willan,
L. R., 5 P. C. 417.'
{e) Iri-ine v. Union Bank of AudraUa, 2 App. Cas. 366 ; 46 L. J., P. C. 87.
446 DIRECTORS.
ritj to superintend, order, conduct, regulate, and manage
all and singular the affairs and business of the company, to
the best of their discretion and judgment, and provided
that the board of directors should, and lawfully might,
from time to time, devise and make such provisions, rules,
orders, and regulations, touching the government, carrying
on, and management of the affairs of the company, the
same not being repugnant to the general rules and regu-
lations in the deed contained, as they should think ex-
pedient, and that the concern should continue for 100
years : it was held, that the directors had the powers of
managing partners in an ordinary banking partnership,
amongst which was the power of borrowing money for the
purpose of discharging the existing liabilities of the bank,
till the assets could be realized ; and of discontinuing the
bank, if they thought such a step essential to the interests
of the shareholders ; and that their having raised a loan
which they had undertaken to repay, and accompanied the
engagement with other stipulations, some of which were
ultra fires, did not discharge the bank; the only effect
being, that such stipulations could not be enforced {g).
But it seems hardly necessary to point out, that directors
of a banking copartnership, whether with or without the
consent of the majority of the shareholders, have no autho-
rity to convert their banking company into a company for
different purposes : and that money borrowed for the pur-
pose of effecting that transmutation, with notice on the
part of the lender, will not constitute a debt of the com-
pany, for the recovery of which it can be sued (//).
Nevertheless, dii'ectors may, undoubtedly,, at their dis-
cretion, either discontinue altogether the business of the
concern, or restrict the business to certain portions of that
in which it was originally intended the bank should em-
ploy its funds, if tlioy think such steps essential to the
interests of the shareholders. Such a power seems neees-
{g) Bank of Australasia v. DrciUat, G Moore, P. C. 152.
(//) G Moore, P. C. 197.
POWERS.
447
sarilj implied in the exclusive power of management, and
in the power of determining what transactions should be
entered into, what notes issued, what deposits received,
what bills discounted, or loans made (/).
The deed of settlement of a banking company provided,
that when one-fourth of the capital was lost, the directors
should call a meeting, and the company should be dis-
solved. Considerably more than one-fourth of the capital
was lost, and a meeting was called, at which the share-
holders resolved to continue the bank. Further losses
were made, but no such meeting was called again, but as
the shareholders knew that the bank was going on after
more than one-fourth of the capital was lost, the directors
were not liable for continuing the bank (/ ) .
But, though directors may restrict, it does not seem
that, even with the sanction of a majority of the members,
they have the same power to extend, the business ;
e. g., if the copartnership were constituted to carry on
banking business in England, they could not extend the
business to India or the colonies (A-). In articles of asso-
ciation, however, ample powers are now generally reserved
to directors for establishing branch banks in defined loca-
lities and extending agencies, as well as for amalgamating
with other companies, and pui'chasing other businesses
within the objects contemplated by the memorandum and
articles of association (/). Although the directors of a
banking company may be empowered by the articles of
association to purchase or acquire the business of any other
company, and to amalgamate with any other company
can-ying on business with similar objects, such amalga-
mation is not binding upon shareholders who do not assent
to the arrangement, as neither the 161st section of the
Companies Act of 1862 (;;?), nor any such provision con-
(j) 6 Moore, P. C. 198.
\j) Tnrqitand v. Marshall, L. R., 4 Ch. 37G.
{k) See 10 Hare, 54, 55, Gl.
{I) See Simpson v. Westminster Falace Hotel Company, 10 H. L. Cas. 712.
\m) 25 & 26 Vict. c. 89.
448 DIRECTORS.
tained in the articles of association, can have tlie effect of
authorizing the directors to render their shareholders liable
for the engagements of another company (ii) .
But in articles of association, incorporating a banking
company, the directors will not be authorized in changing
materially the nature of the objects of the company as pro-
posed in their prospectus (o).
The following case illustrates, in some degree, the ques-
tion of the nature of the business that is within the scope
of banking copartnerships : —
A deed of settlement of a banking copartnership pro-
vided that the directors should not be fewer than five or
more than seven ; that three, or more, should constitute a
board, and be competent to transact all ordliuiry huniness;
that the directors should have power to compound for any
debt owing to the company, and accede to and execute any
deed of composition, or conveyance, or assignment of his
estate or effects, made by any debtor of the company,
whether a shareholder or not, for the benefit of his creditors,
and to give time to any debtor for the payment of his debt,
either upon or without security ; and to abandon any debt
which might seem bad or desj^erate.
A. had purchased of the bank a colliery, of which they
were mortgagees, for a sum, of which he had paid part in
cash and for the balance had accepted bills which had
been renewed, and of which some were in circulation, and
others overdue, in the hands of persons with whom they
had been negotiated by the company. He was also
largely indebted to the company on the balance of his
account current. Afterwards the nimiber of directors
having become reduced to f om*, these four executed a deed,
compounding the debt on the account cui-rent and for the
(w) In re Bank of ITindiidan, Cliina and Japan, Limited, IUggs' case, 13
W. R. 937 ; 2 H. & M. GGG ; Ex parte Bafishaive, L. E.., 4 Eq. 341. See
Bank of Hindustan v. Alison, L. R., 6 C. V. 54, 222.
(o) In re Scottish and Unirnsnl Finance Bank, limited, iS/iip\i case, 13
"W. R. 450; aftinncd on appeal, 2 De G., J. & S. 544. Sco Uounes y.
/Ship, L. R., 3 II. L. 313.
CONTRACTS UNDER THE COMPANIES ACTS. 449
remainder of the purchase-money, on payment of 1,000^.
by A., and his agreeing to abandon the colliery to the
bank ; the directors also covenanted " on behalf of the
company, so far as they could lawfully bind the company,
but not further or otherwise," to indemnify A. against all
such bills of exchange as had passed through the com-
pany's hands.
A. brought an action for not indemnifying him, when it
was held that the covenant did not bind the copartnership ;
for that this was not ordinary business; and no smaller
number than five directors were competent to transact it ;
and it was made a question whether a board of three
directors could transact even ordinary business, unless it
was a board of three out of five directors (7^).
Contracts under Companies Act. — Banking companies
incorporated under the Act of 1862, whether as limited or
as unlimited companies, were legally bound only by con-
tracts made by deed under their common seal ( (7). But
since the Companies Act, 1867 (>•), s. 37, (1), any contract
which, if made between private parties, would be by law
required to be in writing, and if made according to Eng-
lish law to be under seal, may be made on behalf of the
company, and such contract may be in the same manner
varied or discharged; (2), any contract which, if made
between private persons, would be by law required to be in
writing and signed by the parties to be charged therewith,
may be made on behalf of the company in writing, signed
by any person acting under the express or imphed autho-
rity of the company, and such contract may be varied or
discharged; (3), any contract which, if made between
private parties, would by law be valid, although made by
parol only, and not reduced into writing, may be made by
{2)) Eirh X. Bell, 16 Q. B. 290. See also Mahoney v. East Hohjford
Mining Compamj, L. R., 7 H. L. 869 ; 33 L. T. 383.
{q) McArdhi v. Irish Iodine Companf/, 15 Ir. C. L. Rep. 146.
(/■) 30 & Sl'Vict. c. 131 ; Stvift V. Wintcrhofham, L. R., 8 Q. B. at p.
251 ; Beer v. London and laris Hotel Company, L. R., 20 Eq. 412.
G.
G G
450
DIRECTORS.
Bills and
notes drawn
by directors.
Neoflisrence.
Fraud.
parol on behalf of the company by any person acting
nnder tlie express or implied authority of the company,
and such contract may, in the same way, be varied or dis-
charged. And all contracts made according to the above
provisions will be effectual in law, and be binding upon
the company and their successors, and all other parties
thereto, their heirs, executors or administrators, as the case
may be.
Bills and Notes. — Bills and notes drawn by directors on
behalf of a company should appear on the face of them to
be drawn on its behalf, for if there is nothing on the
note or bill itself to exclude their personal liability they
will be held liable. The fact that the company's seal
has been affixed is not sufficient to exclude their personal
liability {s) .
By the Companies Act, 1862 {t), s. 42, directors of a
limited company are liable to a penalty of 50/., if they
sign or authorize to be signed on behalf of such company
bills of exchange, promissory notes, &c., wherein its name
is not mentioned as in the manner prescribed in the act.
Register of Mortgages, s. 43. — Bankers do not stand in
the position of officers of a company for the purposes
mentioned in this section (»).
Negligence. — In order to make directors personally liable
for imprudence in the exercise of powers conferred upon
them, it must appear that such imprudence was so great
as to amount to crassa negligentia (.r).
Fraud. — Directors of a company, like other agents, will
be compelled to make good the truth of their representa-
tions, if they induce persons to deal with them by means of
(«) Dutton V. Marsh, L. R., G Q. B. 361.
(0 25 & 20 Vict. c. 89, s. 12. ante, p. 409.
(«) Kx parte Xat'wnal Banh, L. R., 14 Eq. 507, 515. See ante, pp. 415,
41G.
(.r) Ovcnwl, nurncij ^- Co. v. Oibh, L. R., 5 11. L. 480.
APPROPRIATING SHARES, 451
untrue representatious as to matters of fact. This rule,
however, does not apply to representations as to matters of
law {y). A director of a company is not liable for fraud
(such as the issue of a fraudulent prospectus), committed
by his co-directors, or by any other agent of the company,
unless he has either expressly authorized or tacitly per-
mitted its commission (s).
Notice affecting Company. — The operation of the acts Notice.
of parliament, relating to copartnerships established under
the 7 Geo. IV. c. 46, is such as to render them qium
corporations to this extent, that notice to one of the
members, or even to one of the directors, provided he
has, by the constitution of the company, no share or con-
trol in the management of the accounts of the company,
is not notice to the company {a). So knowledge of a
particidar fact relating to the accounts by one director of
a banking company, is not notice to the company, where
that director has no voice in the management of the
accounts, and the money transactions of the company are
conducted exclusively by a manager under three directors,
of whom the director possessing the knowledge is not
one (6). But where one of the directors is clad with
authority to act on behalf of the company, notice of mat-
ters coming within the scope of that authority is notice to
the company (c).
Approimating Shares. — A transaction entered into by
du-ectors, as the appropriation to themselves of shares,
may be incapable of being sustained (having regard to the
(v) Beattie v. Lord Ebnnj, L. R., 7 Ch. 777; 41 L. J., Clianc. 804 ; 27
L. T. 398; Feck v. Gimiey, L. R., 6 H. L. 377; 43 L. J., Chanc. 19;
22 W. E. 29. As to what amounts to frauckJent knowledge, see JFeirx.
Bell, 3 Ex. D. 32, 238 ; 47 L. J., Exch. 704.
{z) Cargill v. Bower, 10 Ch. D. 502 ; 47 L. J., Chanc. 649; 26 W. R.
716; Wcir\. BcU,svvpva.
{(() rouch V. Page, 3 C. B. 25 ; 15 L. J., C. P. 217.
[b) In re Carcw, 31 Beav. 39.
(c) British and American Telegraph Companij v. Albion Bank, L. R., 7
Ex. 119; 41 L. J., Exch. 67; £x parte Agra Bank, L. R., 3 Ch. 555.
G G 2
DIRECTORS.
provisions of tlie deed of settlement or tlie principles of
equity governing the administration of trusts) as a trans-
action binding on the company, unless brought before the
shareholders and confii-med by them; yet, nevertheless,
the directors by the transaction, although not confirmed
and notwithstanding the irregular nature of it, may bo
bound as between themselves and the company.
Thus, a director in a banking copartnership had regu-
larly, before 1840, become owner of twenty shares, which
number of shares each director was by the deed of settle-
ment obliged to hold, as a qualification for the office. The
deed of settlement provided, that the shares of the com-
pany should be vested in the coui-t of directors, who should
have full power to allot, appropriate, reserve for, or dispose
of the same, to such parties, and upon such terms, and in
such manner, as they might think fit : and that the execu-
tor of any proprietor should not, as such, be a proprietor
in respect of such shares, but he should be at liberty to
dispose of them ; or the company might, upon an executor
giving notice, and complying with the provisions of the
deed, permit him to become the proprietor, and personally
chargeable.
The directors, on the 7th of August, 1840, resolved,
without the privity of the shareholders, to appropriate to
themselves a certain amount of additional shares— or, as
they called them, " credit shares"— for wliieh they were
severally to pay, by giving their promissory notes, payable
to the trustees of the bank, for the amount for which each
subscribed.
A director agreed to take (and he gave a promissory
note in payment for) one hundi-ed of these shares; he also
signed a letter binding himself to pay the deposit and calls
on them, but did not execute the deed of settlement in
respect of them. He died in 1848, eight years after the
giving the promissory note, never having paid any interest
on, or any part of the principal of, the promissory note; in
the books of the company, however, credit was given to
APrROrRIATlNG SHARES. 453
liini in respect of dividends on the credit shares, and he
was charged with interest on the promissory note.
His executor was held to be rightly placed on the list of
contributories, not only in respect of the twenty shares,
but also in respect of the one hundred " credit shares,"
although the creation of the " credit shares " was not war-
ranted by the deed, nor were they, in fact, ever issued or
allotted.
The directors, it was said, " clearly were not entitled to
allot to themselves a very large proportion of the capital
of the company without bringing in a single shilling in
aid of that capital, only giving promissory notes, payable
at some distant period, debiting themselves with interest,
as it became payable on their several notes, and taking
credit for the dividends to which they would properly
have been entitled if they had actually made the pay-
ments" {(().
In another case, which arose under the same deed of
settlement, a director was regularly owner of twenty shares ;
he, subsequently, in pursuance of the resolution of the
court of directors, took five hundred of the credit shares
and gave his promissory note, payable in five years, for the
amount ; he also signed a letter binding himself to pay the
deposit and the calls, but did not execute the deed of
settlement in respect of the five hundred shares. Three '
months after this he died. Within one month of his death
his executors applied to the directors to ascertain the ex-
tent of his interest in, or liability to, the company. In
answer they were informed, on behalf of the directors,
that their testator held twenty shares. These were, there-
upon, duly transferred to a purchaser, and the directors
afterwards cancelled the five hundred sliares, and the pro-
{d) Ex parte Bobinson, 2 De G., Mac. & G-. 517, 520. Por cases where
persons have been put on the list of contributories, notwithstanding that
certain formalities rendered necessary by the deed of settlement or articles
of association have not been complied with, see Bunh's casr, L. R., 6 Ch.
246; Murray v. Bush, L. R., 6 II. L. 37; 42 L. J., Ch. 586; Keene's
Executors' case, 3 De G., M. & G. 272.
454 DIRECTORS.
missory note for tlie amount. Eight years after tlie death
of the testator, it was held that the executors ought not
to be placed upon the list of contributories, for, although
his estate might have been bound, if the claim had been
promptly asserted at the instance of the shareholders, yet,
that so long after the distribution of his assets, the loss
arising from the misrepresentation of the directors must
fall upon themselves and the company and not upon the
estate {c).
The same deed of settlement further provided and re-
quired that the capital of the company should be one
million sterling, divided into 20,000 shares of 50/. each,
and that the proprietor of each share should bring in and
pay to the company the full sum of 50/. in respect of such
share, as and when called upon so to do, in manner there-
inafter {i. e. in the deed of settlement) provided. The
Court, therefore, gathered the intention of the parties to
the deed to be " that all the shares should be actually boud
fide subscribed for as upon money payments, depending
no doubt upon the periods when the directors should
think it right to make calls (/).
The clause, that the directors were to appropriate or
reserve shares, the Court thought might be considered,
perhaps, as giving power to the directors " to appropriate
or reserve," not in terms, but in substance, for f/iei/isclrcs
and their friends, the whole of the shares ; the words are,
" to such parties, and upon such terms as they shall think
fit," which rather looked as if they were to deal with third
parties ; but, whoever might take them, the shares could
only be taken subject to a general liability to pay for
them as a money transaction, altliough tho payment was
to be deferred, in the shape of calls, till wanted {(j).
The whole amount of the " credit shares" taken by the
directors formed an enormous sum in the aggregate, and a
{e) Metix's case, 2 Do G., Mac. & G. 522.
(/) 2 De G., Mac. & G. 529.
() Ibid.
PURCHASE OF SHAKES. 455
very large proportion of the entire capital mentioned in the
deed of settlement.
Notwithstanding, however, that the deed conferred such
large powers, the Court treated the conduct of the directors
as a fraud upon the general body of the shareholders : for
the directors were aware, that without the aid of the ficti-
tious capital represented by these " credit shares," there
was no other way, in which it was possible for the concern
to have gone on {/i).
If, for instance, at the first meeting of the shareholders,
the directors had only represented the capital which was
actually paid up, this company, it is clear, must have
stopped at once, and, in that case, the dii-ectors would have
lost all their power and fancied benefit.
When, therefore, shareholders execute deeds of settle-
ment, or articles of association, giving " full power to the
court of directors to allot, appropriate, reserve for, or dis-
pose of the shares to, such parties, and upon such terms,
and in such manner as they may think fit;" the measure
is one which the shareholders ought to be fully impressed
with the importance of, conferring, as it seems to do, so
vast a power upon the body of directors.
Purchase of Shares. — Unless the memorandum and arti-
cles of association contain in plain terms an express power
to purchase their own shares, the purchase is ultra vires,
although the company may be empowered to deal in shares
of joint stock companies generally ; and therefore, when
the broker of the banking company, acting under the in-
structions of the directors, bought shares in the company
on behalf of the company, and was credited with the price
paid by him for the shares in his banldng account kept
with the company, on the company being wound up the
broker was not entitled to prove against the company for
so much of the balance due to him as represented the price
of the shares {i).
[h) 2 De G., Mac. & G. 529.
(j) In re London, Hamburg and Continental Exchange, L. R., 5 Ch. 444;
DIRECTORS.
If a sale of shares by members of a company to the
directors on behalf of the company is sanctioned by a
majority at a general meeting, even assuming the trans-
action to be ultra vires or improper, an acquiescence of
six years on the part of the dissentient shareholders will
preclude them from impeaching it (/).
Approval of
transfer of
shares.
Approval of Transfer of Shares. — The distinction between
a banking copartnership and an ordinary trading partner-
ship consists in the power and privilege which, by the
provisions of the deed of settlement of the former, are
given to a proprietor to retire and withcbaw his capital
from the concern, without a dissolution of the partnership,
by transferring his shares. This power and privilege con-
stitute very many inducements to the investment of capital
in such concerns, and thereby enable the society, or part-
nership, to raise a capital and carry on transactions which
it would be impracticable to raise, or cany on, upon the
basis of an ordinary mercantile partnership. The conse-
quences which, as between a shareholder and the company,
arise, by operation of law alone, upon a transfer of shares
cannot, therefore, be inferred, from those which attach
upon the dissolution of an ordinary partnership. The con-
sequences arising upon a transfer of shares must be sought
for in the provisions of the deed of settlement, or articles
of association, or in some rule of law not repugnant to
those provisions.
As dii-ectors cannot sell their right, given by the deed
of settlement, of objecting, on behalf of the company, to
any proposed transfer of shares, so tliey cannot exercise
the right of giving tlieir sanction to such proposed transfer.
Land Credit Company of Inland v. Fermoy, L. R., 8 Eq. 7 ; 5 Ch. 763 ;
£x parte Credit Fonticr, L. R., 7 Ch. 164 ; Hope v. Interiiaiioiial Financial
Society, 4 Ch. D. 727; SneWs ease, L. R., 5 Ch. 22 ; In re Dronjield Silk-
stone Coal Company, 17 Ch. D. 76.
(*) Gregory v. Fatcliett, 10 Jur., N. S. 1118. See as to acquiescence,
Fhosphate of Lime Company v. Green, L. R., 7 C P. 43 ; Irvine v. Union
Bank of Australia, 2 App. Cas. 366 ; 46 L. J., P. C. 87 ; In re Dronfield
Silhstone Coal Company, supi'a.
APPROVAL OF TRANSFER OF SHARES. 457
for the pui|)Ose, and upon tlie condition, of obtaining pay-
ment of a debt abeady due to the company from the in-
tended transferor of the shares (/•).
Where articles of association prescribe that the company
may decline to register any transfer of shares whilst a
shareholder is indebted to the company, or unless the
transferee is approved of by the directors, the directors are
not warranted in arbitrarily refusing to register the trans-
fer, if the shareholder is not in point of fact indebted to
the company (/).
A power in the articles of association of a bank to decline
to register any transfer of shares unless the transfer is
approved of is not to be arbitrarily exercised. The
board in such case is to exercise its discretion in a reason-
able manner (/).
A deed of settlement of a banking copartnership declared,
that no transfer of shares should be permitted, except upon
notice to the directors, and, on the consent of a board of
directors, such consent being signified by a certificate in
■writing signed by three directors, at the least ; if such
consent were refused, the shareholder might require the
directors to buy his shares at the market price of the day.
After a consent given, the name of the transferee was
entered in the share register book, and the entry there was
conclusive against him.
A shareholder proceeded to transfer his shares to
different persons, and sent the proper notices to the
directors ; received back consents signed by three directors ;
and completed the transfers ; the transferees' names were
entered in the share register book ; and, in the return
made to the Inland Revenue, his name was omitted from
the list of shareholders, and inserted in the list of those
(A-) Phd-ctt V. Wright, 2 Hare, 120.
[1) Slee V. Intel-national Bank, 17 L. T., N. S. 425 ; Stranton Iron Coin-
pant/, L. R., 16 Eq. 559; Kr parte Fenni/, L. R., 8 Ch. 446; jUofai v.
Farqiihar, 7 Ch. D. 591 ; 47 L. J., Ch. 355 ; look v. Middlcton, 29'Beav.
646; Robinson v. Chartered Bank, L. K., 1 Eq. 32; Tender v. Lushinr/ton,
6 Ch. D. 70; 46 L. J., Ch. 317.
458 DIRECTORS.
who had ceased to be shareholders. The transferees after-
wards received the regular notices of meetings of share-
holders. The directors, subsequently, sought to impeach
these transfers, on the ground of the notices never having
been submitted to a hoard of directors, nor the consents
given by a hoard of directors, as required by the deed, but
that the consents had been signed by the managing
director, and then signed by two other directors. This
appeared to have been the mode of transacting this descrip-
tion of business ever since the formation of the company.
The House of Lords decided, that the directors could not
set up their own want of observance of the formalities re-
quired by the deed, as a ground on which to fix him with
liability as continuing to be a shareholder, for that they
were bound by their course of dealing («).
It is to be observed, that, on the same facts (except that
the register was excluded), a Court of law had previously
held the same party to remain a shareholder, as against
creditors of the bank, for as there was no consent by a
board of directors, the irregular mode of transfer, though
adopted for some years, was wholly ineffectual and conse-
quently he remained a shareholder, as against such cre-
ditors (o).
The c[uestion before the House of Lords, hoAvever, was
whether the directors could take advantage of their own
laches to comply with the requirements of the deed of
settlement, and treat this person as a member, when, but
for their own conduct, there would have been no pretence
for doing so.
A deed of settlement of a banking company provided
that shares might bo transferred with the consent of the
du-ectors, but that the transfers sliould be registered, and
that an indorsement of the registration should be made on
the deed of transfer, and should bo sufHcient evidence of
the consent of the directors. A shareholder placed his
(w) Bargalc v. Shovtridgc, o II. L. Ctis. 297.
(o) Bosunquct V. fihortridye, 4 Exch. G99.
ENHANCING PRICE OF SHARES. 459
shares in the hands of a broker, and thej were sold nomi-
nally to the solicitor of the company, but really (though
without the knowledge of the shareholder) to the company
itself, the puj-chase-money being paid out of the funds of
the company, and the subsequent dividends being carried
to their credit : it was held that, although there was no in-
dorsement on the transfer to the solicitor, the directors'
consent was sufficiently proved, and that on the company
being wound up, the vendor ought not to be placed on the
list of contributories as a shareholder {'p).
A shareholder executed a transfer of his shares, which he
took, together with the certificate, to the company's office
for registration. He left the transfer, but refused to leave
the certificate for the inspection of the directors, but the
Court would not, under the Companies Act, 18G2, s. 35,
compel the company to register the transfer, as the di-
rectors were legally entitled to satisfy themselves of the
validity of the certificate {q).
Enhancing Price of Shaves. — Directors representing,
with the intent to raise the shares of the company in price,
in their reports, and by their agents, that the affairs of the
company are in a very prosperous state, and declaring
large dividends, at a time when those affairs are greatly
embarrassed, and thereby inducing a person to j^urchase
shares, may be made criminally responsible for their
conduct (r) .
So if directors issue false and fraudulent reports to the
public, and the officers of the bank supply detailed state-
ments for such reports, knowing that they are to be used
for purposes of deceit, and a third person acting on such
reports buys shares in the company and sustains loss
[p) KicoVs case, 3 Do G. & J. 387.
Iq) 33 Beav. 119.
(>•) Burnes v. Fcnndl, 2 H. L. Cas. 497, 509 ; it', v. AxpinaJI, 1 Q. B. D.
730 ; 2 Q. B. D. -IG ; and sec 21 & 26 Vict. c. 9G, s. 31, and post,
Chap. LIII.
460 DIRECTORS.
thereby, all assisting in the fraud are personally liable to
the purchaser, though the report was signed only by the
directors (s) .
The criminal liability of directors and officers for issuing
false reports and balance sheets will be considered in
Chapter LIII.
Surrender of Surrcndc)' of Shares. — Grenerally, directors have no
power to accept a surrender of shares on behalf of the
company. Even where the deed of settlement provides
that in all cases not provided for by that or any other
supplemental deed of settlement the directors may act in
such manner as to promote the interest and welfare of the
company, this does not enable them to cancel a retiring
director's shares, so as to exempt him from liability (/).
But where the deed of settlement or articles of associa-
tion expressly gives such a power to the directors they may
accept a siuTender (?^). A sm'render, also, may become
valid by ratification by the company {x), or by all the
shareholders acquiescing in the arrangement (y).
But the cancellation of shares by du"ectors, where the
shareholder has valid grounds to claim cancellation, is
good and effectual, although the shareholder claimed such
cancellation on invalid grounds, not being at the time
aware of the existence of valid grounds (c), as where there
(«) Cullcn V. Thompson, 4 Macq. H. L. Cas. 431; 9 Jiir., N. S. 85;
Feck V. Gurncy, L. E,., 13 Eq. 79 ; 43 L. J., Ch. 19.
(/) Stanhope s cnsc, 3 De G. & S. 198 ; Spack)nnn v. Erans, L. R.,
3 H. L. 171; M'alkvrs case, 6 Eq. 30; London and I'/wincial Coal Com-
pany, h Ch. D. 52.5. By the Companies Clauses Act, 1863 (26 & 27
Vict. c. 118), s. 9, Avhich applies to all companies liaving a special act
and incorporating that act, it is enacted that a company may from time
to time accei)t, on such terms as they may think fit, surrenders of any
shares Avhiuh have not been fully paid uji. Wee also 40 & 41 Vict. c. 26,
8 5.
' (it) See Gradifs case, 1 De G., J. & S. 488 ; SnclVs case, L. R., 5 Ch. 54 ;
In re Bronfield HUkstone Coal Company, 17 Ch. D. 76.
(.r) Sec Brotherhood's case, 31 Beav. 3G5 ; 8 Jur., N. S. 926; Phosphate
lime Co. V. Green, L. R., 7 C. P. 43.
(y) Smallcombc v. Erans, L. R., 3 H. L. 249; Uonldsworih v. Evans,
ib. 263.
(r) In re London and Mediterranean Bank, L. R., 7 Ch. 55.
FORFEITING SHARES. 461
has been a misrepresentation as to the number of shares
alleged to have been subscribed for (s).
Forfeiting S/iares. — A power to forfeit shares must be Forfeiting
expressly conferred by the deed of settlement or articles of
association, it cannot be implied or inferred {a) . By a
clause in a deed of settlement, it was provided that if a
proprietor became indebted to the company in respect of
cash advances or otherwise, the directors might cancel and
declare forfeited, or sell, his shares, either wholly or in
part, as the case might require, towards the liquidation of
such debt, and such person should thenceforth cease to be
a proprietor. A holder of 1,000 shares being indebted to
the bank for cash advances, a notice was given to him that
unless he redeemed the 1,000 shares by payment of the
balance of his account within fourteen days, the directors
would on that day cancel and declare his shares forfeited,
and would place the value of the shares on that day to the
credit of his account. The balance not having been paid,
the directors passed a resolution declaring the shares to be
cancelled and forfeited. The value of the shares on that
day was considered by them to be 10,000/., and it was
resolved that credit should be given to the proprietor for
that amount in his account. He afterwards filed a bill to
set aside the cancellation. The market price of the shares,
on the day of the resolution, slightly exceeded that allowed
by the directors, although if the shares had been carried
into the market, the price would have been reduced greatly
below tha,t amount. A Court of Equity decided that the
directors having placed themselves in the position both of
vendors and purchasers were bound to allow the highest
market price which could be obtained for the shares, with-
out speculating upon what might have been the effect of
{z) In re London and Mediterranean Bank, L. E., 7 Cli. 55.
{a) Clarke v. Hart, 6 H. L. Cas. 633 ; Hope v. International Financial
Society, 4 Ch. D. 327 ; 46 L. J., Chanc. 200. As to forfeiture of shares
under the Companies Act, 1862, yeo Table A, CI. 17 — 22; and as to
companies governed by 8 & 9 Vict. c. 16, see sects. 29 — 35.
462 DIRECTORS.
tlirowiug tlie 1,000 sliares into the market, and tlie cancel-
lation was declared to be void (h) . The power to forfeit,
where it exists, must be strictly construed (c) .
Paying divi- Fciijinfj Bivulcnds out of Profits. — The payment of divi-
profits!^" ^ dends derived from other som'ces than the profits of the
company is a fraud on the part of the directors : for divi-
dends are supposed to be paid out of the profits onlj^, and
when directors order a dividend to any given amount, they,
without expressly saying' so, yet, impliedly, do declare to
the world that the company has made profits which justify
such a dividend. This is a gross fraud, for whicK they are
liable to be punished.
In case any one, in consequence of sucli uniylied mis-
representations, buys shares, and, it appearing that the
concern is failing, he is injured, he may proceed against
the directors by action ; they are liable, also, to be indicted
in such case : even if no one can be shown to have been
injm-ed, as a matter of strict law, they are liable to an
indictment for a conspiracy (r/).
The directors of a banking company in February, 1864,
issued a report declaring a dividend of fifteen per cent,
upon the shares, and a bonus of ten per cent., and a large
addition to the reserve fund. In June, 1864, they offered
to the shareholders the option of taking (according to the
proportion of shares held by each shareholder) a certain
number of reserved shares at a considerable premium.
The executors of a deceased shareholder accepted some of
these reserved shares. The report of February, 1864, was,
in fact, utterly erroneous, and in September the bank
stopped payment. No evidence of wilfulness on the part
of the directors in misrepresenting the aifau-s of the com-
pany was adduced. The House of Lords held, that there
(i) SiiMs V. Lister, 1 Y. & C. N. C. C. 81.
(c) See Clarke v. Hart, supra ; Johnson v. Lythe's Iron Agency, f) Cli. D.
G87.
(d) liurnes v. Pennell, 2 II. L. Cas. 524, 525; i?. v. AsplnaU, 1 Q. B. D.
730; 2 Q. B. D. 48.
ANSWERING INTERROGATORIES. 463
was not enough on this state of facts to constitute a misre-
presentation to avoid the acceptance of the shares, and so
prevent the executors from being put personally upon the
list of contributories {c).
A bill was filed by a shareholder against directors of a
banking company to restrain them from paying a dividend
ah'eady declared, and from declaring or paying any future
dividends, except out of the profits of the bank, but the
other shareholders were not before the Court. The Court
granted an injunction as to future' dividends, but refused
to restrain the payment of the dividend that had been
declared, on the ground that the declaration of the dividend
gave the shareholders a legal right to the payment of that
dividend, and the Court would not, in the absence of a
representation by all the shareholders, interfere with that
right (/).
Ansicering Interrogatories. — The effect of a compulsory
winding up is to take all control over the affairs of the
company out of the hands of its directors, but they may
still be considered to continue officers of the company, and
may be ordered to answer interrogatories in an action
begun after the commencement of the winding up {g) .
(e) Jackson v. Turquand, L. R., 4 H. L. 305.
(/) Faiccctt V. Laurie, 1 Drew. & Sm. 192.
Ig) Madrid Ba»k v. Baileij, 36 L. J., Q. B. 15.
( 4G4 )
CHAPTER LI.
MANAGER.
Banking copaiinersliips and companies, wliere their busi-
ness is extensive, or branclies are established, appoint
managers. In deeds of settlement of joint stock banks
formed under the 7 & 8 Vict. c. 113, a specific provision
as to the appointment of a manager, or other officer to
perfomi the duties of manager, is necessary [a). That
statute requires the manager to make out, verify, and
deliver to the stamp office, the annual returns of the title
of the company, the names and places of abode of the
members, directors, and manager, and the names and
places of the local banks established by the principal
bank {b). Legal proceedings and notices may be served
upon him (c). The duties imposed by this statute upon
managers of joint stock banks formed under its provisions
and still in operation must be continued to be discharged
by them. The subsequent acts regulating the formation
of banking companies do not specifically require the
appointment of managers. But when these companies
appoint managers, then the penalties which the Companies
Act of 18G2 imposes upon managers of limited banking
companies omitting or neglecting to affix the name of tlieir
company on the outside of its several places of business
and branches, to sign instruments, official documents, and
notices with the seal of the company, to publish the state-
ments of its capital, assets, and liabilities (r/), to notify to
the registrar every increase of the capital of the companj' {f) ,
{(i) Sect. 4, unci ante, pp. 390, 391.
(i) Id. 8S. 16—18, ante, p. 385.
{(■) Jd. s. 43, ante, p. 391.
((/) Ante, pp. 408—415.
(<•) Ante, pp. 409, 410.
DUTIES AND POWERS. 46-5
to keep the register of its members (./'), to make out and
forward to the registrar the annual list of its members and
summary of particulars (/), as required by that act, or
refusing an inspection of the register (g), will be incrn'red
by the managers. It will be their office to attend to the
proper discharge of these different duties.
A manager may carry on a separate business, as a mer-
chant or otherwise, by the permission of the company,
which is, however, unusual, and generally inconvenient;
but by his so doing, he is not entitled to grant himself
the same accommodation in respect of his separate trade,
which he might obtain from an independent banker. It
would be necessary for him, in order to sustain such a
proceeding, to show that he had brought the whole cir-
cumstances most fully and fairly before the directors ; it
would not be enough to show merely that he had not
concealed any thing ; such a proceeding, if the whole had
been brought before the dii-ectors and had been assented
to by them, might be permitted to stand, but only in that
case (h).
A manager of a banking copartnership, then, has no
right to grant himself accommodation out of the funds of
the bank without tlie consent of the directors, given with
a full knowledge of all the circumstances. This, however,
though it will prevent the company from repudiating the
transaction, will, in many cases, as of course, fail to save
them from loss.
Thus, the manager of a branch bank, and also the exe-
cutor of a testatrix, had lent 1,500/. on the security of a
ship. The manager afterwards shifted the security from
this ship to another ship, and in his character of executor
borrowed 1,600/. from the bank, and also lent it to the
owner of the latter ship, and took a mortgage of that ship,
for the 1,500/. lent by the testatrix, and also for the 1,C00/.,
(/) Ante, p. 411.
{o) Ante, p. 413.
{■/i) Gu-aUcin v. Camphdl, 1 Juv., N. S. 131.
G. H n
466 MANAGER,
wliich lie had lent as executor. As security for the money
lent to him by the bank, he, several months after the ad-
vance by the bank, assigned to them this mortgage, and
the mortgage debts. The last-mentioned ship was sold
for 1,150/. In a suit by the residuary legatees of the
testatrix against him and the bank for the recovery of this
sum, the executor was held to have no right to pledge the
assets ; and as he was also the agent of the bank, the bank
was considered as having had notice of his inability to
pledge the assets, and so could stand in no better position
than he did, and the legatees were entitled, in preference
to the bank, to the 1,150/. (/).
Bills. Bilk. — Where a bill is drawn, accepted or indorsed by a
manager of a bank, with the y^foxih per procuration, the legal
eif ect of these words is to give an express intimation to every
one, that the acceptance or indorsement was made under a
special or limited authority, binding every one, therefore,
to ascertain, before he takes such a bill, that the indorse-
ment is agreeable to the authority given, according to a
well-known rule respecting all such acceptances or indorse-
ments. A party taking such a bill, therefore, without
inquiry, if it turns out that the manager accepting or
indorsing exceeded his authority, must suffer for his
temerity {h).
It is customary with many banking companies to com-
municate, by circular to their agents and correspondents,
the fact of the appointment of their manager, and his
authority to sign drafts on their account, with a specimen
of his handwriting.
A promissor}^ note, to secure an account at a branch
bank at Birmingham, of a banking copartnership, called
(i) CoUinsonv. Lister, 25 L. J., Chanc. 38; 20 Bear. 356; 7 De G.,
Mac. & G. 634. As to a manager suing for percentage or commission
against the company, see Law v. TItompson, 15 M. k W. 511.
ik) Jlcxainlrr v. Macke)izic, 6 C. B. 7^6 ; Sh'fjq v. Elliott, 12 C. B.,
N. S. 373 ; 31 L. J., C. P. 200. Sec further, pp. 300, 301.
BILLS.
the National Provincial Bank of England, was given in this
form: —
£1,000. Birmlmjham, March 24, 1836.
Three months after date we promise to pay to the Manager of the
National Provincial Bank of England the sum of One thousand poiuids.
A. E.
C. D.
E. F.
At this time the National Provincial Bank of England
carried on business in other places as well as in Birming-
ham bj means of branch banks, but had a general board
of management at London, under a board of directors, at
which Eobertson was manager. Ebich was the local
manager at Bhmingham-.
In an action against A. B. and C. D. on this note by
Eobertson, who declared, as manager of the National Pro-
vincial Bank of England not styling himself public officer,
it was objected, that the action should have been brought
by the bank, suing by their public officer ; 'but it Avas
ruled, that the facts stated were distinct evidence to go to
the jmy that the plaintiff was the manager intended in
the note, and that it was not open to the defendants to con-
tend that the bank ought to have sued by its public officer.
Judgment accordingly was given against the defendants (/) .
A banking company, being the holder of bills indorsed
to them in blank, may authorize their manager to sue upon
such bills {m).
An instrmuent, in the form of a bill of exchange, drawn
on the head office by the manager of a branch bank by
order of the directors, but expressed in the body of it thus,
*' pay, without acceptance," may be treated as a promissory
note, and the directors may be sued as makers by an
indorsee or a holder (»).
Duties and Aid honfij. —The pubhc officer is not neces-
il) Robertson v. Sheward, 1 M. & G. 511.
(;«) Law V. Farncll, 7 C. B., N. S. 282 ; 30 L. J., C. P. 17.
(h) MtUcr V. T/wiiisoii, 3 M. & G. 570.
II TI 2
468 MANAGER.
sarily manager of the affairs of the copartnership (o),
though one person may discharge both offices. Whether
in any given case that is so or not, must depend, in
general, upon the terms of the deed of settlement or of his
appointment, which also is the source to ascertain whether
any act is within the scope of the authority, or not, of the
manager, or public officer. What is the authority and the
extent of it are c^uestions of fact, and the answer is to be
sought for in the deed of settlement, in the first instance ;
if that is silent on the subject, then, evidence of what acts
are usually performed by managers, or what acts the
manager of the particular company has been used to per-
form, as the case may be, must be resorted to (p).
It will be most convenient to define in the articles of
association, as carefully and fully as possible, the duties
and powers of the manager, especially as regards external
acts, such as the extent to which, and the form in which,
he may bind the company by accepting or indorsing bills,
taking up or advancing loans, &c.
The situation of manager is one of high trust, but the
trust becomes still greater, and the responsibility much
enhanced, in the case of a local manager of a branch esta-
blishment of the bank. For many purposes ho is looked
upon by the law and is treated as if he were the whole
body, whom he has power to bind even by his tortious
acts, although he may not be a partner.
For instance, if a local manager of a brancli bank gets
into his hands the money of a customer of the bank by
inducing the customer to consider that he is acting in the
transaction as agent of the bank and is invested with au-
thority to effect the purposes for which the customer con-
fides the money to him, and then appropriates the money
to his own purposes, the customer's loss will fall upon the
copartnership. To hold the bank not to bo liable in such
case would be, it has been said, to hand over the public to
(o) Alexander v. Mackenzie, 6 C. B. 706.
\)j) Eyre v. M'ThvclL \\ Ir. Com. Law Rep. 3U.
DUTIES AND AUTHORITY,
•169
the mercy of tlie clerks employed by tliese banks. The
principle seems to be, that the manager is a servant whom
the bank, for the puq)oses of their trade, virtually accredit
and hold out to the world as invested by them with general
authority to act for them in the affairs of the branch bank,
and the public has no power or means to discriminate
what is, and what is not, in any particular case, within the
legitimate scope of the agent's powers or in accordance
with the directions of his principals ; and, therefore, when
a customer, in a matter connected with his relations with
the branch bank, confides in the servant, he, in fact, trusts
the masters and they are liable even for the fraud of the
servant whom they have appointed, if committed in the
course of his service {q).
It is usual for customers of a bank to make inquiries
through their bankers as to the commercial credit and
solvency of persons with whom they intend to have mone-
tary transactions, as a measure of precaution to themselves.
It is within the scope of a manager's general authority to
make these inquiries and to afford the requisite informa-
tion. If the information is given in writing and it turns
out to be false or untrue, whereby the party for whose
benefit it is supplied suffers loss, the banking company
will be liable as well as the manager if they are both sued
together (r). Thus, the plaintiff sued the public officer
of the Grloucestershire Banking Company, established
under 7 Geo. IV. c. 46, and their manager at one of
its branches, for a false representation with respect to the
solvency of Sir William Russell. It appeared that the
plaintiff was a customer of the Sheffield and Hallamshire
Bank, and had requested the manager of that bank to
inquire for him as to Sir William Russell's credit. The
{q) Thompson v. Bell, 10 Exch. 11. See Ficker'mg v. Bml; 15 East, 53 ;
Barwickv. London Joint Stock Bank, L. R, 2 Ex. 259; Mackay v. Gom-
mercial Bank of Xew Brunswick, L. E., 5 P. C. 394; McGowan v. Di/cr,
L. E,., 8 Q. B. 141 ; Addic v. Western Bank of Scotland, L. R., 1 H. L.
145 ; Houldsworth v. City of Glctsgow Bank, 5 App. Cas. 317.
(V) Hosegood v. Bull and Kingdom, 36 L. T. 617 ; Swift v. Winterbotham,
L. R., 8 Q. B. 244.
470 MANAGER.
manager wrote a letter addressed to the manager of the
Grioucestershire Banking Company, requesting information
whether Sir William Russell was -responsible to the extent
of 50,000/. The manager of that company wrote a letter,
in which he signed himself as manager, giving a favour-
able reply as to Sir William Russell's responsibility. The
plaintiff in consequence of this letter supplied Sir William
Russell with goods, for which he never was paid in eon-
sequence of Sir William Russell's insolvency. The state-
ment made by the manager was false to his knowledge.
This company, however, had no knowledge, otherwise than
through theii" manager, that such a letter liad been written,
and gave him no express authority to write the letter, but
the writing of such a letter Avas an act within the scope of
the general authority conferred on him as manager by the
company ; the Court of Queen's Bench upon this state of
facts held, first, that his signature as manager was not
merely that of an agent but of the banking company
itself, and therefore the signature of the party to be
charged within 9 Greo. IV. c. 14, s. G (s), so as to make
the banking company liable for the false representation ;
secondly, that the letters showed that the communications
were between the two banks, and the representation was
not merely the representation of the manager personally
but of the banking company ; thirdly, that inasmuch as it
is usual for customers of a bank to make inquiries of the
description made by the plaintiff, it must be taken to have
been witliin the contemplation of the banking company
that the inquiry as to Sir William Russell's solvency
miglit have been made on belialf of a customer of the
Sheffield bank, and that the representation might be com-
(s) By this Rtatutc, -wliicli is commouly cnllcd Lord Tcutcrdcn's Act, it
is enacted, "That no action shall bo broug-ht ■\vhcreby to charge any
person upon or by reason of any representation or assurance made or
given concerning or relating to the character, conduct, credit, ability,
trade or dealings of any other jicrson to the intent or pui'posc that such
other persf)n may obtain credit, money or goods upon {aic in the original
section), unless such representation or assurance be made in vriting,
signed by the party to be charged therewith."
DUTIES AND AUTHORITY. 471
mimicated to liim, aud that the banking company and
their manager were liable to the plaintiff, he being tlie
customer who had made the inquiry, and for whose benefit
it was intended ; fourthly, that the banking company was
liable for the false representation of its manager, made in
the course of conducting the business of the bank; and
lastly, that as all persons dii^ectly concerned in the commis-
sion of a fraud are to be treated as principals, the banking
company and their manager might be sued jointly {t).
So again, where the plaintiff — having for some time, on
the guarantee of the defendant, supplied J. D,, a customer
of theii's, with oats, on credit, for carrying out a govern-
ment contract — refused to continue to do so unless he had
a better guarantee, the defendant's manager thereupon
gave him a written guarantee to the effect that the cus-
tomer's cheque on the bank in plaintiff's favour, in payment
for the oats supplied, should be paid, on the receipt of the
government money, in priority to any other payment,
" except to this bank." J. D. was then indebted to the
bank to the amount of 12,000/., but this fact was not
known to the plaintiff, nor was it communicated to him
by the manager. The plaintiff thereupon supplied the
oats to the amount of 1,227/. ; the government money,
amounting to 2,676/., was received by J. D., and paid into
the bank, but J. D.'s cheque drawn on the bank for the
price of the oats in favour of the plaintiff was dishonoured
by the defendants, who claimed to retain the whole sum of
2,676/. in payment of J. D.'s debt to them. The plaintiff
having brought an action for false representation, and for
money had and received : — Held, first, that there was
evidence to go to the jury that the manager knew and
intended that the guarantee should be unavailing, and
fraudulently concealed fi-om the plaintiff the fact Avhich
would make it so ; secondly, that the defendants would
be liable for such fraud in the agent; thirdl}^, that the
{t) Su-lft V. Wintcrbotham, L. K., 8 Q. B. 244.
472 MANAGER.
fraud was properly charged in the declaration as the fraud
of the defendants {u).
The arrest, and still less the prosecution, of an offender
does not come within the ordinary routine of a hanking
business, and is consequently not within the ordinary
scope of its manager's authority (x).
A manager and cashier of a bank obtained the signature
of B. to a document in the form of a cheque, purporting
to be drawn upon the bank by B., imder the pretence that
it was a receipt for a private debt due to him from the
manager. B. was an illiterate person, and unable to read,
and the manager then paid B. his debt with the banker's
money. The transaction was entered in the bank books,
as a loan by the bank to B., upon his cheque. B. was not
a customer of the banker ; it was held that the banker was
not entitled to recover back the money from B., for the
cheque was obtained by the fraud of the banker's agent,
and that he must suffer the loss, if the manager was unable
to make it good (//).
That the manager of a branch bank must necessarily
have a larger authority than usually attaches to agents is
apparent from this : an agent, in general, has no authority
implied by law independently of his particular instruc-
tions to borrow money for the service of his principals
in the business he conducts for them : to obtain deposits,
that is, to obtain loans of money for his employers, is one
principal part of the business of a manager of a branch
bank ; his power, in this respect, is unlimited ; and thus he
makes them responsible for every shilling which he receives
from a customer of the bank.
So, if he advances money on loan, the loss, if any, must
fall on the shareholders of the bank : thus, in a case where
the manager of a branch bank had advanced money to the
agent of a mining concern, to pay the wages of the laboui-ers
(«) Barxvick v. English Joint Stoclc Bank, supra.
{x) Bank of New South ll'ales v. Otcston, 4 App. Cas. 270.
(y) Foster V. Green, 1 II. & N. 881 ; 31 L. J., Exch. 158.
DUTIES AND AUTHORITY. 473
in the mine, which were in arrear, and for which they had
obtained warrants of distress upon the materials, &c., in
the mice, the copartnership of the bank was unable to
recover the amount of the advances, by action, against a
shareholder in the mine, on the ground that an agent, in
general, has no implied authority to borrow money for the
service of his employers, and there was no evidence of any
special authority having been given by the shareholders,
although the money had been applied in payment of the
wages due from the shareholders to the labourers (z) .
In respect of any contract into which the manager may
enter on behalf of a branch bank (provided it falls within
the usual course of banking business), although, under the
deed of settlement, or otherwise, the manager may be
restricted from entering into contracts of that particular
class, there being no proof that the party, with whom the
contract was entered into, was cognizant of such restriction,
the copartnership will be liable (a) .
Where in an action by a banking company against their
late manager and cashier to recover moneys belonging to
the bank, alleged to have been improperly applied, in dis-
counting bills for his own advantage, for the benefit of
persons and companies with whom he was connected, and
in which he was interested, it appeared that such trans-
actions were all in the ordinary course of the business of
the bank, that he had not exceeded the power and autho-
rity with which he was entrusted, and that no case of bad
faith could be established against him, the Privy Council
held that the action was not maintainable (b).
The criminal liability of managers will be mentioned in
Chapter LIU.
(;) Hawtayne v. Uourne, 7 M. & W. 59.5.
(a) Hauken v. Bourne, 8 M. & TV. 709 ; see Ex parte Chippendale, 4 De
G., Mac. & G. 19.
[b) Bank of Upper Canada v. Bradshaiv, 4 Moore, P. C. C, N. S. 406 ;
L. R., 1 P. C. 479 ; and see Ward v. Greenland, 19 C. B., N. S. 527.
( 474 )
CHAPTER LII.
PUBLIC OFFICER.
Appowfmoif.— The 7 G-eo. lY. c. 4G (1826), which legalized
the establishment of banking copartnerships in England,
exceeding a radius of sixty-five miles from London, re-
quired them to nominate and appoint two or more public
officers, being members and resident in England, and
empowered them to sue and to bo sued in the name of
one of such public officers {a). The duties which this act
imposes upon a public officer are the making out, verifying
on oath, and delivering to the stamp office the several
annual returns in the forms prescribed, as pointed out in
a former Chapter (b). These provisions apply only to
banking companies established beyond sixty-five miles
from London. The 3 & 4 Will. lY. c. 98, which enabled
banking companies to establish themselves n-ithin sixty-
five miles of London, did not confer upon them the power
or privilege of suing or being sued in the name of a public
officer. The 7 et 8 Yict. c. 113, s. 47, first conferred this
power or privilege upon these banking companies, if esta-
blished before the 6th of May, 1844, provided they made
out and delivered, from time to time, to the Board of
Inland Eevenue, the retui^ns required by the 7 Geo. lY.
c. 46, and all the provisions of such act are to apply to the
accounts or returns so made out and delivered by such
companies, as if they had been originally included in the
provisions of the 7 Geo. lY. c. 4G. The Companies Act,
1862(f), although it repeals the 7 & 8 Yict. c. 113, ex-
pressly re-enacts tlie 47th section. The appointment of
(a) 7 Geo. 4, c. 46, s. 9.
{b) Ante, pp. 370, 377.
(V) 2.5 &. 2Q Vict. c. 80, s. 20.3. Tliird Schedule, Part II.
ACTIONS AND SUITS BY AND AGAINST. 475
public ofllcers by banking companies, formed under tne
provisions of the 7 & 8 Vict. c. 113, became altogether
unnecessary on their obtaining charters of incorporation ;
neither are public officers required to be appointed by
banking companies established imder the Companies Act
of 1862, as on registration these companies become entitled
to all the privileges of incorporated bodies (d).
The appointment of public officers, when required, is
regulated by the terms of the deed of settlement of the
company, and should generally be made by a deed. The
appointment may be proved by a certified coj)y of the
official retm'n to the stamp office, or by the production of
the instrument appointing them, or even by parol evi-
dence {c).
Banking copai-tnerships smrendering their right to issue
their own bank notes, by agreement with the Bank of
England, do not lose the privilege of suing or being sued
in the name of their public officer (/').
Actions and Suits. — In respect of banking companies
governed by 7 Geo. IV. c. 40, all actions by or against the
company must be brought by or against its pubKc officer,
and not otherwise {g).
In an action by a public officer, it is usual, though not
essential, to allege, in the declaration, that he, at the
commencement of the suit (/?), has been named and duly
appointed one of the public officers of the copartnership ;
but it is not necessary to state that he is a member of the
company, or that he has been duly registered (/), or that
he has been duly named and appointed as the nominal
plaintiff on behalf of the copartnership (A-).
{(1) 25 & 2G Vict. c. 89, s. 18.
(t-) Edwards v. Biichauan, 3 B. & Ad. 788.
(/) 27 & 28 Vict. c. 32, s. 1.
\g) Steward \. Greaves, 10 M. & W. 721 ; Todd x. WrUjht, IG L. J.,
Q. B. 311 ; Chapman v. Milvain, b Exeh. 61.
{h) Esdaile v. Maclean, 15 M. & W. 277; M'Intyre v. Miller, 13 M. &
W. 725.
(i) Spiller v. Johnson, 6 M. & W. 570.
(V) Christie v. Peart, 7 M. & W. 491.
476 PUBLIC OFFICER.
Notwithstanding the change of name of the copartner-
ship, and the accession of fresh proprietors, the increase
of their capital, and the addition of fresh directors, the
public officer of the new copartnership is the proper person
to sue on a guarantie given to the company before the
alteration (/).
The public officer may sue after the copartnership has
suspended payment, and the establishment is kept open
only for the purpose of winding up {m) .
A copartnership having become insolvent, and ceased
to carry on business, the public officer instituted a suit
in equity, charging some of the directors with losses, by
reason of unauthorized speculations in shipping, and of
a fraudulent transaction by a deed of arrangement with
a debtor to the company, praying relief in respect of all
these matters, and to have the deed set aside. The suit
was considered to have been properly instituted by the
public officer, although the company had ceased to carry
on business ; that directors and trustees, not charged with
improper transactions or fraud, need not be made parties
to the suit ; but the manager, who, it appeared, was mixed
up in these transactions, ought to be made a party ; and
that tliough there wore several distinct transactions, they
were properly comprised in a single suit (>?).
So, when a wan*ant of attorney has been given to the
trustees of the copartnership to secui'C a debt due to the co-
partnership, the judgment thereon can only be entered up
in the name of the public officer (o) .
So the public officer is to sue on a breach of covenant
with trustees of the copartnership to pay calls (p), and, in
general, is the only proper party to sue on all covenants in
the deed of settlement ; although the covenants are made
with trustees (q).
(/) Wihon V. Craven, 8 M. & W. 584.
{m) Davidson v. Cooper, 11 M. & W. 778.
hi) llarrisun v. Brotcn, 5 Do G. & S. 733.
\o) lldlv. Fish, 12 C. B. 493.
(>) Wills V. Sutherland, 4 Excb. 211.
(ij) Chapman v. Milvain, 5 Exch. 61.
LIABILITIES. 477
But a note payable to tlic order of a person who is a
trustee for the comjDany must, if unindorsed, be sued upon
by the payee, and not by the public officer of the com-
pany (;•).
The company will not be bound by a judgment in an
action by a person not at the time their public officer (-s-) .
If a defendant, in an action pm^j^orting to be brought
by a public officer of a a company, traverses his appoint-
ment as public officer, and has a verdict on that issue, it is
a good defence (s). *
The public officer may file a petition for adjudication
of bankruptcy or sue out a judgment debtor summons
against a debtor indebted to the copartnership, provided,
in the declaration signed by him, he declares that he is
such public officer, and entitled to sue {t).
So he may prove on a bankrupt's estate in like
manner {i<).
Both the public officers cannot sue together ; but if they
are joined, an amendment by striking out the name of
one will be allowed (x) .
Liabilities. — In an action in which a public officer sues
on behalf of the company, interrogatories may be admi-
nistered to him, and he must answer them {>/).
When an action is brought against the public officer of
a copartnership, as such, he will not be permitted to plead
that he has become bankrupt, for he is a mere parlia-
mentary defendant ; he represents the interests, j)erhaps, of
several hundred persons, and, if he were to be allowed to
{)■) M'Dowcll V. Doffle, 7 It. Com. Law Rep. 598.
{s) Jiarneivall V. Sutherland, 19 L. J., C. P. 292. See Patcrson v. Iron-
side, 14 Jul'. 722.
{t) Bankruptcy Act, 1869, s. 80, par. 7.
{>() Id. s. 144. See a form of affida\dt of proof of debt by a public
officer in. Schedule of Forms, p. 212, Roche & Hazlitt's Bankruptcy Act,
1869.
{x) Holmes v. BUuieij, 6 Scott, 346 ; 4 Bing. N. C. 454. As to suing
both, 16 M. & W. 669.
(y) M'Knu/a v. Holt, 28 L. J., Exch. 380; 4 H. & N. 738. See
Judicature Acts, Ord. XXXI. r. 4.
478 rUBLIC OFFICER.
plead such a plea, of a matter merely personal to himself,
in bar of the action, he would confer the benefit of that
defence on all those whom, as a matter of form, he repre-
sents as defendants. In such a case, however, the plaintiff
would be restrained from issuing execution against the
defendant, or his estate (y). Nor does attachment lie
against him (s).
Accordingly, it has been held that where a deed of
settlement provided, that if any of the public officers
became bankrupt he should become disqualified, and his
office should become vacant, the proper construction was
not that the person should cease to be public officer abso-
lutely, but only at the election of the company {a). If
bankruptcy, per se, disqualified, the company could have
had no election.
So, a person sued as public officer will not Ije allowed
to plead that he is not public officer, iocjether with other
pleas going to the merits of the action. He may rely on
that plea as his sole defence, if it is capable of proof ; but,
as the company are the real defendants, they must rely on
such defence as they have to the merits of the action ;
they cannot be allowed to turn the plaintiff round on so
mere a matter of form as whether the defendant was public
officer at the commencement of the suit [h). But in an
action by a public officer, a plea denying that the copart-
nership was at the commencement of the action carrying
on the trade or business of bankers, in addition to pleas
of non assumpsit and of accord and satisfaction, will be
allowed (c).
Death, Resignation or Removal. — The death, resignation,
or removal of a public officer will not abate any action,
(y) Steward V. Lunn, 11 M. & W. C3.
(2) Corpe V. Ghjyi, 3 B. & Ad. 801.
(«) Steicard v. Duuii, 12 M. & W. 6.>5.
(b) Xeedham v. Law, 11 M. & W. 400. Qiicvrc, whethor tlii.s is so now
under the powers of alternativo pleading given by Ord. XIX. r. 8, of the
Judicature Acts, 1873, 187o. Sec also rule 11 of that Order.
(f) Itoew Fuller, 7 Kxch. 220; 21 L. J., Exrh. 101.
JUDGMENT AGAINST. 479
suit, or proceeding commenced by or on the behalf of or
against the copartnership, but the same may be continued,
prosecuted, and carried on in the name of any other of the
public officers of the copartnership for the time being ((/).
If the public officer dies during the progress of an action,
a suggestion of his death, and of the appointment of his
successor, should be entered on the proceedings before the
next step is taken, otherwise they may be set aside for
informality (c).
A cognocit actionem, given to a public officer, was con-
sidered to be sufficient, after his removal,- to authorize a
succeeding public officer to enter up judgment in his own
name (/). To enter it up in the name of the officer, in
whose time the cognovit was given, would be erroneous (^).
"When the public officer dies after judgment obtained
in an action, and after the issuing of a writ of ca. sa., but
before its execution, this does not cause the action, or the
proceedings consequent on it, to abate, and, therefore, it
was held, a defendant could be taken in execution {//).
In equity, it was ruled, as there was no change of
interest, it was unnecessary to file any supplemental bill,
in order to make a new registered public officer a party to
the suit (/).
Judgment against. — When a plaintiff obtains judgment
against a public officer, he may issue execution against him
without first suing out a scire facias, for he is already a
party to the record (Ic) .
{(I) 7 Geo. 4, e. 46, s. 9. And see now Jud. Acts, Ord. XIX. r. 13,
and Ord. L. rr. 1, 4.
(e) BarneicaU v. Sutherland, 19 L. J., C. P. 290; 14 Jur. 720; 9 C. B.
380 ; Faterson v. Ironside, 14 Jur. 722, n. See Jud. Acts, Ord. L. and
Crane v. ZoftKs, 24 W. R. 93.
(/) This seems to be the effect of the judgment in Webb v. Taylor,
1 I). & L. 676. But a judge's order by consent has now almost entirely
superseded the practice of cognovits. See Archibald's Practice, pp. 248,
249.
[g) See 1 D. & L. 687 ; rrohbi v. Loeo'clc, 1 Dowl., K S. 197.
[h) Toddy. Wright, 16 L. J., Q. B. 311; Ellis v. Griffiths, 16 M. & W.
106.
(0 Butchart v. Dresser, 18 L. J., Chanc. 198 ; 10 Hare, 453.
[k] Haruood v. Law, 7 M. & W. 203.
480 PUBLIC OFFICER.
Indemnitij. — A public officer, in whose name any suit
or action has been commenced, prosecuted or defended,
sustaining any loss, damages, costs, or charges will be
entitled to reimbursement out of the funds of the copart-
nership, or, in failure thereof, to contribution from the
other members, as in a case of an ordinary partnership (/).
Criminal Proceedings. — Prosecutions by public officers
on behalf of the company, and their criminal liability, will
be treated of in the next Chapter.
(/) 7 Geo. 4, c. 4G, s. 14.
( 481 )
CHAPTER LIII.
CRIMINAL LIABILITY OF MEMBERS AND OFFICERS OF
BANKING COMPANIES.
The members of the copartnerships either established
beyond sixty-five miles from London under the 7 Geo. 4,
c. 46, or established in London, or within sixty-five miles
of London imder the 3 & 4 Will. 4, c. 98, s. 3, may be
prosecuted in the name of their public officer for any mis-
demeanor' or felony committed by them against these co-
partnerships as if they were actually strangers {a) . A
clerk may therefore be convicted of embezzling or stealing
the property of one of these copartnerships, although he
is a shareholder {b) . The property may be alleged in an
indictment for larceny or for embezzlement to belong to
one of the public officers or of one of the members named
and others (c). The members of banking companies
formed under the 7 & 8 Yict. c. 113, or registered under
the 20 & 21 Yict. c. 49, or the Companies Act, 1862 (d),
committing fraudulent or other criminal acts against
theii' company will be liable to prosecution at the suit of
and in the registered or corporate name of that particular
company.
The legislature has created certain specific acts of
directors, members, managers and public officers, misde-
meanors, to which it will be necessary to refer in detail.
It may be mentioned that banking co-partnerships
formed under the provisions of the 7 Geo. 4, c. 46, are
public companies {c) ; and banking companies registered
(ff) 3 & 4 Vict. c. Ill, s. 2 ; made perpetual by 5 & 6 Vict. c. 85.
{b) Req. V. Atkinson, Car. & M. 525 ; 2 Mood. C. C. 278.
(c) 7 Geo. 4, c. 64, s. 14; Meff.v. Fritchard, 30 L. J., M. C. 169 ; 8 Cox.
C. C. 461.
{d) See sect. 18.
(e) See 3I'Iiityre v. Conndl, 20 L. J., Clianc. 284; Graham v. Conncll,
19 L. J., Exch.361.
G. II
482 CRIMINAL LIARILITY OF MEMBERS AND OFFICERS.
under the Companies Act, 1862, are bodies corporate
witliin tlie scope of tlie following enactments.
Fraudulenthj (qyproijriating the Property of the Com-
pa)vj. — A director, member or public officer of a body
corporate or public company who fraudulently takes or
applies for his own use or benefit, or for any use or pur-
poses other than the use or purposes of the body corporate
or public company, any of the property of the body
corporate or public company, will be guilty of a misde-
meanor (/).
Keeping Fraudulent Accounts. — A director, public officer
or manager of a body eor[iorate or public company, who
receives or possesses himself of any of the property of the
body corporate or public company, otherwise than in
payment of a just debt or demand, and with intent to
defraud omits to make, or to cause or direct to be made, a
full and true entry thereof in the books and accounts of
the body corporate or public company, will commit a mis-
demeanor (r/).
Falsifying or destroying Accounts or Documents. — So
a director, manager, public officer or member of a body
corporate or ];)ublic company who, Avith intent to defraud,
destroys, alters, mutilates or falsifies any book, paper,
writing or valuable security belonging to the body
corporate or public company, or makes or concurs in the
making of any false entry, or omits or concurs in omitting
any material particular in any book of account or other
document, will be guilty of a misdemeanor {It).
Publishing fake Statements or Balance Sheets. — A di-
rector, manager or ]iublic officer of a body corporate, or
(/■) 21 & 2.') Vict. c. '.((I, s. Kl.
(//) hi. s. s-j.
(/,) /,/. s. ,s:!.
PUBLISHING FALSE STATEMENTS OR l^.A LANCE SHEETS. 483
public company, making, circulating or publishing, or con-
cm-ring in making, circulating or publishing any written
statement or account which he shall know to be false in
any material particular, with intent to deceive or defraud
any member, shareholder or creditor of the body corporate
or public company, or with intent to induce any person
to become a shareholder or partner therein, or to intrust
or advance any property to the body corporate or public
company, or to enter into any seeiuity for the benefit
thereof, will be guilty of a misdemeanor (/) .
A false representation by an* officer or a servant of a
company, even though when made at the bank, is not for
criminal pui-poses the representation of the company (/.•).
A false representation, in order to be the representation of
the company, must be made by a report adopted at a
general meeting, and put forth to the public either inten-
tionally or circulated in the ordinary course of business (A-) .
The directors of a bank are liable also to be indicted
for a conspii'acy to defraud by publishing false balance
sheets, and circulating false reports as to the condition and
solvency of their bank, and issuing new shares to the
public, at a time when they know the bank to be in a state
of insolvency. The manager will be equally liable with
the directors under such circumstances, where he has the
chief control and management of all the affair's and trans-
actions of the bank [l) .
When the manager and the secretary of a banking com-
pany were indicted for making and publishing false state-
ments of the affairs of the bank, and conspiring together
to do so, the prosecutors were put to their election as to
the counts on w^hich they would rely, and having elected
to rely on the counts for conspiracy, it .-^^as not enough to
(i) 24 & 25 Vict. c. 96, s. 84.
(/.•) Ex parte Froicd, 9 W. R. 328 ; 3 L. T., N. S. 843.
(/) Hpff. V. i:sdaile, 1 F. & F. 213 ; 7 Cox, C. C. 442, and tlie report of
the trial of The Aftornci/- General v. Brown and others, coram Lord Camp-
hell, C. J., Feb. 1858, "by J. C. Evans, Esq., and published by Messn?.
Stevens & Norton, BeU Yard. See also R. v. AxninaH, 1 Q. B. D. 730 ;
2 Q. B. D. 48 ; 46 L. J., M. C 145.
I T 2
CRIMINAL LIABILITY OF MEMBERS AND OFFICERS.
prove that they made and put fortli statements intended
and calculated to deceive, unless they had entered into a
precedent and fraudulent conspiracy to do so {>u).
With respect to the foregoing misdemeanors, it is pro-
vided, as in the case of bankers fraudulently misapplying
or disposing of securities or property intrusted to their
care, that the parties are not to be privileged from answer-
ing questions in relation to the charges in any civil pro-
ceedings, but on making disclosm-es in any compulsory
proceeding they are not liable to a criminal prosecution {n).
Neither is any criminal prosecution for the commission
of any of these misdemeanors to affect or to prejudice any
remedy or right at law or in equity against the delinquent
parties (»). Comdctions (o) are not, however, to be admis-
sible in evidence in civil proceedings (p).
The Companies Act of 1862 provides for the prosecution
of dii-ectors and other officers, found, on the winding-up
of a company, to be delinquents. The following are the
provisions relating to this subject : —
Poicer of Court to assess Damages. — If, in the com-se of
winding-up proceedings, it should appear that a past or
present director, manager or officer, has misapplied or re-
tained or become liable or accountable for any moneys of
the conipan}', or has been guilty of misfeasance or breach
of trust in relation to the company, the Court may, on the
application of a liquidator or of a contributory or of a
creditor, notwithstanding that the offence is one for which
the offender is criminally responsible, examine into the
conduct of the director, manager or officer, and compel
him to repay the moneys so misapplied or retained, or for
(;«) Reg. V. Binrh, 4 F. & F. 407.
(«) 24 & 25 Vict. c. 9G, ss. 8o, 86. See R. v. Skcen, 28 L. J., M. C. 91,
and ante, p. 289.
() The puniHliment on conviction for any of these misdemeanors is
defined by sect. 75 of the 24 & 25 Vict. c. 9G, to be penal servitude for
not more than seven nor less than five years (by 27 & 28 Vict. c. 47, s. 4),
or imprisonment for not more tlian two years, -vvitli or ■without hard
labour, and with or without solitary conlinement. These misdemeanors,
however, cannot be prosecuted or ti-ied at quarter sessions ; sect. 87.
[p) 24 &- 25 Vict. c. 96, .s. 8G.
PROSECUTION OF DELINQUENT DIRECTORS,
wliieli lie has become liable or accountable, with interest,
or to contribute such sums of money to the assets of the
company by way of compensation, as the Coui't may think
just {q).
Fahification of Books. — If a director, officer or contri-
butory of a company -finding up should be found to have
destroyed, mutilated, altered or falsified any books, jmpers,
writings or secm-ities, or to have made or been privy to
the makmg of any false or fi'audulent entry in any registry,
book of accoimt or other document belonging to the com-
pany, with intent to defi-aud or deceive any person, every
person so offending will be deemed guilty of a misde-
meanor, and upon being comdcted will be liable to impri-
sonment for any term not exceeding two years, with or
without hard labour {>•).
Prosecution of Delinquent Directors. — "Where there is an
order for winding up a company by the Court, or subject
to the supervision of the Com-t, if it should appear in the
course of such winding-up that a past or present director,
manager, officer or member, has been guilty of any offence
in relation to the company for which he is criminally
responsible, the court ma}", on the apphcation of any
person interested in the winding-up or of its own motion,
direct the official liquidator or the liquidator (as the case
may be) to institute and conduct a prosecution or prose-
cutions for such offence, and may order the costs and
expenses to be paid out of the assets of the company (s).
This application must be made by petition {f).
Prosecution of delinquent Directors, Officers or Members,
under a voluntary Winding-n}). — Where the winding-up is
{q) 25 & 26 Vict. c. 89, s. 165. Bankers of a company are not officers
of the company -within the terms of this section. In re Imperial Land
Company of Marseilles, 39 L. J., Ch. 331.
(»•) Id. s. 166.
(«) Id. s. 167.
(0 Gen. Orel. 1 1th November, 1862, r. 51.
486 CRIMINAL LIAI'ILITY OF iMEMRERS AND OFFICERS.
altogether voluntary, if it should appear to the liquidators
that a past or present director, manager, officer or member,
has been gnilty of any offence in relation to the company
for which he is criminally responsible, it shall be lawful
for the liquidators, with the previous sanction of the
Court, to prosecute such offender, and all expenses pro-
perly incun-ed in the prosecution will bo payable out of
the assets of the company, in priority to all other lia-
bilities (?/)•
The application to the Court for the purpose of insti-
tuting the prosecution must be by petition (,r) . In the
above provisions a liquidator abusing his trust or office is
included {//).
(«) 25 & 2G Vict. c. 89, s. 168.
(.'■) Glen. Ord. 11th November, 1862, r. ol.
(y) 25 & 26 Vict. c. 89, s. 165.
( -i^r )
CHAPTER LIV.
ATTACHING FUNDS IN TJANKEr's HANDS.
By the Judicature Act, 1875, Orel. XLY. r. 2, it is enacted
that " the Court or a judge may, upon the ex parte appli-
cation of a judgment creditor, either before or after oral
examination, and upon afhdavit by himself or his solicitor
stating that judgment has been recovered, and that it is
still unsatisfied, and to what amount, and that any other
person is indebted to the judgment debtor, and is within
the jurisdiction, order that all debts owing or accruing
from such third person (hereinafter called the garnishee)
to the judgment debtor shall be attached to answer the
judgment debt ; and by the same or any subsequent order
it may be ordered that the garnishee shall appear before
the Court or a judge or an officer of the Court, as such
Court or judge shall appoint, to show cause why he shoidd
not pay the judgment creditor the debt due from him to
the judgment debtor, or so much thereof as may be suf-
ficient to satisfy the judgment debt."
This is taken from sect. 61 of the C. L. P. Act, 1854.
A customer's balance may be attached by a judgment
creditor of the customer to answer his judgment debt {a).
By Pule 8, " Service of an order that debts due or
accruing to the judgment debtor shall be attached, or
notice thereof to the garnishee, in such manner as the
Court or judge shall direct, shall bind such debts in his
hands" {b).
(a) Sojmour v. Brecon Corporation, 29 L. J., Ex. 243 ; In re Fritchard,
2 De G-., r. & J. 354. See also judgments in Mayor of London v. London
Joint Stock Bank, 6 App. Cas. 393. A garnishee order nisi does not create
a charge until service of it on the garnishee. Jfaincr v. Gihs, 11 Ch. D.
942; 48 L. J., Chanc. 508.
(A) The debt must be an absolute and not a conditional one. ItoueU
V. Jfcfrojio/ifaj/ iJi^'tr'rt BaHa-ai/, 19 Ch. D. 508.
48S ATTACHING FUNDS IN HANKEu's IIANUS.
By Rule 4, "If the garnishee does not forthwith pay
into Court the amount due from him to the judgment
debtor, or an amount equal to the judgment debt, and
does not dispute the debt due or claimed to be due from
him to the judgment debtor, or if he does not appear upon
summons, then the Court or judge may order execution
to issue, and it may issue accordingly, without any pre-
vious writ or process, to levy the amount due from such
garnishee, or so much thereof as may be sufficient to satisfy
the judgment debt."
By Rule 8, " Payment made by, or execution levied
upon, the garnishee under any such proceeding as aforesaid
shall be a valid discharge to him as against the judgment
debtor, to the amount paid or levied, although such pro-
ceeding may be set aside, or the judgment reversed" {a).
In the city of London funds in the possession of bank-
ing partnerships, other than banking corjiorations, are liable
to the process of foreign attachment, as existing in the
Mayor's Court, though the process must be strictly pur-
sued according to the custom. Fictitious summonses and
returns, as formerly resorted to, will render the suit
invalid {b) . This process is much more extensive in its
operation within the ambits of the city jurisdiction, than
an attachment of debts under the provisions of the Judi-
cature Act already mentioned (r). Under that statute, it
will be observed, debts cannot be attached until judgment
has been obtained ; Avhereas, under the custom of the city,
debts are attachable for the purpose of compelling the
defendant to appear and put in bail to the action in the
Lord Mayor's Court (r). Until a city attachment has
been dissolved or withdi'awn, a banker cannot part with or
pay away funds belonging to his customers {c) . As regards
banking corporations, the recent case decided in the House
of Lords {h) has now clearly settled that this process is a
(a) See Jfotvdl v. Mtfropolitaii District Bailwaij, supra.
{b) Mai/or of London v. London Joint Stock Bank, supra,
(r) See Braiidon on ForeinTi Attachment.
ATTACHING FUNDS IN BANKER's HANDS. 489
personal one, and cannot be applied to a corporation aggre-
gate.
Funds of foreign governments, in the hands of bankers
as their agents for the payment of the dividends on foreign
bonds or stocks, are not attachable at the suit of the
creditors of such governments (r/).
Accounts kept by collectors or receivers of government
taxes with bankers may be seized under a writ of extent
at the suit of the Crown against the bankers {c). So, an
extent may be issued against a banker, with whom a col-
lector has deposited promissory notes or bills of exchange
taken by him in payment of taxes {e). If a collector pays
moneys received by him for taxes to a third party who
pays the same into his private account with his bankers,
and the bankers have knowledge of the fact that the moneys
are the moneys of the Crown, an extent may issue against
the bankers for the recovery of such moneys (./) . If by the
terms of the deposits interest is payable by the bankers,
that is also recoverable by the Crown (e).
Recently it has been alleged that there is a custom among
bankers who have discounted their customer's bill of ex-
change, upon the acceptors suspending payment before
their maturity, to call upon their customers to take them
Tip, or, failing to do so, to retain their balances in their
hands to meet the liability on the cmTcnt bills (g). The
custom has been denied, and its validity in point of law
may be open to considerable doubt. The case in which
the custom was alleged to exist was compromised and
apparently in favour of the customer and against the claim,
and consequently no decision was given (g).
By the National Debt Act, 1870, consols and other
public stock are not liable to foreign attachment by the
custom of London or otherwise {h) .
(d) Wadsworth v. The Queen of Spain, 17 Q. B. 171.
\e) Reg. v. Adams, 2 Exch, 299.
(/) Reg. V. Ward, 2 Exch. 301, n.
{g) Agra and Mastermaii''s Bank, Limited v. llnffman, 13 W. R 22G ■
11 L. T., N. S. 701; 34 L. J., Chanc. 28.5, coram Stuart, V.-C.
(A) 33 & 34 Vict. c. 71, s. 10.
( 490 )
CHAPTER LV.
WINDING-UP AND DISSOLUTION OF BANKING COMPANIES.
AVe propose in this chapter to state the general outline of
the law applicable to the winding-np of banking copart-
nerships and companies, unable to meet their engagements
or to cany out the objects for which they were promoted.
For more detailed information, and for the cases decided on
the various sections of the Comj)anies Act, the reader must
be referred to those works expressly dealing with Company
law.
Banking copartnerships constituted under the 7 Greo.
lY. c. 46, or under the 3 & 4 "Will. IV. c. 98, or, as to
Ireland, under the 6 Geo. IV. c. 42, and not registered as
limited or unlimited banking companies under the Com-
panies Act of 1862, must be wound up under the provi-
sions of that statute as unregistered companies {a) .
And bauldng companies formed under the 7 & 8 Vict.
c. 113, or mider the 21 & 22 Vict. c. 91, as limited, and
registered under the 20 & 21 Vict. c. 49, or formed and
registered under the Companies Act of 1862, must be
wound up under the provisions of the last-mentioned
act (b).
The winding-up will be by a compulsory process, imder
the direct action and control of the Court of Chancery (c),
or by a voluntary process aided by liquidators appointed
by the companies (f/). But companies which have not
been registered as limited or unlimited banking companies,
under the Companies Act of 1862, cannot avail themselves
(«) 25 & 26 Vict. c. 89, n. 199.
(/>) Id. 8S. 179, 196.
(r) Id. s. 79.
('/) Id. H. 129.
AviNuixci-rr a>;d DissuLurioN. 491
of the voluntary process of wdndiug-up — they must he
"vvouiid up hy the Court of Chancery (e) .
Reversing the order of time in wliich these banks were
estabhshed, we will first consider the winding-up of the
companies fonned and registered under the Companies
Act of 1862, as many of its provisions will tend to eluci-
date the principles applicable to the winding-up of pre-
viously existing companies ; secondly, companies formed
under the 7 & 8 Vict. c. 113, or under the 21 & 22 Yict.
c. 91, as limited, registered under the 20 & 21 Yict. c. 49,
and re-registered under the Companies Act of 1852 ; and
thirdly, copartnerships formed under the 7 Greo. IV. c. 46,
and the 3 & 4 Will. IV. c. 98, and not registered under
the 20 & 21 Vict. c. 49, or under the Companies Act of
1862, — and the respective rights and liabilities of the
members and contributories of these companies.
"With regard, then, to the mnding-up of limited banldng
companies formed under the Companies Act of 1862, it is
to be remembered that the liability of the members is
fundamentally and constitutionally limited to the amount
unpaid on their respective shares (/') ; consequently, if
the shares in these banking companies have been fully
paid up, there will be no liability on the part of a past or a
present member to contribute to the debts of the company
on its being wound up. On the other hand, if the shares
have not been fully paid up, a past or a present member
may be called upon to contribute to the debts and liabilities
of the company the amount remaining unpaid on his shares,
subject to certain conditions and limitations (g). The con-
ditions are, — first, that the person has only ceased to be a
member within the year ; next, that the debts must have
been contracted before he ceased to be a member; and,
thirdly, that the present members are unable to satisfy the
contributions required to discharge the debts of the com-
((•) 25 & 26 Vict. c. 89, s. 199 (2j.
(/) Id. s. 7.
(.y) Id. s. 38 (1).
492 WINDING-UP AND DISSOLUTION.
pany {/i). A member will not be liable to contribute, if
he has ceased to be a member for a period of one year or
upwards prior to the commencement of the winding-up of
the company (/). The commencement of the winding-up
for this purpose is the time when the petition was pre-
sented to the Court of Chancery in the case where it is
compulsory (A-), and where it is voluntary, the time when
the resolution of the company authorizing the winding-up
was passed (/). Members will not be entitled to set off
dividends and profits due to them as such against the
claims of the creditors of the company, or to enter into
competition with creditors, although on the final adjust-
ment of their rights amongst themselves, as contributories,
their claims in respect of dividends or profits may be taken
into account {m) .
With these qualifications, members present and past of
limited banking companies will be liable to contribute to
the assets of the company to an amount sufficient for the
payment of its debts and liabilities, and the costs, charges
and expenses of the winding-up, and for the payment of
such sums as may be required for the adjustment of the
rights of the contributories amongst themselves (;?).
Compvhot'tj Wind ill (J- up. — A compulsory winding-up
may be resorted to under the following circumstances,
viz. : —
(1.) Whenever the company has passed a special reso-
lution requiring the company to be wound up by
the Court (o).
(h) 25 & 2G Vict. c. 89, s. 38. In re Barncd's Bank; lldhcrt v. Banner,
L. R., 5 H. L. 28 ; 40 L. J., Ch. 410.
(0 Id. 8. 38 (I).
{k) Id. a. 84.
(/) Id. 8. 130.
(w) Id. s. 38 (7).
(«) Id. B. 38.
(o) Id. fi. 79. As to special resolutions, sec ante, p. 417. The statute
also specifies another reason, viz., whenever the members are reduced in
number to less than seven, but as this is not likely to occur in a limited
banking company, consisting of a numerous body of shareholders, it is
not stated in the text.
COMPULSORY VVINDING-TTP.
(2.) Whenever the company does not commence its
business within a year from its incorporation, or
suspends its business for the space of a whole
year (7;).
(3.) Whenever the company is unable to pay its
debts {p).
(4.) Whenever the Court is of opinion that it is just
and equitable that it should be wound up (j)).
A company will be deemed unable to pay its debts : —
(1.) Whenever a creditor, to whom the company is in-
debted in a sum exceeding 50/., has served on
the company, by leaving at its registered office, a
written demand requiring the company to pay
his debt, and the company has for three weeks
neglected to pay the debt, or to secure or com-
pound for the same, to the reasonable satisfaction
of the creditor {q).
(2.) Whenever an execution on a judgment, decree or
order obtained by a creditor against the com-
pany has been retm^ned unsatisfied, wholly or in
part (q).
(3.) Whenever it is proved to the satisfaction of the
Court, that the company is unable to pay its
debts (5').
A company, however, will not be regarded as unable to
pay its debts simply because it has not paid a debt which
it disputes, and which the creditor has not established by
action (r) .
In the case of a banking company, the Lord Justice
Turner has expressed an opinion that a winding-up by the
Court, rather than a voluntary winding-up, should be
adopted in cases of enormous magnitude, where vast in-
terests are at stake — where the most ample powers which
the law has given must be required to be exercised — where
{jj) 25 & 26 Vict. c. 89, s. 79.
(q) Id. s. 80. See Buckley, pp. 164—175.
(V) lie Catholic Publkhinc/ CoDipain/, 33 L. J., Clianc. 325 ; In re Imperial
Guardian, ^-c. Society, L. E,., 9 Eq. 447; In re Kind's Cross Industrial
BivcUinffs Company, L. R., 11 Eq. 149.
493
49-i -WINUIXG-UP AND DISSOLUTION,
there have been transactions justifying, if not requiring,
investigation — where it may he doubtful whether the pro-
perty of the shareholders will answer the liabilities, and
where there is danger to the creditors of the shareholders
escaping from their liabilities («).
Petition. — A winding-up order Avill be obtained upon
a petition presented to the Court of Chancery by the com-
pany, or by any one or more creditor or creditors or con-
tributory or contributories, or by all or any of the above
parties together or separately, and every order which may
be made on any such petition shall operate in favour of all
the creditors and all the contributories of the company in
the same manner as if it had been made upon the joint
petition of a creditor and a contributory (/). A holder of
scrip certificates may petition for a winding-up order, on
his clothing himself with the character of a contributory {u).
But a holder of fully paid-up shares must show special
circmnstances to entitle him to an order (,<•).
Restraining Actions against the Company. — The Court
may, after the petition has been presented, upon the ap-
plication of the company, or of a creditor or of a contribu-
tory, restrain proceedings in actions or suits against the
company, and ap])oint a provisional liquidator (//). Appli-
cations must now be made to the Court where the actions
are pending {z).
"When a winding-up order has been made, the act pro-
vides that no suit or action shall be proceeded with or
commenced against the company, except with the leave of
the Court, and subject to such terms as it may impose {(i).
{s) In re Korthumhcrland and JJurham District Bankiiiq Compatni, 2 De
a. & J. 378.
[t) 25 & 2G Vict, c. 89, s. 82. See Buckley, pp. 177—182.
(w) Ex parte Ellis, 34 L. J., Chanc. 237 ; 11 Jur., N. S. 211.
\x) llJur., N. S. 4.
(y) 2.3 & 26 Vict. c. 89, s. 85. Soo Buckley, pp. 183—194.
(2) Under .sect. 24, sub.s. o of Judicature Act, 1873, and sect. 11,
stibs. 1 of Judicature Act, 1875. And see J'eoph's Garden Company,
1 Ch. D. 44 : Hose v. Garden Lodge Company. 3 Q. B. D. 235 ; In re
Artistic Colour Prinfinr/ Compatn;, II V\\. T). .'lOi.
(») 2.'. & 2fl Vict. c.'Sf). .9. 87.'
VOLUNTARY WINDIXC^-LT. 495
The Court is also empowered, at any time after an order
has heen made for winding-up a company upon the appli-
cation of a creditor or contributory, to stay proceedings
under the winding-up order, either altogether or for a
limited time (b). The Court may dismiss the petition with
or without costs, or adjourn the hearing, or may make an
interim or any other order that it may deem just under
the circumstances of the case (c) .
The Court is to consult the wishes and interests of the
creditors and contributories in all matters connected with
the winding-up of the company {d) .
FoncarcUnrj Order to Registrar. — A copy of the winding-
up order is to be forthwith forwarded by the company to
the Registrar of Joint Stock Companies, who must make a
minute of it in his books relating to the company [e).
Under a compulsory -^dndiug-up, the Court has the
power of appointing official liquidators for the purpose of
assisting it in the conduct of the business. The powers
and duties of official liquidators will be considered with
those of liquidators appointed under a voluntary winding-
up — to which head we now proceed.
Voluntary Winding-vjh — A banking company may be
wound up voluntarily in the events and under the circum-
stances following, viz. : —
(1.) Whenever the period fixed for its duration by the
articles of association has expired, or when it is
provided by the articles that the company is to
be dissolved, and it has passed a resolution in
general meeting requiring the company to be
wound up volimtarily (/).
(i) 25 & 2G Vict. c. 89, s. 89 ; Buckley, 205, 206.
(c) Id. s. 86.
[d) Id. s. 91.
W Id. s. 88.
(/■) Id. s. 129; Buckley, 2.>;]-2.J5.
496 ■SVINDIXG-UP AND DISSOLU HON.
(2.) Whenever the company has passed a special reso-
lution for that purpose (/).
(3.) Whenever it has passed an extraordinary resolution
to the effect that it has been proved to its satis-
faction that the company cannot, by reason of its
liabilities, continue its business, and that it is
advisable to wind up the same (//).
An extraordinary resolution {g) for this piu-pose will be
when notice of the resolution has been given and confirmed
in the same manner as a special resolution (//).
The winding-up commences to operate from the time
when the resolution was passed (i). It will not preclude
a creditor from afterwards applying to the Court to have
the company wound up by the Court (A-). Notice of the
special or extraordinary resolution, as the case may be,
must be advertised in the Grazette (/). The company
thenceforth ceases practically to carry on its Imsiness, and
transfers of shares, unauthorized by the liquidators, will
be void, and the status of the members cannot be altered
in their relations to the company (?«) . The corporate
character of the company, with its incorporated powers,
continues until formally dissolved {ni). When the resolu-
tion has been passed and confirmed for winding-up the
company voluntarily, the next step will be the appoint-
ment of one or more liquidators (»). On their appointment
the powers of the directors determine, unless continued
with the sanction of the company or the liquidators {ii) .
Their duties and powers will be considered in connection
with those of the official liquidators. The costs of a
voluntary winding-up, including the remuneration of the
(/) 25 & 26 Vict. c. 89, s. 129 ; Bucldev, 2:}3— 2.').').
if/) Id. 8. 129.
(//) See ante, p. 417, for the mode of passing special resolutions.
(«•) 25 & 2G Vict. c. 89, s. 130; Buckley, 255; Dawes' case, L. R.,
6 Eq. 232 ; In re Smith, Knight &; Co., ib. 238 ; L. R., 4 Ch. 20.
(/,•) Id. 8. 145. See Buckley, 266—269.
(/) Id. 8. 132.
(/«) Id. 8. 131 ; Buckley, 256.
(«) Id. s. 133; Buckley, 257—260.
LTQUIHATOR*^. 407
liquidators, will be payable out of the assets of tlie com-
pany (o).
Winding-up under Sapervii^ion of the Court. — When a
company is being- wound up voluntarily, the proceeding
may be transfen'ed to and adopted by the Court of Chan-
cery, and completed imder its supervision. This course "will
be taken when the voluntary winding-up is not proceeding
satisfactorily, or is inefficient in its working for the inte-
rests of creditcTS or contributories (jj).
Liquidators. — The Court of Chancery, in winding-up a
company under its control, generally appoints an official
liquidator, who ought to be an entu-ely disinterested per-
son — neither a creditor nor a shareholder of the com-
pany {q).
In all proceedings he will be described as the official
liquidator of the particular company, and not in his indi-
vidual name (r). His duty will be to take possession of
all the property of the company, and perform such other
acts in reference to the winding-up as the Court may im-
pose upon him (r). His powers will be to bring or defend
actions or suits, or institute prosecutions in the name or on
behalf of the company («), to realize the propei-ty of the
company (s), to prove in bankruptcy (s), to draw, accept or
indorse any bill or promissory note in the name and on
behalf of the company, to take out letters of administra-
tion to any deceased contributory, and do and execute all
matters that may be necessary for winding-up its affairs
and distributing its assets («). These powers may be
exercised with or without the sanction or intervention of
{o) 25 & 26 Vict. c. 89, s. 144.
[p) Id. s. 147. See Imperial Bank of China, L. R., 1 Ch. 339 ; Buckley,
270 ; In re London and Mercantile Discount Coinpani/, L. R., 1 Eq. 277; In
re Beaiijolais JFine Company, L. R., 3 Ch. 15.
{ri) In re Northumberland and Durham District Bankimj Compani/, 2
De G. & J. 508.
(>•) 25 & 2G Vict. c. 89, s. 94.
(s) Id. s. 95.
O. K K
498 WINDING-UP AND DISSOLUTION.
the Coui't of Chancery, if the Court has made an order to
that effect {t). Under a voluntary winding-up liquidators
are appointed by the company, and the powers given to
official liquidators may he exercised by them, without the
sanction of the Court (ii). They have power to settle the
list of eontril)utories, and the list will he prima facie exi-
deuce of the liability of the persons named therein as
contributories (??). Before ascertaining the sufficiency of
the assets, they may call upon the contributories to pay to
the extent of their liability, for the liquidation of the debts
of the company {,v), and in making calls take into conside-
ration the liability that some may fail to pay their respec-
tive proportions (x). They are also to adjust the rights of
the contributories amongst themselves {x). The liquidators
are also empowered, with the sanction of the Coiui, where
the company is being Avound up under its control, or
subject to its supervision, and with the sanction of an ex-
traordinary resolution of the company, when it is being
wound up voluntarily, to compromise calls, liabilities
and claims between the company, its contributories or
debtors (y) , and to pay or settle with its several classes of
creditors in full or otherwise (y) . The Court of Clianeery
will not compel a liquidator against his judgment to sanc-
tion a compromise of debts (~).
These arrangements will be binding on tlie company
and creditors, subject to the right of creditors to appeal to
the Com-t within three weeks of their eomjDletion (a). The
Court, in sanctioning a compromise, exercises a judicial
discretion, and will not direct the official liquidators to
conclude a compromise without the means of itself forming
an o])inion as to the propriety of the terms of the compro-
(t) 25 & 2G Vict. c. 89, ss. '.).), 9G ; Tiorjiuind v. 7u/7///, L. R., 4 Eq. 123.
{/<) Id. 8. 133; Buckley, 258.
(r) Id. s. 133.
{>/) Id. Hs. 159, IGO; Gen. Ord. it. 49, 50. This power extends to a
general compromise with the creditors as a class. Commercial Sank CoV'
poration nf India and the East, L. R., 8 Eq. 231.
{z) In re East of England Banking Coinj'an)/, L. R., 7 Ch. 309.
[a] To & 26 Vict. c.'89, ss. 136, 137.
LIQUIDATORS.
499
mise {h). Therefore, where official liquidators applied to
the Court to sanction a compromise, which had been pro-
posed by a body of thirty-five shareholders, to pay among
them an aggregate sum in discharge of their liabilities as
shareholders, but Avithout disclosing to the Court the parti-
culars or the data of such compromise, the Com-t refused
the application, althougli it was sworn that the compromise
was fomided upon details of property, and circumstances
which, if divulged, woidd operate detrimentally to the
thirty-five shareholders and to the interests of the com-
pany (J).
The liquidators are also empowered, with the like sanc-
tion of the Com-t or company, where the property of the
company is proposed to be sold to another company, to
accept shares in such other company as the consideration
of the purchase-money (r). Official liquidators of a bank
entered into a provisional contract with B. to sell him
property belonging to the bank for 16,000/. At a meeting
before the chief clerk in chambers, this contract was sub-
mitted for the approval of the judge, when it was objected
to by the creditors, who stated that C, another pm-chaser,
would give a higher price, and who afterwards offered
17,600/., it was held that the chief clerk was right in riot
adopting the provisional contract with B., if a larger sum
could be obtained, and the official liquidators were directed
by the Court to carry out the contract witli C. for
17,600/. {d).
The liquidators may appeal to the Com-t to determine
any question which may arise in the com-se of the exercise
of their powers, on a volimtary winding-up {e). They
have power also to call general meetings of the company,
and if the winding-up should be prolonged beyond twelve
[b) Kortlutmhcrhnd and Durham District Bank Coiiipau!/, Ex 2]((>-tc Tottij,
29 L. J., Chanc. 702,
(f) 25 & 26 Vict. c. 89, s. 161 ; Buckley, 315—320.
\d) In re KorthumherloM Distrirt Banking Compani/, 9 W. R. 584;
5 L. T., N. S. 633.
[e) 25 & 26 Viet. c. 89, s. 138.
K K 2
500 WINDING -UP AXD DISSOLUTIOX.
months, they must at the end of each year lay before the
meeting an account showing their acts and dealings and
the manner in which the winding-up has been conducted
during the preceding year (e) . In the case of a vacancy
in the office, another hcpiidator may be appointed, and the
Coui-t may remove any liquidator on due cause show^n (/).
Delinquent Kquidators, as we have seen, will be liable
to criminal prosecution {g).
We pi'oceed to mention the winding-up of the second
and third classes of banking companies.
Winding-up of Companies existing before 1862. — Banking
companies formed under the 7 & 8 Yict. c. 113, or under
the 21 & 22 Vict. c. 91, as limited, and respectively regis-
tered under the 20 & 21 Vict. c. 49, and the Companies
Act of 1862, will be wound up under the latter act {h),
and all its provisions with regard to banking companies,
formed and registered since the 2nd of November, 1862,
will apply, with this exception, that persons liable at law
or in equity, to contribute to the j)ayment of the debts or
liabilities of the company contracted prior to registration,
and for the adjustment of tlie rights of the members
among themselves, will be contributories in respect of such
debts and liabilities [i). The Court of Chancery may,
when the petition for the winding-up has been presented,
on the application of a creditor, restrain further proceed-
ings in actions or suits, as well against contributories as
against the company [k), and legal proceedings caimot
afterwards be commenced against contributories, without
the special leave of the Court (/).
The members of unlimited banking companies registered
under the 20 & 21 Vict. c. 49 (?/?), as limited banking com-
[e) 25 & 26 Vict. c. 89, s. 138.
(/) Id. 88. 140, 141 ; In re Sir John Moore Gold Mutiny Compauy,
12 Ch. D. 325.
{g) 25 & 26 Vict. c. 89, s. 165, ante, p. 486.
(//) Id. 83. 179, 180.
(0 Id. 8. 196.
(/,) Id. s. 197.
(/) Id. s. 198.
\m) Sect. 8.
OF COMrANlES EXISTING BEFORE 1862. 501
panies, on winding-up, will be liable beyond the amount
paid up on tbeir respective shares for the debts of the
company contracted or incurred previously to registra-
tion {n). The effect of registration in these instances is
to make the company limited quoad liabilities incurred
after registration, but unlimited quoad debts previously
contracted (ii).
So banking companies established under the 7 & 8
Geo. IV. c. 46, or under the 3 & 4 Will. lY. c. 98, or
banking companies not registered as limited or unlimited,
under the Companies Act of 1862, will be woimd up as
unregistered companies (o) under that act, with this ex-
ception, that no such company can be wound up volim-
tarily, or subject to the supervision of the com-t (p). The
circumstances under which such a company may be wound
up are : —
(1.) Whenever it is dissolved, or has ceased to cany on
business, or is carrying on business merely for
the purpose of winding-up (q).
(2.) Whenever it is unable to pay its debts (q).
(3.) Wlienever the Court is of opinion that it is just and
equitable that the company should be wound
up((7).
The circumstances under which an unregistered com-
pany will be considered as unable to pay its debts are
similar to those already detailed in regard to registered
companies {>•). The Court of Chancery has a similar
power of staying actions commenced by creditors against
the company or contributories, on the presentation of the
winding-up petition (.s), and of prohibiting the commence-
(«) Ux parte Stevenson, 32 L. J., Chanc. 96; Garnett Gold Mining Com-
pany of America v. Sutton, 13 W. E. 412 — Exch. Cham. See Lind. 1445,
and compare Fountain'' s case, 11 Jur., N. S. 553. As to the liability of
members of companies registered under the Act of 1862, see ante, p. 401.
(o) 25 & 26 Vict. c. 89, s. 199.
{p)Id. 8. 199 (2).
[q) Id. s. 199 (3).
(>•) Id. 8. 199 (4) ; and see ante, p. 493.
W Id. s. 201.
WINDING-UP AND DISSOLUTION,
nient of actions against contributories without its leave (t).
The rights and liabilities of contributories to creditors and
amongst themselves, under the winding-up, remain un-
affected by recent legislation as to these copartnerships [ti).
Having seen when and under what eu'cumstances banking
copartnerships and companies may be wound up, it be-
comes now necessary to point out the parties who are
liable as contributories, and the nature of their liability,
and the mode of enforcing it. These matters will be the
subject of the concluding portion of this chapter.
Contributories general///. — A contributory is defined, by
the Companies Act of 1862, to be every person liable to
contribute to the assets of the company, in the event of the
same being wound up ; and in all proceedings for deter-
mining the liability of contributories, any person alleged
to be a contributory (.t?). Grenerally, persons who are, or
who ought to be, members in accordance with the provi-
sions of the deed of settlement, or the regulations of the
articles of association of the company, will be contribu-
tories, either in theii' own right or as representing others.
Illustrations taken from the decisions of the cases will be
the best guides in determining who are contributories in
the absence of a more specific definition than is afforded
by the statute (y).
It must be carefully borne in mind, with reference to the
cases of contributories, that the liabilities of contributories
are not always equal ; each contributory is not always
liable for the whole expenditure of tlie company ; in the
cases respecting contributories, all that is decided, when
the Court orders that such a person shall bo placed on the
list of contributories of the company, is, not that ho is
necessai'ily in precisely the same situation, with respect to
{() 25 k 26 Vict. c. 80, ,s. 202.
((/) Id. 8. 200.
(x) Id. s. 74.
(y) Sec Buckley, 155.
bankrupt's trustek. 503
peoiiniary responsibility, as every other person who has
been or may be placed upon the list, but only that in
respect of shares that he holds or has held, (as his case
may be,) he is liable to bear some share or other in aid of
the liabilities of his fellow members of, or the debtors to,
the company. What he must eventually pay, as his pro-
portion of the losses, remains for subsequent investigation,
and the result depends on the number of shares he has
held, on the mode in which they were transferred to him,
the time during which he has held them, and a variety of
other cu-cumstances, and combinations of circumstances,
differing in almost each particular instance (::).
The 7 Geo. IV. c. 4G, s. 13, has no bearing on the
question who are contributories.
Ajyjjlicants and Allottees. — It is not necessary that a per-
son should be a shareholder to make him a contributory ;
all that is required is that there should have been a con-
cluded agreement to take shares under section 23 ; nor
is it necessary that the agreement should have been in
writing {a). In an ordinary case of an application for
shares, to constitute such an agreement, the letter of appli-
cation must generally be followed by an allotment which
must be communicated to the applicant (/>). But a person
may be a contributory if he has agreed to take shares,
even although there has been no allotment made to him [c]
or he has no notice of it {d).
Banknipfs Trustee. — A contributory becoming bankrupt
before or after he has been placed on the list of contribu-
tories, his trustee will be deemed to be a contributory, and
[z) ^QQ per Lord Cottenham, C, in Ex parte Mansfield [Earl), 2 Mac. &
G. 671.
(rt) Cookneri's case, 26 Beav. 6 ; Beese River Silver Mining Compani/ v. Smith,
L. R., 4 H. L. 64 ; Bloxam, Ex parte, 33 L. J., Chanc. 574 ; Buckley, 35—69.
{b) EeUafs ease, L. E., 2 Ch. 527 ; Uobbs' case, L. R., 4 Eq. 9 ; TJ'^ard's
case, L. E., 10 Eq. 659.
(r) Bird's case, 4 De G., J. & S. 200.
{d) Adams' case, L. E , 13 Eq. 474 ; Folder's case, L. E., 14 Eq. 316.
WINDING-UP AND DISSOLUTION.
may be called upon to admit proofs against his estate, or
to allow payments out of his assets in due course of law
of any moneys due from the bankrupt in respect of his
liability to contribute, and the estimated value of his lia-
bility to future calls may be proved against his estate (c).
Directors. — As to when directors, acting without the
necessary qualification in respect of shares prescribed by
the memorandum or articles of association, -will make
themselves liable as contributories in respect of such shares,
see p. 444.
Executors and Administrators. — On the death of a con-
tributory either before or after being placed on the list of
contributories, his personal representatives, heirs and de-
visees will be liable in due course of administration to con-
tribution, and his personal representatives, heirs and devisees
will be the contributories (/).
Executors holding shares merely as such, and never having
talicn to them as beneficial holders, are only liable to the
extent of the assets of those whom they represent ; the
liability is that of the estates of the original holders {g).
Females marrying. — A female marrying either before or
after being placed on the list of contributories, her husband
will dming the marriage be liable to contribute the same
.sum as she would have been liable to contriliute had she
not married, and he will be deemed the contributory (//).
A married woman, having separate estate, may make
herself a shareholder in her own riglit, provided the con-
tract was entered into on the credit of that estate, and that
the company's deed of settlement does not exclude married
women from becoming shareholders (/). But it would seem
(/•) 2.') & 26 Yict. c. 89, s. 77 and s. 7o.
(/) Id. «. 76.
[fj) Evans v. Covoifnj, 2') L. .J., Chauc 499.
{)<) 25 & 20 Vict. c. 89, s. 78.
(i) Mrs. Mfithcumaji^s case, L. R., 3 Eq. 781.
rRINCIPALS AND AGENTS. 505
lier husband is liable to be put on the list of eontributories
wdth her (/.•), unless she was known by the company to be
a married woman, and she, and not her husband, was
accepted as shareholder (/). If she has no separate estate,
the husband, as a general rule, will be liable even where
she has bought the shares with his consent and know-
ledge {»i). If, on the other hand, she is known to be a
married woman, and the company, notwithstanding, deal
with her as a principal, and the steps necessary by the deed
of settlement to constitute the husband a member have
not been taken, he would not, it seems, be liable, nor would
the wife {>}).
Infants. — An infant, it would seem, could not be put on
the list of eontributories unless his being put there should
happen to be for his benefit, as where there are surplus
assets (o).
Legatees. — If shares have been bequeathed and the
executor has assented to the bequest, and the legatee has
accepted it and been accepted by the company as a share-
holder, the latter, and not the executor, is liable as a con--
tributory (/;).
Principals and Agents. — A person taking shares, though
intending to do so as an agent only for another, will be
personally liable as a contributory, unless he states at the
time that he accepts only as agent {q) . But if he does so
and is in fact the authorized agent of that other he is not
liable but his principal (r).
{k) LuarcVs crisc, 1 De G., F. & J. 533; but see In re London, Bombay
und Mediterranean Bank, 18 Ch. D. 581, and ante, pp. 437, 438.
(/) Angas^s case, 1 De G. & S. 560.
{m) B'Oaseley's case, 18 Sol. J. 282.
(«) Ex parte' Rhodes, 7 W. R. 510.
(o) See Lindley, 1356.
[p) See Kccnc's Executors' case, 3 De G., M. k G. 272; CrossfchVs case,
2 ib. 128.
(q) Bird, Ex parte, 33 L. J., Bank. 49.
\r) Barrett's case, 4 D. J. & S. 200.
506 WINDING-UP AND DISSOLUTION.
Trustees. — The trustee is liable to be put on the list of
coiitributories aucl not the cestui que trust, nor is his lia-
bility limited to the amount of the trust estate (s). A
trustee of course, has his remedy against the cestui que
trust for indemnification (t).
Purchasers l)ij means of 3IisrepresentatioJi. — Persons in-
duced to piu-ehase shares in a comjiany through fraud
(provided the fraud is in law the fraud of the company),
can as against the company repudiate their shares («) ; but
as against creditors when the winding-up has commenced,
it is now finally settled no such repudiation can be made,
but that they must be put on tlie list of contributories {r).
Scrijiholdcrs. — A mere holder of scrip "will not necessarily
be liable as a contributory ; whether he will be so or not
depends on whether he holds the scrip as principal or as
agent for another. Therefore, where London bankers had
in their hands, at the date of the winding-up order, shares
belonging to their foreign corresi^ondents, on which they
were in the habit of receiving the dividends, they were
held not to be contributories (.r).
List of Contributories. — As soon as practicable after the
order for winding-up has been made, the official liquidator
settles the list of the contributories {ij). In settling this
list a distinction must be made between persons contribu-
tories in theu" own right and persons ^\\\o are representa-
tives of others or liable for their debts (;:).
In the case of a personal representative of a deceased
(«) Barrett" s case, supra; Hoarc^s case, 2 J. & H. 229; LcifchihVs case,
L. R., 1 Eq. 231 ; Muir v. Clt;/ of Glaf-goir Bank, 4 App. Cas. 337.
(/) Cruse V. I'aine, L. E., G Eq. 641 ; James v. May, L. R., 6 H. L. 328.
{><) Kish V. Central Bai/urn/ Conipani/ of Voiezuda, L. E., 2 H. L. 99.
(t) Oakcs V. Tarquand, L. E., 2 H. L. 325 ; Utonc v. Citi/ Bank, 3 0. P. D.
282 ; Cargill v. Boictr, 10 Ch. J). 502.
{x) Ex parte Finlay, 20 Beav. 182.
(>j) 25 & 2G Vict. c. 89, s. 98 ; Gen. Ord. it. 29—31. Sec Anderson' a
case, 17 Ch. D. 373.
(r) Id. 8. 99.
PAST MEMBERS. 507
coutribiitory being* placed on the list, it will not be neces-
sary to add his heirs or devisees. The heirs or devisees
may, however, be added as and when the Com-t may think
fit (^0.
On a voluntary winding-up the liquidator appointed by
the company has sunilar powers of settling the list, and
the list will be prima facie evidence of the liability of the
persons named therein as contributories {b). Persons dis-
satisfied with the insertion of their names on the list may
appeal (c).
Past Members. — There is only one list of contributories
as past members (called the B list), and all persons ceas-
ing to be members within the year are liable to be put on
it as soon as it appears that the contributions of present
members will be insufficient, and that the debts to be paid
were contracted previous to theu* retirement (d). kSo a
past member of a limited banking company who has trans-
ferred his shares within a year of the winding-up is liable
(if his transferee has not paid the unpaid capital on his
shares, and if the present members' contributions are in-
sufficient) to contribute, together with other past members,
to the assets of the company to the full amount of the
debts which were due at the date of the transfer, and which
were still unpaid at the date of the winding-up, but from
this amount must be deducted the dividends already re-
ceived from the present members (e). Each past share-
holder is liable to contribute to such unpaid debts, to the
extent of the amount unpaid on the shares by his trans-
feree, 2)ari passu with all the other past shareholders who
are liable for the same debts, and cannot require that the
past members who transferred their shares after his transfer
(ff)"25 & 2G Vict. c. 89, s. 99.
(b) Id. s. 133 (9).
(c) Id. s. 124.
{d) Id. s. 38 (2), (3). See BrctCs case, L. R., C C'li. 800; IFcbb v.
Whiffin, L. R., oH. L. 711.
(e) In re Oriental Commercial Bank, L. E,., 7 Ch. 200.
508 -WINDING-UP AND DISSOLUTION.
was registered should be exliausted before any call is made
on him (). The funds contributed by the B list of share-
holders become part of the general assets of the company,
and are not to be applied, preferentially or exclusively, to
the pajmient of those debts which were incurred before the
B shareholders retired (d). Compromises vdih some of
the existing members, effected by liquidators vnth the
sanction of the Court, will not operate as a release to past
members (e).
Bcctlfuing Ecgktcr on settling List. — On settling the
list of contributories the Court has likewise power to rec-
tify the register of the members of the company, under the
Companies Act, 1862, s. 35, whenever parties have been
improperly entered or omitted (/) .
Proof of Debts. — For the purpose of ascertaining the
debts of the company, the creditors are called upon, by
the official liquidator, to come in and prove their debts or
claims against the company. All debts payable on a con-
tingency, and all claims against the company present or
future, certain or contingent, ascertained or soimding only
in damages, shall be admissible to proof against the com-
pany ; a just estimate being made, so far as is possible, of
the value of all such debts or claims as may be contingent
or sounding only in damages {g).
Making Calls on Contrihiitories and Rigl/t of Sct-ojf. — The
Com-t of Chancery is empowered to make calls on tlie con-
tributories settled on the list to the extent of their liability,
for payment of tlie debts of the company and the costs,
charges and expenses of Avinding-up, and for tlio adjustment
(r) In re Oriental Commercial Jicail; L. R., 7 Ch. 200
{d) Webb V. Whijin, L. R., 5 H. L. 711.
(f) In re Jk/rncd's Jian/:, Jj. U., oil. L. 28; Hudson's case, L. R., 12
Eq. 1 ; Ilclbcrt v. Banner, L. R., 5 II. L. 28.
(/) 25 & 26 Vict. c. 89, ss. 35, 98, ante, p. 412. And see In re London,
Hamburg and Continental Exchange liank, L. R., 2 P]q. 226; 2 Ch. 431
as to when the Court will excrci.se this power.
{g) Id. ft. 158; Gen. Ord. rr. 20-28. Pec Burkloy. pp. 2S0— 311.
MAKING CALLS ON CONTRIBUTORIES AND RIGHT OF SET-OFF. 509
of the rights of the coiitribiitorles amongst themselves, and
in making a call the Court may take into consideration
the probability that some of the contributories may fail to
pay their proportions (j). Making a call is within the
discretion of the Court ; and the call will not be made
if the Court is satisfied that there are sufficient assets
in the hands of the liquidators; but it will be made if
there are only outstanding assets, the realization of which
is doubtful both as to amount and time (/.•). A liquidator
under a voluntary winding-up has similar powers (/). In
making an order for payment of a call on a contributory,
when the company was not limited, it was held by Malins,
V.-C, that the contributory might be allowed to set off
any moneys due to him from the company on any inde-
pendent dealings or contracts with the company {in) ;
but Mr. Justice Fry has refused to follow this decision,
and has decided that, in the winding-up of a company
with unlimited liability, a contributory has no right to set
off debts due to him by the company against calls made on
him by the liquidator {ii). So, too, where the company is
limited, and that whether the winding-up is voluntary or
compulsory (o). But when all the creditors of the com-
pany, whether limited or unlimited, have been paid in
full, moneys due on any account whatever to any contri-
butory from the company may be set off against any
subsequent call or calls (7;). An order for a caU is con-
clusive evidence that the call is due, and all other pertinent
matters stated in the order are to be taken to be truly
stated as against all persons (7), with the exception of
[j) 25 & 26 Vict. c. 89, s. 102.
{k) In re BarnccVs Bank, L. R., 5 H. L. 28.
{I) 25 & 26 Vict. c. 89, s. 133 (9).
{m) Gibbs and JFest^s case, L. R., 10 Eq. 312; GrlsaelVs case, L. R.,
1 Ch. 528.
(«) Ex parte Branuhite, 48 L. J., Ch. 463 ; 40 L. T. 652.
(o) GrisseWs case, L. R., 1 Ch. 528; In re Whitehouse, 9 Ch. D. 595.
As to the efEect of sect. 10 of Judicature Act, 1875, see GilVs cane, 12 Cli.
D. 755.
{p) 25 & 26 Vict. c. 89, s. 101. Gibbs and West's case, L. R., 10 Eq.
312.
{q) Id. s. 106.
510 WINDING-UP AND DISSOLUTION.
proceedings taken against the real estate of a deceased
contributory, when the order will he only ^;;'M»d facie evi-
dence for the purpose of charging his real estate, unless
his heirs or devisees were on the list of contrihutories at
the time when the order was made ((/) . A right of appeal
is however given against any order that may be made or
that is sought to be enforced against a contributory or his
representatives (>•).
Nature of LiahiUty. — Calls made on the winding-up of
a banking company, formed under the Companies Act of
1862, will create a specialty debt clue from the contributory,
and will not be barred till the lapse of twenty years (s).
Extent of LiahUitij undertahen hij Transferee. — As a
general rule the liability of the transferor is, as between
the company, the transferee and himself, transferred to the
transferee by the transfer of the shares ; so a transferee of
shares iu a banking company, established under the 7 Geo.
IV. c. 46, was held liable as a contributory in respect of
debts contracted as well before as after the transfer, there
being no provisions in the deed of settlement of the com-
pany in any way limiting such liability {t).
So where the name of a person wlio had purchased
shares in a similar banking company was after its stoppage
placed on the list of contrihutories, but only from the date
at which he made the purchase, this qualification of his
liability was struck out on appeal (?/).
Enforcing Calls. — The mode by which calls are en-
forceable is by the service of the summons of the order
for the call on the contrihutories, or their representatives,
requuing payment to be made to the official liquidator
(7) 25 & 2G Vict. c. 89, s. 106.
(/•) Id. 8. 124.
(«) Cork and Bamloii liailwHi/ Compnnij v. Goodc\ 13 C. B. 82G. See also
Ex parte Itobiiison, 6 De Gr., Mac. & G. 572 ; 26 L. J., Chanc. 95.
[t) Kt parte Cape, 2 De G., Mac. & G. 562 ; 22 L. J., Chauc. GOl.
[it) HcudtrMn v. Jhiidrrsoii, L. E., 3 II. L. 698.
DISSOLUTIOX ON WINDING-UP. 511
of the amount therein mentioned and at a specified time,
which if not complied with, an attachment or a sequestra-
tion according to the practice of the Court may be issued
against the defaulters (,r). In the case of a voluntary
winding-up, application must be made by the liquidator
to the Court for its aid to enforce calls (//).
If the representative of a deceased contributory makes
default in paying a call, proceedings may be taken for
administering either his personal or real estate and of
compelling payment thereout of the calls (z).
A contributory may be arrested upon proof of probable
cause being given to the Coui't, either before or after
making the winding-up order, of his intention to quit or
abscond from the United Kingdom for the pm^pose of
evading payment of calls (a). An order for the pajanent
of calls made in England may be enforced in Ireland or
Scotland against contributories (A).
Dissolution on Winding-up, — In the case of a compul-
sory winding-up, a company will be deemed to be dis-
solved when its affairs have been completely wound up,
and an order has been obtained from the Court of Chan-
cery dissolving the company [c) . The official liquidator
must report the order to the registrar who will make a
minute in his books of the dissolution of the company {d).
Should he fail in reporting the order, he will incur a
penalty not exceeding 5 A for each day of delay ((>). In
the ease of a voluntary winding-up, as soon as the affairs
of the company have been fully wound up, the liquidators
(.(■) 25 & 26 Vict. c. 89, n. 101 ; Gen. Orel. r. 35, and Forms 38, 39, 42,
(y) Id. s. 138.
{z) Id. s. 105.
(«) Id. s. 118. See //; re Imperial 3IciT(i/ifUe Credit Company, L. R., 5
Eq. 264.
{b) Id. ss. 122, 123.
[c] Id. s. Ill ; and see form of Order, No. 56, Gen. Ord., 11th Nov.
1862.
{d) Id. s. 112.
(e) Id. 8. 113.
512 WINDING-UP AND DISSOLUTION.
must make up an account showing tlie manner in which
the winding-up has been conducted, and the property of
the company disposed of (/) ; and the liquidators are then
to call a general meeting of the company for the pm-pose
of laying this account before the meeting, and hearing
their explanations {/). The liquidators are afterwards to
make a return of the holding of the meeting to the regis-
trar, and, on the expiration of three months from the date
of the registration of this return, the company will be
deemed to haA'e been dissolved (g) . If the liquidators fail
to make the retm-n, they mil incur a penalty not exceeding
5/. for every day of default {(j).
Other Modes of Winding-up. — Independently of the
procedure provided by the Companies Act of 1862 for
winding-up and dissolving a banking company, there is
another mode which it may be useful to mention. It is
usual for promoters to state in their prospectus, that they
reserve to themselves the right of returning the deposits,
with or without certain deductions for preliminary ex-
penses, shoidd the proposed capital not be subscribed, or
from any other event the project should fail in their
opinion to be practicable. This being a legal stipulation
is binding upon all parties and is illustrated by the follow-
ing case {h) : —
The directors of a projected bank, not being able to carry
out the project to its full extent, determined upon winding-
up and returning the deposits. Deposits amounting in
the whole to two-thirds of the subscriptions had been re-
tui'ncd, and the remainder was in com'se of liquidation.
A bill was filed by purchasers of shares or intended shares
who were dissatisfied with the termination of the proposed
bank ; and it was held, that the directors were justified in
the coiu'se they had taken, it being morally impossible
(/) 25 & 2G Vict. c. 89, s. 142.
() Id. B. 14.1.
(//) Haul: nf Sirilzn-lioid v. liati/: of Tnrlci/. 5 L. T., N. S. .')-10.
COLONIAL BANKS.
513
that the project coukl have been carried out in its integrity
from the events which had happened (/).
But if the company is not incorporated either according
to foreign or English law, and therefore never in existence
as a company, it cannot he woimd up imder the Companies
Act, 18G2 (/.•).
Colonial Banks.— The Eoyal Bank of Australia was
wound up in Chancery under the Acts of 1848 and 1849 ;
the petitioner for the winding-up order, a shareholder in
the hank, heing described in his petition as of a place out
of the jurisdiction, was ordered to give security for costs
before his petition could be heard ; and proceedings taken
in Scotland against the petitioner, in respect of a debt due
from the company, were held to furnish proper ground for
a wanding-up on his petition (/).
But the Court of Chancery refused to make an order
winding-up the Union Bank of Calcutta, established in
India in 1829, on the ground that substantial justice could
not be done in this country {m) .
(0 Bank of Switzerland v. Bank of Turkey, 5 L. T., N. S. 549.
[k) In re Imijcrlal Anglo-German Bank, 26 L. T., N. S. 229.
{l) Ex parte Latta, 3 De G-. & S. 186.
\m) Watson's case, 3 De Q. & S. 253.
G.
L L
( 014 )
CHAPTER LVI.
BANKRUPTCY.
In tlie following chapter it is proposed to state as shortly
as possible the law relating to bankruptcy.
Who may be WIio may he made Banhntpts. — Generally speaking,
m^ te ^^^^' every person capable of making a binding contract is also
capable of being made a banki^upt, either as a trader or
non-trader {a). By the Bankruptcy Act, 1869, Sched. 1,
bankers are expressly declared to be traders liable to the
bankrupt laws ; and all persons, it would seem, are to be
deemed bankers who act as such, although they may not
keep banking houses [h) .
Married Married Women. — A married woman is not ordinarily
women. \ir^\^\Q to bankruptcy (r) ; but where, by the custom of
London, she is trading as a feme sole {d), or where her
husband is civilly dead {e), or in exile {e), or she is living
apart from him under a decree of judicial separation or
order of protection, she may be made a bankrupt (/). A
married woman, however^ cannot be made a bankrupt in
respect of her separate estate {[/).
(a) Robson on Bank. j). 99.
{b) Ejrpartc JFilson, 1 Atk. 217 ; Richardson v. Bradshaic, ih. 129. For
definition of trader, see sched. 1 .
(f) Robson on Bank. p. 99.
{d) La Vie v. FhilUps, 3 Burr. 177G ; Ex parte Carrington, 1 Atk. 20G. _^
(e) Sparrow v. Carruthcrs, cited 2 W. Bl. 1197; Ex parte Franks, 7
Bmg. 769.
(/) 20 & 21 Vict. c. 85, ss. 21, 25, 26 ; 41 & 42 Vict. c. 19 ; Ramsdett
V. Brearletj, L. K, 10 Q. B. 147 ; 44 L. J., Q. B. 46.
() Ex parte Holland, L. II., 9 Ch. 307; 43 L. J., Bauk. 85; Ex parte
Jones, re GrUsell, 12 C'h.D. 484 ; 48 L. J., Bank. 109.
FOREIGNERS. 515
Infants. — An infant cannot be made a "bankrupt, unless, Infants,
perhaps, for necessaries supplied to him {h), nor can he
render himself liable to be made so by ratifying the debt
on attaining his majority (/). An infant who has traded
cannot be adjudicated a bankrupt on the petition of a
person who has supplied him with goods on credit for
trade purposes, but to whom he has made no express
representation that he is of full age, even though he has
previously filed a liquidation petition, the proceedings
under which have become abortive. Nor could the Court
under such circumstances make an adjudication against
the infant under sub-section 12 of section 125 of the Bank-
ruptcy Act, 1869. Whether, if the infant had expressly
represented to the petitioning creditor that he was of full
age, an adjudication could be made quccrc. The Infants'
Eelief Act, 1874, applies to the trading contracts of an
infant {J ) .
Foreigners. — The English Court of Bankruptcy has Foreigners.
p7'md facie no jurisdiction to make an adjudication of
bankruptcy against a foreigner domiciled and resident
abroad who has never been in England, even though he
is a member of an English firm which has traded and
contracted debts in England (/.•). A foreigner, however,
domiciled abroad, who contracts debts in England or
abroad, is liable to be made a bankrupt under the Bank-
ruptcy Act, 1869, if he commits an act of bankruptcy in
England, although he may have left England before the
petition for adjudication is presented. But he cannot be
made a bankrupt upon an alleged act of bankruptcy com-
mitted abroad (/).
{h) Bx parte Jones, 18 Ch. D. 109 ; 50 L. J., Ch. 673.
(i) 37 & 38 Vict. c. 62 ; Ex parte Hihhle, L. R,, 10 Ch. 373 ; U L. J.,
Bank. 63 ; Malney, In re, 3 L. R., Ir. 459.
{J) Ex parte Jones, supra, overruling Ex parte Lynch, 2 Ch. D. 227.
[k) main. Ex parte, Sawyer, In re, 12 Ch. D. 512 ; 41 L. T. 46-C. A.
(0 Ex parte Crispin, L. R., 8 Ch. 374 ; 42 L. J., Bank. 65 ; 28 L. T.
483; 21 W. R. 491 ; Fascal, Ex parte, 3[ycr, In re, I Ch. D. 509 ; 45 L. J.,
Bank. 81 ; 34 L. T. 10 ; 24 W. R. 202.
I, 1, 2
>16
BANKRUPTCY.
Undischarged
bankrupt.
Companies.
Petition for
adjudication
in bank-
ruptcy.
Undischarged Bcinlcnqit. — An adjudication of bankruptcy
against an undischarged bankrupt who has been permitted
by the trustee to resume and continue business is good (/).
Conipaiiics. — Neither partnerships, associations, nor bodies
corporate registered under the Companies Act, 1862, can
be adjudicated bankrupt {m). Such companies must be
wound up, as explained in a pre\dous chapter (n) .
Adjudication. — By sect. 6, "A single creditor, or two
or more creditors if the debt due to such single creditor, or
the aggregate amount of debts due to such several creditors,
from any debtor, amount to a sum of not less than fifty
pounds, may present a petition to the Court, praying that
the debtor be adjudged a bankrupt, and alleging as the
ground for such adjudication any one or more of the
following acts or defaults hereinafter deemed to be and
included under the expression ' acts of bankruptcy :'
" (1.) That the debtor has, in England or elsewhere,
made a conveyance or assignment of his pro-
perty to a trustee or trustees for the benefit of
his creditors generally (o) :
" (2.) That the debtor has, in England or elsewhere,
made a fraudulent conveyance, gift, delivery,
or transfer of his proj)erty or of any part
thereof (jj) :
" (8.) That the debtor has, with intent to defeat or delay
his creditors, done any of the following things,
namely, departed out of England {q), or being
(l) Sx parte Watson, 12 Ch. D. 380.
{m) Sect. 5.
(«) See ante, p. 490.
(o) That is to say, a conveyance or assignment of all his property (sco
Robson, p. 123). As to when such a transaction comes within 13 Eliz.
c. 5, and can be set aside as tending to defeat and hinder creditors, see
Spencer v. Slater, 4 Q. B. D. 13 ; BoUhro v. London JJiscount Co., 5 Ex. D.
47 ; Tirt/ne^s case, 1 Sm. L. Ca. 7th ed. p. 12.
( p) For general summary as to the result of the cases decided under
this paragraph, and as to what amounts to a fraudulent conveyance, see
ante, p. 184 ; and E.c parte Dann, 17 Ch. D. 26.
(<7) See Ex parte Crispin, L. K., 8 Ch. 374 ; 42 L. J., Bank. 65, The
consequence of his departure must be to delay creditors. Ex parte
Mutric, Yes. 376; Ilolroi/d v. IFhitehtad, 3 Camp. 530.
ADJUDICATION.
out of England remained out of England (r) ;
or being a trader departed from his dwelling-
house, or otherwise absented himself (•*) ; or
begun to keep house {t) ; or suffered himself
to be outlawed :
" (4.) That the debtor has filed in the prescribed man-
ner in the Court a declaration admitting his
inability to pay his debts {u) :
" (5.) That execution issued against the debtor on any
legal process for the purpose of obtaining pay-
ment of not less than fifty pounds has in the
case of a trader been levied by seizure and sale
of his goods ix) :
" (6.) That the creditor presenting the petition has
served in the prescribed manner on the debtor a
debtor's summons requiring the debtor to pay a
sum due, of an amount of not less than fifty
pounds, and the debtor being a trader has for
the space of seven days, or not being a trader
has for the space of three weeks, succeeding the
service of such summons, neglected to pay such
sum, or to secure or compound for the same {y) .
{)■) See Ex parte Bunneij, 32 L. J., Bank. 41 ; Ex parte Crispin, supra.
(*) See Wydoivn'scase, 14 Ves. 86; Ilolroyd v. Whitehead, supra ; Mills
V. Bennett, 2 Rose, 269 ; Ex parte Meyer, L. R., 7 Ch. App. 178.
{t) If bankers close the doors and windows of the bank, and their
customers cannot obtain admission, this is " beginning to keep house."
Cmmning v. Bailey, 6 Bing. 363 : see further Ex parte Foster, 1 Rose, 50.
This will be inferred from debtor giving an order to be denied to creditors.
Mitehlow V. May, 1 Taunt. 179. Stopping payment is not of itself an act
of bankruptcy. Hatckins v. Whitten, 10 B. C. 217.
(?/) The declaration must be signed, dated and witnessed according to
Form 1 in the schedule, and filed in the Bankruptcy Court. See Rule 16.
As to when the filing of the declaration is complete, see Ransford v.
Maule, L. R., 8 C. P. 672 : 42 L. J., C. P. 231.
(:r) By sect. 87, where the goods of a trader have been taken in execu-
tion in respect of a judgment for a sum exceeding 50/., the sheriff must
retain the proceeds of the sale for fourteen days : and, if notice is served
on him within that time of a banki'uptcy petition against such trader, he
must hold the proceeds in trust to pay the same to the ti-ustee. See Ex
parte Villars, L. R., 9 Ch. 432 ; 43 L. J., Bank. 76; Ex parte Brooke,
L. R., 9 Ch. App. 301 ; Ex parte Keys, L. R., 10 Eq. 432 ; 39 L. J.,
Bank. 28 ; Ex parte James, L. R., 9 Ch. App. 609.
(y) See Rvdes 15, 17—25, and 41, 59, 61, 62, 63, 64, and Forms 4—9.
As "to who may take out a debtor's summons, see Ex 2}artc Carter, 2
617
518
BANKRUPTCY.
Proceedings
in relation
to a debtor's
summons.
No person, however, " shall be adjudged a bankrupt on
any of the above grounds unless the act of bankruptcy on
which the adjudication is grounded has occurred within
six months before the presentation of the petition for
adjudication ; moreover, the debt of the petitioning
creditor must be a liquidated sum due at law or in equity
and must not be a secured debt, unless the petitioner state
in his petition that he will be ready to give up such
security for the benefit of the creditors, in the event of
the debtor being adjudicated a bankrupt (z), or unless the
petitioner is willing to give an estimate of the value of his
security, in which latter case he may be admitted as a peti-
tioning creditor to the extent of the balance of the debt
due to him after deducting the value so estimated, but he
shall, on an application being made by the trustee within
the prescribed time after the date of adjudication, give up
his security to such trustee for the benefit of the creditors
upon payment of such estimated value " («).
By sect. 7, "A debtor's summons may be granted by the
Court on a creditor proving to its satisfaction that a debt
sufficient to support a petition in bankruptcy is due to him
from the person against whom the summons is sought, and
that the creditor has failed to obtain payment of his debt,
after using reasonable efforts to do so. -The summons
shall be in the prescribed form, resembling, as nearly as
Ch. D. 806 ; Ex parte Harris, 2 Ch. D. 423 ; Ex parU Brorldehanlc, 6 Cli. D.
358 ; 46 L. J., Bank. 113 ; Ex parte Shepherd, 10 Gh. D. 673 ; 48 L. J.,
Bank. 35. A debtor so served may apply to have it dismissed, on the
ground that he is not indebted (r. 22). f>ee Ex parte Barron, L. R., 10
Ch. 269 ; Ex parte Ellis, L. R., G Ch. 602. As to proof of service, sec Ex
parte Rogers, 15 Ch. D. 207.
(r) See ^j; parte Good, 14 Ch. D. 82; 40 L. J., Bank. 49; Ex parte
English a>/d American Bank, L. R., 4 Ch. 49; Ex parte Manchester and
Liverpool Bank, L. R., 18 Eq. 249.
(a) The value so assessed is binding on the creditor. {Ex parte King,
L. R., 20 Eq. 273 ; 44 L. J., Bank. 92.) The trustee is not so bound, for
he may order the security to be realized (r. 136). The trustee can redeem
the security at its assessed valuation (r. 100). By sect. 12, a secured cre-
ditor, notwithstanding bankrujjtcj', can realize liis security. As to ■when
his right to count as a secured creditor is contested, see r. 78. See, as to
deduction of value of security. Ex parte West Biding Union Banking Co.,
10 Ch. D. 105.
ADJUDICATION. 510
circumstances admit, a writ issued hy one of Her Majesty's
Superior Courts. It shall state that in the event of the
debtor failing to pay the sum specified in the summons, or
to compound for the same to the satisfaction of the creditor,
a petition may be presented against him praying that he
may be adjudged a bankrupt. The summons shall have
an endorsement thereon to the like effect, or such other
prescribed endorsement as may be best calculated to
indicate to the debtor the nature of the document served
upon him, and the consequences of inattention to the
requisitions therein made (b) .
" Any debtor served with a debtor's summons may apply
to the Coiu't, in the prescribed manner and within the
prescribed time to dismiss such summons, on the ground
that he is not indebted to the creditor serving such
summons, or that he is not indebted to such amount as will
justify such creditor in presenting a bankruptcy petition
against him ; and the Coui't may dismiss the summons,
with or without costs, if satisfied with the allegations
made by the debtor, or it may, upon such security (if any)
being given as the Coui't may require " (r).
The bankruptcy of a debtor is, by section 11, " deemed Defiuitiou of
to have relation back to and to commence at the time of the commence-
raent oi bixnk-
act of bankruptcy being completed on which the order is ruiDtcy.
made adjudging him to be bankrupt; or if the bankrupt
is proved to have committed more acts of bankruptcy than
one, to have relation back to and to commence at the tune
of the first of the acts of bankruptcy that may be proved
to have been committed by the bankrupt within twelve
months next preceding the order of adjudication ; but the
bankruptcy is not related to any prior act of bankruptcy,
unless it be that at the time of committing such prior act
the bankrupt was indebted to some creditor or creditors in
(b) See further, r. 22. As to who may take out a debtoi''s summons,
see Ex 2J((rtc Kibble, L. R., 10 Ch. 373 ; In re BrocUchank, G Ch. D. 358 ;
Ex parte Shepherd, 10 Ch. D. 572.
(c) For the j)roceecliiigs on a debtor's summons, sec rr. 22, 23, 50, 61,
63, 64, sect. 7 ; and for proceedings on petition, see rr. 26 — 48.
520
BANKRUPTCY.
Creditors
bound by
bankruptcy
liroceedings.
a sum or sums sufficient to support a petition in bankruptcy,
and imless such debt or debts are still remaining due at the
time of the adjudication" id).
" Where a debtor shall be adjudicated a bankrupt, no
creditor to whom the bankrupt is indebted in respect of
any debt provable in the bankruptcy shall have any re-
medy against the property or person of the bankrupt in
respect of such debt except in manner directed by this
act"(f).
By sect. 13, the Court may, after a presentation of a
petition, restrain actions against the debtor in respect of
debts provable in banki'uptcy and appoint a receiver.
Meeting of
• Teditors for
appointment
(if persons to
administer
bankrupt's
property.
Appointment of Trustee. — By sect. 14, " When an order
has been made adjudging a debtor bankrupt, herein re-
ferred to as an order of adjudication, the property of the
bankrupt shall become divisible amongst his creditors in
proportion to the debts proved by them in the bankruptcy;
and for the purjDose of effecting such division the Court
shall, as soon as may be, summon a general meeting of his
creditors, and the creditors assembled at such meeting shall
and may do as follo"\\'s :
"1. They shall, by resolution, appoint some fit person,
whether a creditor or not, to fill the office of
trustee of the property of the bankrupt at such
remuneration as they may from time to time
determine, if any ; or they may resolve to leave
his appointment to the committee of inspection
hereinafter mentioned :
They shall, when they appoint a trustee, by reso-
lution declare what security is to be given, and
to whom, by the persons so appointed, before he
enters on the office of trustee :
t( o
(d) Sec i:.r parte Grepe, 50 L. J., Ch. 723 ; Kc paric GUhoj, 8 Ch. D.
218 ; 47 L. J., Bank. 49.
((?) Sect. 12. As to the effect of bankruptcy on secured creditors, see
ante^ p. 518.
APrOINTMENT OF TRUSTEE, 521
" 3. Tliey shall, by resolution, appoint some other fit
persons not exceeding five in number, and being
creditors, qualified to vote at such first meeting of
creditors as is in this act mentioned, or authorized
in the prescribed form by creditors so qualified to
vote, to form a committee of inspection for the
purpose of superintending the administration by
the trustee of the bankrupt's property :
" 4. They may, by resolution, give directions as to the
manner in which the property is to be adminis-
tered by the trustee, and it shall be the duty of
the trustee to conform to such directions unless
the Court for some just cause otherwise orders."
By sect. 15, " The property of the bankrupt divisible Descriptions
amongst his creditors, and in this act referred to as the property divi^-
property of the bankrupt, shall not comprise the following ^^^^^. amongst
• T / /i\ creditors.
particulars (/ ) :
" (1.) Property held by the bankrupt on trust for any
other person {g) :
" (2.) The tools (if any) of his trade and the necessary
Avearing apparel and bedding of himself, his
wife and children, to a value, inclusive of tools
and apparel and bedding, not exceeding twenty
pounds in the whole :
(/) Sect. 15. "Property" is defined by tte act, sect. 4, as meaning
money, goods, things in action and every description of property, real or
personal ; also obligations, easements and every description of estate,
interest and profit, present or future, vested or contingent, arising out of
or incident to property as above defined.
((/) This applies both to express and implied trusts. So property in the
hands of a bankrupt factor is protected. {Tai/lor v. Phoner, 3 M. & S.
562.) See also, as to implied trusts. Ex parte Ellis, 1 Atk. 101 ; Ex parte
Barber, 28 W. R. 522. So also to money in the liands of a trustee, the
cestui que trust ha^dng a charge pro tanto upon the balance in the hands
of the banker of the bankrupt trustee. {Harris v. I'ruman, 7 Q. B. D.
240 ; 50 L. J., Q. B. 633 ; Ex parte Cooke, 4 Ch. D. 123 ; Kingston, Ex
parte, 13 Ch. D. 696 ; 49 L. J., Ch. 415, ante, p. 239.) Property held on
a bona fide express (and sometimes on an implied) trust is also exempted
from the operation of the reputed ownership clause (sub-s. 5). {Martin,
Ex parte, 19 Ves. 491 ; Harris v. Truman, supra; Ex parte Buck, 3 Ch. D.
795 ; Brir/ht, Ex parte, 10 Ch. D. 501.) Again, as we have already seen,
property held by the bankrupt for a specific purpose is protected. Thus
bills sent to a banker for a specific purpose and still remaining in specie
do not pass to the banker's trustee. See ante, 138, whore the subject has
been fully discussed.
522
BAXKRUrXCY.
Earnings.
Property of
"wife.
Pay or pen-
sion.
Fraud.
Disclaimer of
onerous con-
tracts.
"What actions
pass to trus-
tee.
" But it shall comprise the following particulars :
" (3.) All such property as may belong to or be vested
in the bankrupt at the commencement of the
bankruptcy, or may be acquired by or devolve
on him during its continuance (A) :
" (4.) The capacity to exercise and to take proceedings
for exercising all such powers in or over or in
respect of property as might have been exercised
by the bankrupt for his own benefit at the com-
mencement of his bankruptcy or during its
continuance, except the right of nomination to
a vacant ecclesiastical benefice (/) :
(/;) Money earned by the bankrupt "when carrying on a trade, as distin-
guished from mere personal labour, during his bankruptcy passes to the
trustee. [Ex parte Banks, 4 Ch. D. 689 ; 46 L. J., Bank. 74 ; Emdcn v. Carte,
17 Ch. D. 169, 768; 50 L. J., Ch. 492.) As a general rule all such interests
as a husband possesses by marriage in his wife's property, and he can dis-
pose of, passes to his trustee on his bankruptcy. {Miles v. WiUiains, 1 P. &
W. 249; Greij v. Kentish, 1 Atk. 280.) As regards her choses inaction, see
Mitford V. Mitford, 9 Ves. 187; and as to her right to an equity to a settle-
ment, Murray v. EUihank, 10 Ves. 90; Wliite & Tudor's L. C. 3rd ed.
vol. i. p. 388.
The pay, pension or salary of an officer in the army, fiavy or Civil
Service, or the pension granted by the Treasury, pass to the trustee.
(See sect. 89.) So the Coui't has power to order payment of any part of
a salary or income received by the bankrupt other than in the way just
mentioned. (Sect. 90.) A mere voluntary allowance made to the bank-
rupt is not "income" within the section. Ex parte Wicks, 17 Ch. D. 70.
As a general rule, property obtained by the bankrupt by fraud, or left
■with him entirely by mistake, will not pass to his trustee. Ex parte
Barnctt, 3 Ch. D. 123 ; Lindsay v. Candy, 2 Q. B. D. 96 ; Ex parte
Whittakcr, 10 Ch. D. 440; 44 L. J., Bank. 91.
By sect. 23 the trustee is enabled to disclaim in writing (see Tl'ilson
V. iralluin, 5 Ex. D. 15.5), property burdened with onerous covenants,
or umiiarketable shares, or unprofitable contracts, or unsaleable pro-
perty, &c., &c. {Ex parte TFallon, 17 Ch. D. 746; In re West of Enq-
land Bank, 12 Ch. D. 228 ; 48 L. J., Bank. 764 ; Ex parte Walton, 17 Ch.
D. 746 ; Ex parte Ladhury, ib. 532 ; Ex parte Glcgg, 19 Ch. D. 7.) In
the case of leases leave to disclaim ought to be obtained. (Rule 28 ;
Ex parte Ladbury, supra ; Ex parte Sadler, 19 Ch. D. 122.) Any person
injured by such disclaimer may prove to the extent of the injury done to
him. (Sect. 23; Ex parte Blake, 11 Ch. D. 572.) As to the time in
■which tru.stee must disclaim, sec sect. 24 ; Banner v. Johnston, L. R.,
6 H. L. 157 ; Ex parte Itichardson, Be Harris, 16 Ch. D. 613. As to the
liability of trustee before and after disclaimer, see In re Sneezum, 8 Ch.
D. 4C3 ; 45 L. J., Bank. 137; Ex parte Dressier, 9 Ch. D. 252 ; Lowrojy.
Barker, 5 Ex. D. 170.
(/) An undischarged bankrupt is capable of making a contract ; but
should the trustee choo.se to interfere and take the benefit of it, ho may,
as a general rule, do .so. {Herbert v. Saycr, 5 Q. B. ]). 965; Jameson v.
Brick and Stone Co., 42 Q. B. D. 208.) Actions for personal torts do not
pass. {Beckham v. Drake, 2 H. L. 579.) As to trustee's power generally,
see sect. 25.
APPOINTMENT OF TRUSTEE.
523
" (5.) All goods and chattels being, at the commencement
of the bankruptcy, in the possession, order or
disposition of the bankrupt, being a trader, by
the consent and permission of the true owner,
of which goods and chattels the bankrupt is
reputed owner, or of which he has taken upon
himself the sale or disposition as owner ; pro-
vided that things in action other than debts
due to him in the course of his trade or busi-
ness, shall not be deemed goods and chattels
"within the meaning of this clause" (/r).
(k) As to what are ffoods and cltattels, see Robson, p. 497. Fixtures are Reputed
not chattels till severed. [Horn v. Baker, 9 East, 215 ; 2 Sm. L. C. 7th ownership
ed. p. 205.) Bills and notes are chattels within the section, see Robson,
498. Choses in action are, by the concluding words of the paragraph,
exempted, except debts due to the banki-upt in the coiu-se of his business.
Shares, as we have seen, are not choses in action for this purpose. {Ex
parte Union Bank of Manchester, L. R., 12 Eq. 354 ; 40 L. J., Bank. 57,
ante, p. 163.) Aliter, a debenture of a joint stock company, Ex parte
Ecnsburg, 4 Ch. D. 685 ; and a policy of insurance, Ex parte Ibbetson,
8 Ch. D. 519 ; and see ante, p. 161.
The goods must have been actually in the possession, order and dis- Possession
position of the bankrupt : or constructively so, as where they are in the order and dis-
bands of his agent. {Hornabi/ v. Millar, 1 E. & E. 192.) He must, position,
moreover, have had them in his sole possession, order and disposition ;
and, consequently, where the goods of a third person were in the joint
possession of a bankrupt and his partner, who was solvent, it was held
that they did not pass to the trustee of the former. [Ex parte Dorman,
L. R., 8 Ch. 51 ; 42 L. J., Bank. 20. See also Ex j'X'rte Fletcher, 8
Ch. D. 51 ; Ex parte Mai/man, ib. 11.) As to when property has been
assigned by a bill of sale given by the bankrupt, see Chapter on Bills
of Sale. Goods taken imdcr a distress, or otherwise riffhtfiilhj in the
custody of the law, are not within the clause. [Taylor v. Eckersleij, 5
Ch. D. 740.) As to the necessity of giving notice in the case of equitable
deposits to exclude the operation of this clause, see ante, p. 161 et seq.;
and as to the effect of change of fu'm, see Ex parte Sprajuc, 6 D. M. &
G. 866 ; Ex parte Burton, 1 Gl. & J. 207. •
The goods must be in the possession of the bankrupt as reputed owner: Reputed
whether they are so or not is a question of fact. [Ex parte Jf'atkins, owner
L. R., 8 Ch' 520 ; 42 L. J., Bank. 50.) Possession for any length of
time will raise a strong presumption that they are the bankrupt's (see
Lingham v. Biffffs, 1 B. & P. 82) ; on the other hand, that presumption
can be rebutted by showing the existence of a well-established usage or
custom of trade (a custom which the ordinary creditors, and not only
those of a particular class, may be presumed to have known) to leave
particular goods in the possession of persons who are not the true owners of
them [Ex parte Ton-ell, 1 Ch. D. 501 ; 45 L. J., Bank. 100 ; Ex jiartc
Emerson, 41 L. J., Bank. 20; Ex parte Watkins, 8 Ch. 520) : such, for
instance, as letting furniture on hire to an hotel -keeper [Ex parte
Toivell, sujjra ; Craucoiir v. lialtcr, 18 Ch. D. 30). See further on this
524
BANKRUPTCY.
Protection of
certain trans-
actions with
bankrupt.
By reason of tlie relation back of the date . of bank-
ruptcy, as has been already explained on p. 519, the
trustee would, were it not for the following clauses, be
entitled to all the real and personal property in the pos-
session of the bankrupt at that period at which the bank-
ruptcy is legally held to have commenced (/). To prevent
the injustice that might in consequence be done to innocent
parties, it is, by section 94 of the Bankruptcy Act of 1869,
enacted that : —
" Nothing in this Act contained shall render in-
valid, —
" (1 .) Any payment made in good faith and for value
received to any bankrupt before the date of the
order of adjudication by a person not having at
the time of such payment notice {m) of any act
subject, Kc parte loveriiic/, L. R., 9 Ch. G21 ; Ex pnvfe Hattcrsley, 8
Ch. D. GOl ; Ex parte Wbigjield, 10 Ch. D. i591.
Consent of By the expression ' ' true owner, ' ' is meant that person who has either
owner. a legal or equitable right to put an end to the apparent possession of the
bankrupt {Ex parte Union Bank of Manchester, L. E., 12 Eq. 354 ; 40
Li. J., Bank. 57) ; and, as we have seen, includes an equitable mortgagee
(see ante, p. 161). The consent may be implied. See Eobson and Great
Eastern Ilailwaij v. Turner, L. R., 8 Ch. 149; Ex parte Ward, ib. 144; 42
L. J., Bank. 17; Ex parte Hay man, 8 Ch. D. 11 ; Ex parte Bright, 10
Ch. D. 5G6 ; 48 L. J., Bank. 81.
(0 ItoHch V. G. TF. Rail. Co., 1 Q. B. D. 51 ; Thomas v. Besanges, 2 B. &
Aid. 586.
{m) The notice may be express or inferred. The following rule is laid
down by Melli-sh, L. J., in Ex jmrte Snon-ball (L. R., 7 Ch. 549) : " It ap-
pears to us that if a person is proved to know facts which constitute an act
of bankruptcy, or is proved to know facts from which a Court or a jury,
or any impai'tial person, Avould naturally and proj^erly infer that an act
of banlcruiJtcy had been committed, ho ought to be held to have had
notice that an act of bankruptcy had been committed, and that the Court
ought not to enter upon the inquiry whether he did iu his own mind
believe that an act of bankruptcy had been committed, or whether he did
in his own luind di-aw the inference that the bankrupt intended to defeat
and delay his creditors. A person may have proved to have had notice
that an act of bankruptcy Iiad been connnittcd, eitlier by proof that he
had received formal notice that an act of bankruptcy had been committed,
or by proof that he knew facts which were sufficient to inform him that
an act of bankruptcy had been committed. If he is proved to have
received a formal notice he is not allowed to escape from the effect of
having had notice by saying he had not read it, when he ought to have
read it, or that he did not believe it when he had read it ; and we think
that if he is proved to have known facta which were sufficient to have
APPOINTMENT OF TRUSTEE. 525
of bankruptcy committed by the bankrupt, and
available against him for adjudication :
" (2.) Any payment or delivery of money or goods
belonging to a banki"upt, made to such bank-
rupt by a depositary of such money or goods
before the date of the order of adjudication,
who had not at the time of such payment or
delivery notice of any act of bankruptcy com-
mitted by the bankrupt, and available against
him for adjudication :
" (3.) Any contract or dealing (n) with any bankrupt,
made in good faith and for valuable considera-
tion, before the date of the order of adjudica-
inf ormed him that an act of bankruptcy had been committed, he cannot
be allowed to escape from the effect of having- had notice by saying he
did not draw the natural inference from the facts." A notice to an execu-
tion creditor which states that a petition in banki-uptcy against the exe-
cution debtor has been filed on a date, at a Court, and by a person named
in the notice, is a sufficient notice of an act of bankruptcy to prevent
the execution being a protected transaction (sect. 95, sub-sect. 3), since
such creditor ought to know that the petition would contain a statement
that the debtor had committed an act of bankruptcy. {Lucas v. Dicker,
6 Q. B. D. 84 ; 50 L. J., C. P. 190. See also, on the subject of notice,
Rv parte Sc/iultc, L. R., 9 Ch. 409; Somes v. Hallam, L. R., 6 Q. B.
713; 40 L. J., Q. B. 229; Ex parte Gilbey, 8 Ch. D. 248; 47 L. J.,
Bank. 49.) Notice of an intention to commit an act of bankruptcy will
not suffice. Ex parte Arnold, 3 Ch. D. 70 ; 45 L. J., Bank. 130.
(n) An attachment of a debt by a garnishee order is not " a dealing "
•within this clause. {Ex parte I'illars, re Curtoys, L. E,., 17 Ch. D. 653;
50 L. J., Ch. 691. See also as to what is "a dealing," Ex parte Arnold,
supra; Ex parte Borman, re Lake, L. E.., 8 Ch. 57 ; 42L. J., Bank. 20.) The
drawer of a post-dated cheque given for payment is under no obligation
to stop its payment before its date for the benefit of a third person. If,
for instance, before the date of payment the drawer receives notice of an
adjudication of bankruptcy, made against the payee since the delivery of
the cheque to him upon an act of bankruptcy committed by him before
the delivery, he is not bound, for the benefit of the bankrupt's creditors,
to give notice to his bankers not to pay the cheque and thus expose him-
self to the risk of an action by a bona fide holder of the cheque for value.
If the cheque was originally delivered by the drawer to the payee in
good faith and for value, and without notice of an act of bankruptcy
previously conunitted by the payee, on which an adjudication is subse-
quently made, the transaction is protected by sect. 94 (sub-sect. 3) of the
BanJiruptcy Act, 1869, and the trustee in the bankruptcy cannot recover
the amount of the cheque from the drawer. When a customer pays a
cheque to his bankers with the intention that the amount of it shall be at
once placed to his credit, and the bankers carry the amount to his
credit accordingly, they become immediately holders of the chc que for
value, even though the customer's account is not overdrawn. Ex parte
Eichdule, Ln re I'almer, 19 Ch. D. 409.
526
BANKRUPTCY.
Protection of
certain trans-
actions en-
tered into by
or in relation
to the pro-
perty of the
bankrupt.
tion, by a person not having, at the time of
making such contract or dealing, notice of any
act of bankruptcy committed by the bankrupt,
and available against him for adjudication.
" 95. Subject and without prejudice to the provisions of
this Act relating to the proceeds of the sale and seizure of
goods of a trader (o) and to the provisions of this Act
avoiding certain settlements (p), and avoiding, on the
ground of their constituting fraudulent preferences certain
Proceeds of (o) By sect. 87, "Where the g-oods of any trader have been taken in
sale and execution in respect of a judgment for a sum exceeding fifty pounds and
seizure of sold, the sheriff, or in tlie case of a sale under the direction of the county
goods. court, the high bailiff or other officer of the county court, shall x'etain the
proceeds of such sale in his hands for a period of fourteen days, and upon
notice being served on him within that period of a bankruptcy petition
having been presented against such trader, shall hold the proceeds of such
sale, after deducting expenses, on trus-t to pay the same to the trustee ;
but if no notice of such petition having been i^resented be sewed on him
■within such period of fourteen days, or if, such notice having been served,
the trader against ■whom the petition has been presented is not adjudged
a bankrupt on such petition, or on any other petition of ■which the sheriff,
high bailiff, or other officer has notice, he may deal ■with the proceeds of
such sale in the same manner as he -would have done had no notice of the
presentation of a bankruptcy petition been served on him."
Avoidance of (^) By sect. 01, "Any settlement of property made by a trader not
voluntary being a settlement made before and in consideration of marriage, or made
settlements. in favour of a purchaser or incumbrancer in good faith and for valuable
consideration, or a settlement made on or for the wife or children of the
settlor of property ■which has acci-ued to the settlor after marriage in right
of his wife, shall, if the settlor becomes bankrupt within two years after
the date of such settlement, be void as against the trustee of the bankrupt
appointed under this act, and shall, if the settlor becomes bankrupt at
any subsequent time within ten years after the date of such settlement,
unless the parties claiming under such settlement can prove that the
Bettlor was at the time of making the settlement able to pay all his debts
•without the aid of the property comprised in such settlement, be void
against such trustee." {^ce Ex 'parte Uuxtable, L.E,., 2 Cli. 54 ; 45 L. J.,
Bank. 59.) "Any covenant or contract made by a trader, in consideration
of mari-iage, for the future settlement upon or for his wife or children of
any money or property wherein he had not at the date of his marriage any
estate or interest, whether vested or contingent, in possession or remainder,
and not being money or property of or in right of his wife, shall, upon
his becoming bankrupt before such property or money has been actually
transferred or paid pursuant to such contract or covenant, be void against
his trustee appointed under this act."
" 'Settlement' shall for the purj)oses of this section include any con-
veyance or transfer of property." See, on this section, Ex parte JioUand,
ri'ciuit, L. R., 17 Eq. 115; Ex parte Cox, re Read, 1 Ch. D. 302. Volun-
tary settlements can also be set aside under 13 Eliz. c. 5, where their effect
is to hinder or delay creditors. See Twi/ne\'> case, and notes thereto in
Sm. L. Ca. 7th ed. vol. 1, p. 12, and the recent case of Ex jjarte Jiassett,
Li re Bntterworth, 10 Cli. D. 588.
APPOINTMENT OF TRUSTEE. 527
conveyances, charges, payments, and judicial proceed-
ings (q), the following transactions by and in relation to
(rj) By sect. 92, " Every conveyance or transfer of property, or charge Avoidance of
thereon made, every payment made, every obligation incun-ed, and every fraudulent
judicial proceeding taken or suffered by any person unable to pay his preferences,
debts as they become due from his own monies in favour of any creditor,
or any person in trust for any creditor, with a ■view of giving such cre-
ditor a preference over the other creditors, shall, if the person making,
taking, paying, or suffering the same become bankrupt within three
months after the date of making, taking, paying, or suffering the same,
be deemed fraudulent and void as against the trustee of the bankrupt ap-
pointed under this act ; but this section shall not affect the rights of a
purchaser, payee, or incumbrancer in good faith and for valuable consi-
deration."
The following would seem to be a general summarj- of the law relating
to fraudulent preference : —
In order to bring a case under this section it must in the first place
appear that the transaction, &c. rehed upon as being a fraudulent pre-
ference was made ' ' with a view of giving the creditor a preference over
the other creditors." These words may be taken as being equivalent in
their effect and to bear the same construction as the word " volimtarily"
{Ex parte Bolland, 7 Ch. App. 24 ; 20 W. R. 136) under the law prior to
1869. In consideiing, therefore, what is or is not a roluntanj act under
this section, the cases decided previous to the act will still be applicable.
Very slight evidence of pressure on the part of the creditor will prevent
the transaction from being voluntaiy. (Sec Ex parte Tempest, L. E,., 6
Ch. 70; Ex parte Craven, L. E., 10 Eq. 648; Smith v. Pilgrim, L. R., 2
Ch. D. 127 ; Ex parte Winter, 44 L. J., Bank. 107 ; Ex parte Si/monds, 14
Ch. D. 693 ; 28 AY. E. 803.) Any act, on his part, in short, that can be
considered as interfering with the debtor's free volition will suffice.
Thus, an earnest request by a creditor, although not accompanied by a
threat or remonstrance, or very positive demand, would be enough to
deprive the payment of that voluntary character which would tend to
make it impeachable. (Bacon, V. -C, in Ex parte Blacl-burn, re Cheese-
borough, L. E., 12 Eq. 358 ; 40 L. J., Bank. 79.) A threat to bring an
action, when the debtor is on the verge of bankruptcy, will not amount to
pressiu'e. {Ex parte Hall, In re Cooper, 19 Ch. D. 580.) Payments in the
ordinaiy course of trade, the honoring bills of exchange presented at
their maturity, the payments of debts which have become due in the
usual and customary manner, or payments made in fulfilment of a con-
tract, or engagement to pay in a particular manner, or at a particular
time, are not open to any objection on the ground of their being
voluntary, even althoixgh they were made without anj- express demand
by the creditor, unless at the time he had notice of an act of bankruptcy
committed by the creditor. {Ibid.) So, also, a jjayment made to avoid
a distress being levied, is not a voluntary preference. {Stevenson v. Wood,
5 Esp. 200.) Kor is a payment made in consequence, and under fear of
civil or criminal proceedings, though such fear was in point of fact
Avithout foundation {Thomson v. Freeman, 1 T. R. 155), a voluntary
prefei'ence of a creditor, though it can be set aside as a fraud on the
bankrupt law, is not an act of bankruptcy. {Ex 2^(irte Stiibbins, 17 Ch. D.
58.)
Not merely must the payment be voluntary, but there must have
existed also an intention on the part of the debtor to prefer the creditor
{Ex parte Topham, L. E., 8 Ch. 014; 42 L. J., Bank. 57; Ex parte
Bolland, L. E., 7 Ch. 24 ; 25 L. T. 648 ; 20 W. E. 136 ; Ex parte London
528 BANKRUPTCY.
the property of a bankrupt shall be valid, notwithstanding
any prior act of bankruptcy :
" (1.) Any disposition or contract with respect to the
disposition of property by conveyance, transfer,
charge, delivery of goods, payment of money,
or otherwise howsoever made by any bankrupt
in good faith and for valuable consideration,
before the date of the order of adjudication,
with any person not having at the time of the
making of such disposition of property notice of
any act of bankruptcy committed by the bank-
rupt, and available against him for adjudica-
tion :
" (2.) Any execution or attachment against the land of
the bankrupt, executed in good faith by seizure
before the date of the order of adjudication, if
the person on whose account such execution or
attachment was issued had not at the time of
the same being so executed by seizure notice of
any act of bankruptcy committed by the bank-
rupt, and available against him for adjudica-
tion :
" (3.) Any execution or attachment against the goods
and County Bank, L. R., IG Eq. 391), and a knoichdge on the part of the
creditor that he was being-, in fact, preferred. {Ex parte Keraii, L. R.,
9Ch. 752 ; Butcher v. Stead, L. R., 7 H. L. 839 ; 44 L. J., Bank. 120 ;
24 W. R. 4G2 ; 33 L. T. 541.) Under the old law this was not necessary.
[Davidson v. Robiuso)i, 3 Jur., N. S. 791.)
Under tlie old law it was necessary, in order to impeach the transaction
on the ground of it being a fraudulent preference, to show that at the
time of making it the debtor contemplated bankruptcy ; and great diffi-
culty arose in deciding what was or was not a contemplation of bank-
ruptcy. The present section, however, docs away with this ; and in its
place requires it to be shown merely that the debtor vas unable to pay
his debts, as they became due, from his oicn moyilcs : and that he has become
bankrupt icithln three months from the date of the transaction. {Ex parte
Bolland, supra; Ex parte Jfathcu's, 25 L. T., N. S. 27G.)
This section, as to fraiidulcnt preference, must be clearly understood as
applying only where the X)arties stand in the position of debtor and
creditor. As regards trust property, or property held for a sj>ecific
purpose, or improperly detained from the possession of a third party to
whom it has been given up, it has no ap])lication. {Sinclair v. Wilson, 20
Beav. 324 : Ex parte Kelh/, L. R., 11 Ch. J). 30G ; 4S I.. J., Bank. 65 ;
40 L. T. 404 ; Ex parte Stiibbins, 17 Ch. 1). 38 )
PROVISIONS AFFECTING ADMINISTRATION OF PROPERTY. 529
of any bankrupt, executed in good faith by
seizure and sale before the date of the order of
adjudication, if the person on whose account
such execution or attachment was issued had
not at the time of the same being executed by
seizure and sale notice of any act of bankruptcy
committed by the bankrupt, and available
against him for adjudication."
General Provisions affceting Administration of Property. — Conduct of
•' The bankrupt shall, to the utmost of his power, aid in
the realization of his property, and the distribution of the
proceeds amongst his creditors. He shall produce a state-
ment of his affairs (r) to the first meeting of creditors, and
shall be publicly examined thereon on a day to be named
by the Court, and subject to such adjourned public exami-
nation as the Court may direct (s). He shall give such
inventory of his property, such list of his creditors and
debtors, and of the debts due to and from them respec-
tively, submit to such examination in respect of his pro-
perty or his creditors, attend such meetings of his creditors,
wait at such times on the trustee, execute such powers of
attorney, conveyances, deeds, and instruments, and gene-
rally do all such acts and things in relation to his property
and the distribution of the proceeds amongst his creditors,
as may be reasonably required by the trustee, or may be
prescribed by rules of Court, or be directed by the Coui-t
by any special order or orders made in reference to any
particular bankruptcy, or made on the occasion of any
special application by the trustee or any creditor."
" If the bankrupt wilfully fail to perform the duties im-
posed on him by this section, or if he fail to deliver up
possession to the trustee of any part of his property, which
is divisible amongst his creditors imder this act, and which
may for the time being be in the possession or under the
control of such bankrupt, he shall in addition to any other
()•) Rules 90—92.
(s) Rules 5, 96, 111.
rj MM
530 BANKRUPTCY.
punisliment to which he may be subject be guilty of a
contempt of Coui't, and may be punished accordingly."
(Sect. 19) (0-
Powerof tnis- By sect. 25, it is enacted that, " Subject to the provisions
tee to deal £ ^j^- ^^^ ^^^ trustee shall have power to do the following
■with property. ^ ' ^
things :
" (1.) To receive and decide upon proof of debts in the
prescribed manner, and for such pm-pose to ad-
minister oaths :
" (2.) To carry on the business of the bankrupt, so far
as may be necessary for the beneficial winding-
up of the same :
" (3.) To bring or defend any action, suit, or other legal
proceeding relating to the property of the bank-
rupt :
" (4.) To deal with any property to which the banki'upt
is beneficially entitled as tenant in tail in the
same manner as the bankrupt might have dealt
with the same; and the sections fifty-six to
seventy-three (both inclusive) of the act of the
session of the third and fourth years of the
reign of King William the Fourth (chapter
seventy-four), ' for the abolition of fines and re-
coveries, and for the substitution of more simple
modes of assurance,' shall extend and apply to
proceedings in bankruptcy under this act, as if
those sections were here re-enacted and made
applicable in terms to such proceedings :
" (5.) To exercise any powers the capacity to exercise
which is vested in him under this act, and to
execute all powers of attorney, deeds, and other
instruments expedient or necessary for the piu'-
pose of canying into effect the provisions of
this act :
{() As to discovery of bankrupt's property see sect. 9G, and Hx parte
Tatton, 17 Ch. D. 572; Ex parte Bramble, re Tokman, 13 Ch. D. 885.
As to examination of -witnesses, sect. 97, Rule 40, sects. 75, 98. By
sect. 93, monies in the hands of bankrupt's banker must be delivered up
to trustee.
PROVISIONS AFFECTING ADMINISTRATION OF PROPERTY. 531
" (6.) To sell all the property of the bankrupt (in-
cluding the goodwill of the business, if any,
and the book debts due on growing due to the
bankrupt) by public auction or private contract,
with power, if he thinks fit, to transfer the
whole thereof to any person or company, or to
sell the same in parcels :
" (7.) To give receipts for any money received by him,
which receipt shall effectually discharge the
person paying such monies from all responsi-
bility in respect of the application thereof :
" (8.) To prove, rank, claim, and draw a dividend in
the matter of the bankruptcy or sequestration
of any debtor of the bankrupt."
By sect. 26, " The trustee may appoint the bankrupt him- Power to
self to superintend the management of the property or of ^pt\o^
any part thereof, or to carry on the trade of the bankrupt manage pro-
(if any) for the benefit of the creditors, and in any other
respect to aid in administering the property in such
manner and on such terms as the creditors direct,"
By sect. 27, " The trustee may, with the sanction of the Power of
committee of inspection, do all or any of the following
things :
" (1.) Mortgage or pledge any part of the property of
the bankrupt for the purpose of raising money
for the payment of his debts :
" (2.) Eefer any dispute to arbitration, compromise all
debts, claims, and liabilities, whether present or
future, certain or contingent, liquidated or un-
liquidated, subsisting or supposed to subsist be-
tween the bankrupt and any debtor or person
who may have incurred any liability to the
bankrupt, upon the receipt of such sums, pay-
able at such times, and generally upon such
terms as may be agreed upon :
" (3.) Make such compromise or other arrangement as
may be thought expedient ^nth creditors, or
M M 2
trustee to
compromise,
&c.
532
ba:nkruptcy.
Power of trus-
tee to accept
composition
or general
scheme of ar-
ranorement.
Trustee, if a
solicitor, may
be paid for
services.
persons claiming to be creditors in respect of
any debts provable under the bankruptcy :
" (4.) Make such compromise or other arrangement as
may be thought expedient with respect to any
claim arising out of or incidental to the property
of the bankrupt, made or capable of being made
on the trustee by any person or by the trustee
on any person :
" (5.) To divide in its existing form amongst the credi-
tors, according to its estimated value, any pro-
perty which from its peculiar nature or other
special circumstances cannot advantageously be
realized by sale.
" The sanction given for the purposes of this section may
be a general permission to do all or any of the above-
mentioned things, or a permission to do all or any of them
in any specified case or cases."
And by sect. 28, " The trustee may, with the sanction of
a special resolution of the creditors assembled at any meet-
ing of which notice has been given specifying the object of
such meeting, accept any composition offered by the bank-
rupt, or assent to any general scheme of settlement of the
affairs of the bankrupt, upon such terms as may be thought
expedient, and with or without a condition that the order
of adjudication is to be annulled, subject nevertheless to
the approval of the Court, to be testified by the judge of
the Court signing the instrument containing the terms of
such composition or scheme, or embodying such terms in
an order of the Court."
" A trustee shall not, without the consent of the com-
mittee of inspection, employ a solicitor or other agent, but
where the trustee is himself a solicitor he may contract to
be paid a certain sum by way of per-centage or otherwise
as a remuneration for his services as trustee, including
all professional services, and any such contract shall,
notwithstanding any law to the contrary, be lawful."
(Sect. 29.)
PAYMENT OF DEBTS AND DISTRIBUTION OF ASSETS. 533
Payment of J)ehU and Distribution of Assets. — "Demands Description of
in the nature of unliquidated damages arising otherwise intank^^^ ^
than by reason of a contract or promise shall not be provable ruptcy.
in bankruptcy, and no person having notice of any act of
bankruptcy, available for adjudication against the bankrupt,
shall prove for any debt or liability contracted by the
bankrupt subsequently to the date of his so having notice.
" Save as aforesaid, all debts and liabilities, present or
future, certain or contingent, to which the bankrupt is
subject at the date of the order of adjudication, or to which
he may become subject during the continuance of the
bankruptcy by reason of any obligation incun^ed previously
to the date of the order of adjudication, shall be deemed
to be debts provable in bankruptcy, and may be proved in
the prescribed manner before the trustee in the bankruptcy.
" An estimate shall be made according to the rules of the
Court for the time being in force, so far as the same may
be applicable, and where they are not applicable at the
discretion of the trustee, of the value of any debt or li-
ability provable as aforesaid, which by reason of its being
subject to any contingency or contingencies, or for any
other reason, does not bear a certain value.
" Any person aggrieved by any estimate made by the
trustee as aforesaid may appeal to the Coui't, and the
Court may, if it think the value of the debt or liability
incapable of being fairly estimated, make an order to that
effect, and upon such order being made such debt or
liability shall, for the purposes of this act, be deemed to
be a debt not provable in bankruptcy, but if the Court
think that the value of the debt or liability is capable of
being fairly estimated it may dii-ect such value to be
assessed with the consent of all the parties interested before
the Court itself without the intervention of a jury, or if
such parties do not consent by a jury, either before the
Court itself or some other competent Court, and may give
all necessary directions for such purpose, and the amount
of such value when assessed shall be provable as a debt
under the bankruptcy.
534
BANKRUPTCY.
" 'Liability' sliall for the purposes of this act include
any compensation for work or labour done, any obligation
or possibility of an obligation to pay money or money's
worth on the breach of any express or implied covenant,
contract, agreement or undertaking, whether such breach
does or does not occur, or is or is not likely to occur or
capable of occurring before the close of the bankruptcy,
and generally it shall include any express or impHed en-
gagement, agreement or undertaking, to pay, or capable
of resulting in the payment of money or money's worth,
whether such payment be as respects amount fixed or un-
liquidated ; as respects time present or future, certain or
dependent on any one contingency or on two or more con-
tingencies ; as to mode of valuation capable of being ascer-
tained by fixed rules, or assessable only by a jury, or as
matter of opinion." (Sect. 31.)
With certain exceptions made in favour of parochial and
local rates and assessed taxes, and in favour of the wages
or salaries of clerks or servants, all debts provable under
the bankruptcy shall be -paid pari passu. (See sect. 32.)
By sect. 34, power is reserved for a landlord to distrain
for one year's rent {n).
Proof in case
of felony.
Proof in case of Felony. — It would seem that proof
cannot be made by a creditor in respect of a claim arising
directly out of a felony until the bankrupt has been
prosecuted or a prosecution has become impossible. But
it would appear that proof may be made for a claim oidy
indirectly connected with a felony, as where bankers al-
lowed a customer to overdraw his account, one of the
inducements for their doing so being the deposit of cer-
tain bills which subsequently turned out to be forged by
the bankrupt (r).
Distribution
of dividends.
Dicidcnds. — " Tlie trustee shall from time to time, when
(w) Sec In re Thnlfall, IG Ch. D. 271 ; Ex pftrtc rtouict, ib. 22G.
((•) Ex parte Leslie, 20 Ch. D. 131 ; Ex parte Elliot, 3 Mont. & A. 110 ;
He Jfaple'.w/:, 4 Ch. D. 150 ; Ex imric Bull, 10 Ch. D. GG7.
PROOF liY AND AGAINST SURETY. 53o
the committee of inspection determines, declare a dividend
amongst the creditors who have proved to his satisfaction
debts provable in banki'uptcy, and shall distribute the
same accordingly ; and in the event of his not declaring a
dividend for the space of six months, he shall summon a
meeting of the creditors, and explain to them his reasons
for not declaring the same." (Sect. 41.)
" In the calculation and distribution of a dividend it shall Provision for
be obligatory on the trustee to make provision for debts siding at a
provable in bankruptcy appearing from the bankrupt's /, L. E,., 6 Eq. 344 ; In
re European Bank, L. R., 5 Ch. App. 358 ; 39 L. J., Ch. 588.
iff) Ex parte Todd, 2 Rose, 232 ; Ex parte WUdman, 1 Atk. 109 ; Ex
parte Adam, 2 Rose, 36.
(A) Id.
\l) Ex parte Newton, 16 Ch. D. 330.
538 BANKRUPTCY.
Power to pre- Bt/ and against Partner. — " Any creditor whose debt is
ro?iS;*one^ sufiicient to entitle him to present a bauki-uptcy petition
partner. against all the partners of a firm may present such peti-
tion against any one or more partners of such firm without
including the others." (Sect. 100.)
Power to dis- 101. " Where there are more respondents than one to a
a^ain^t som^ petition the Court may dismiss the petition as to one or
respondents more of them, without prejudice to the effect of the petition
as against the other or others of them."
Joint creditor 103. "If one partner of a firm is adjudged bankrupt,
pmws^^of ' ^^y creditor to whom the bankrupt is indebted jointly with
voting. the other partners of the firm, or any of them, may prove
his debt for the purpose of voting at any meeting of
creditors, and shall be entitled to vote thereat, but shall
not receive any dividend out of the separate property of
the bankrupt until all the separate creditors have received
the full amount of their respective debts" (/). And by
rule 76, any separate creditor of any bankrupt shall be at
liberty to prove his debt under any adjudication of bank-
ruptcy made against such bankrupt, jointly and with any
other person. Distinct accounts are to be kept of the joint
estate, and of the separate estate, and the separate estate is
to be applied in the first place in satisfaction of the debts
of the separate creditors : and the joint estate of the joint
Joint and creditors: and by sect. 104, "Where joint and separate
dcndT '^ ^"" properties are being administered, dividends of the joint
and separate properties shall, subject to any order to the
contrary that may be made by the Com-t on the applica-
tion of any person interested, be declared together ; and the
(t) See Ex parle Cooke, 2 P. "Wms. 500. As to what is "joint" and
"separate" estate, see Ex parte Bear, 1 Ch. D. ol-l ; 4o L. J., Bank. 221 ;
Ex parte Manchcbter Bank, 12 Ch. D. 917 ; 48 L. J., Bank. 94 ; Ex parte
Hatcher, 13 Ch. D. 466 ; I)t re Collie, Ex parte Manchenter and County
Hank, 3 Ch. D. 481 ; 45 L. J., Bank. 149; Ex parte Buckley, 16 Ch. D.
513. As to proof by firm ag-ainst separate estate of one partner, see Ex
parte Sillltoe, 1 Gl. & J. 374 ; Ex parte Harris, 1 Rose, 437 ; and as to
proof Ly pai-tner against firm, Ex parte Maude, L. E.., 2 Ch. 550 ; Ex
parte SiUitoe, supra ; and as to proof by partner against separate estate
of co-partner, Ex parte Maude, .supra ; Ex parte Hhvcn, 6 Ch. D. 235 ;
Lacey\. Hill, 8 Ch. D. 441. For full information on this subject, see
Ilobson, 717.
SET-OFF. 539
expenses of and incident to such dividends shall be fairly
apportioned hy the trustee between the joint and separate
properties, regard being had to the work done for and
the benefit received by each property."
Double. Proof. — By sect. 37, " If any bankrupt is at the Proof in
date of the order of adjudication liable in respect of dis- distinct *con-
tinet (/i) contracts as member of two or more distinct firms, tracts.
or as a sole contractor, and also as member of a firm, the
circmnstance that such firms are in whole or in part
composed of the same individuals, or that the sole con-
tractor is also one of the joint contractors, shall not prevent
proof in respect of such contracts, against the properties
respectively liable upon such contracts " (/).
Set-off'. — 39. " Where there have been mutual credits, Set-off.
mutual debts, or other mutual dealings between the
bankrupt and any other person proving or claiming to
prove a debt under his banki'uptcy, an account shall be
taken of what is due from the one party to the other in
respect of such mutual dealings, and the sum due from
the one party shall be set off against any smn due from
the other party, and the balance of such account, and no
more, shall be claimed or paid on either side respectively ;
but a person shall not be entitled under this section to
claim the benefit of any set-off against the property of a
bankrupt in any case where he had at the time of giving
credit to the bankrupt notice of an act of bankruptcy
committed by such bankrupt and available against him for
adjudication" {m).
[k) The contracts, though they must be distinct, may be contained
in the same instrument. Hx parte Honey, L. E., 7 Ch. 178 ; 41 L. J.,
Bank. 9.
(/) On this section, see In re Oriental Commercial Bank, L. R., 7 Ch.
99 ; Ex 2}artc Banco di Tortvgal, L. E., 11 Ch. 717 ; 5 App. Ca. 161 ;
49 L. J., Bank. 33 ; Ex parte Foiilson, De Gex, 79 ; Ex parte Adamson,
8 Ch. D. 807 ; Ex parte Fiudlay, 17 Ch. D. 334 ; oO L. J., Ch. 696.
(hj) The transactions must have been mutual ; in other words, it must
have been between the same parties and in the same right — thus a debt
540 BANKRUPTCY.
Order of dis- Discharge of Bankrupt. — " "Wlien a bankruptcy is
arge. closed {n), or at any time during its continuance, Avith
the assent of the creditors, testified by a special resolution,
the bankrupt may apply to the Court for an order of
discharge ; but such discharge shall not be granted unless
it is proved to the Court that one of the following con-
ditions has been fulfilled, that is to say, either that a
dividend of not less than ten shillings in the pound has
been paid out of his property, or might have been paid
due to a baukrupt from an executor personally cannot be set off against
a debt due from the bankrupt to the executor in his representative
capacity, and I'ice versa. (See !Stammcrs v. Elliot, L. R., 3 Ch. App. 195 ;
Hallett V. Hnlictt, 13 Ch. D. 332 ; Bishop v. Church, 3 Atk. 691 ; Ex parte
Morier, 12 Ch. D. 491 ; 49 L. J., Bank. 9.) In the same way a debt due
from a partnership cannot be set off against the separate debt of an in-
dividual partner. [Ex parte Ticngood, 11 Ves. 517 ; Lanesboroi;s.
547
at liberty to re-enter and expel the bviilder and take pos-
session of all building materials then left on the land " as
and for liquidated damages," T^'as not a bill of sale within
the act, such licence not being " as security for any
debt"(.r). Nor is a licence to a vendor to seize furniture
or pianos, in default of payment of instalments under an
agreement to purchase them on the hire system, imder a
bill of sale, for the property in the goods does not pass
from the vendor until the completion of the paj^ments {y) .
A deed in which, after reciting that Y. was indebted The excej)-
to several creditors therein mentioned, that Y., unable to As^fgnments
r)ay his debts in full, had offered a composition of 7s. Qd. for the benefit
^ " 01 creditors.
in the £ payable by instalments guaranteed by D. B., and
which the creditors accepted, it was then stated that
D. B. guaranteed the payment of two instalments of ?)S.
and 3.S. in the £, and that Y. in consideration thereof
granted and assigned all his stock in trade " for the pay-
ments of the said sums hereinbefore mentioned in trust for
the said creditors," was held to be an assignment for the
benefit of creditors, and within the meaning of the excep-
tion (s).
A nost-nuptial settlement to trustees for the benefit of Marriage
JL i- scttlcniGiits,
wife and children not made in pm-suance of ante-nuptial '
articles is not within the exception, but operates as a bill
of sale and must be registered {a) .
A bill of sale of a ship is within the exception, and none Transfers of
the less because it has not been registered under the shares
Merchant Shipping Act of 1854 (h) . thereof.
{x) Ex parte Xewitt, In re Garrard, 16 Ch. D. 522 ; 4-1 L. T. 5 ; and for
other instances of licences to take possession not within the act, see Broun
V. Batenum, L. R., 2 C. P. 272 ; Blake v. Izard, 16 W. R. 108 ; 2Iorton
V. Woods, L. E., 4 Q. B. 293 ; Hale v. Saloon Omnibus Companij, 4 Bvexw
498.
{y) Ex parte C'raivcour, 9 Ch. D. 419 ; Crawcoiir v. Salter, 18 Ch. D. £0.
{z) General Furnishing and Upholstering Comjjanyy. Venn, 32 L. J., Ex.
220 ; 2 H. & C. 153.
(«) Fou-ler v. Foster, 28 L. J., Q. B. 210 ; Ashton v. Blachshaw, L. K.,
9 Eq. 510.
{h) Union Bank of London v. Lenanton, 3 C. P. B. 243.
N N 2
548
BILLS OF SALE.
Warrants or
orders for
delivery of
goods or
other docii-
meuts used
in the ordi-
nary course
of business,
&c.
Grantor must
he in posses-
sion.
After -ac-
quired or
substituted
property.
Personal
chattels de-
fined, s. 4.
include fix-
tures and
growing-
crops sepa-
rately
assigned ;
This provision appears to be evidence of an intention of
the legislature that while the interests of the persons re-
garded by the statute shall be fairly secured, the ordinary
mode of business and commercial transactions shall not be
unduly interfered with, and the governing words for the
latter members of the clause of exceptions are " in the
ordinary course of business." Thus, within the exception
comes a letter of hypothecation given in the ordinary course
of business by a factor and warehouse-keeper pledging cer-
tain goods to secm-e a sum of money, no delivery of the
goods being made, but a promise to deliver them on the
following morning being added at the foot of the letter ((/) ;
and also, it is presumed, an agreement by a purchaser to give
to the vendor a lien or right connected with the vendor's
lien, and analogous to it, if made so as to be a transfer of
goods within the ordinary course of business (c).
A bill of sale, to be good within the act, must be a
document executed by a person in possession of the goods
at the time (/).
The property in stock in trade afterwards {g) brought
into the premises in substitution for, or addition to, that
which is there at the time of making the bill of sale, may
be passed by the same bill of sale {//), and so in the case of
fixtures (/).
Personal chattels are defined in sect. 4 (/.) ; and fixtures
(other than trade machinery as defined in sect. 5), and
growing crops are made personal chattels within the act
on/// ulten separatdij asniyncd {k).
[d) Ex parte North TFestcrn Bank, L. R., 15 Eq. G9.
(c) Ex parte Watson, In re Love, 5 Ch. D. 35.
(/) Chapman v. Knight, 5 C. P. D. 314.
{g) See note at end of chapter, sects. 4, 5, G, for the proposed alteration
in the law as to after- acquired property, p. 566.
(/<) Lazarus v. Amlrade, 5 C. P. U. 318 ; 43 L. T. 30 ; CuUi/er v. Isaacs,
W. N. 1881, 140.
(/) Meax V. Jacobs, L. R., 7 H. L. 481, at p. 491 ; JiaghuU v. Xorman,
41 L. T. 787.
(A-) See post. Appendix.
FIXTURES AND GROWING CROPS. o4'J
Trade macliinerj, as defined in sect. 5 (/), is made per- Sect. 5.
sonal chattels within the act, as from the 1st January, ^^^^^[Qg^
1879, whether separately assigned or not.
Separate assignment is defined hy sect. 7 (/) to he where Sect. 7.
no interest in the land passes by the same instrument by ag^^nfgnt
which the fixtures or growing crops pass (/). what?
This definition of separate assignment is made retro- Defmition of
... , . T T , separate as-
spective m its application (/), and m such general terms as, signment
it is submitted, to apply to all deeds comprising fixtures, [^^gp^^^^^ion!
whether trade or other, executed before the commencement
of the act (;;?). Although growing crops are mentioned in
this provision for the retrospective operation of the rule of
construction as to separate assignment, it has no applica-
tion in respect of them, for they were not personal chattels
under the old act {n), and the inclusion of them in the
definition of personal chattels in the present act is not
retrospective. No question, therefore, can arise as to
growing crops comprised in deeds executed before the
commencement of the present act.
Registration, therefore, appears to be now necessary to Pro^•isioIls
the validity of bills of sale comprising fixtures : — apply .'
(a) If executed before the commencement of the present (a) as to
act, only where the fixtures (including trade fix- ^\^^^^5 JJ^ J^.^
tures, but excluding growing crops ) (o) comprised Jan. 1879.
in them are separately assigned or charged
within the meaning of sect. 7 of the Act of
1878(i;).
(b) If executed since the commencement of the act, (b) a-^ to
(i) as regards trade fixtures (see sect. 6), in all cuted since
Jan. 1879.
(/) See post, Appendix.
(w) See In re Arnujtagc (14 Ch. D. 379) for observations upon the
meaning of sect. 7, but there has been no decision exactly in point.
(«) Brcodom v. Griffits, 2 C. P. D. 212; Ex parte Faync, 11 Ch. D. 539.
(o) Brantom v. Griffits, 1 C. P. D. 349; 2 C. P. D. 212; Ex parte
Fayne, In re Cross, 11 Ch. D. .539.
{p) In re Armytage, 14 Ch. D. 379 ; 42 L. T. 443. The test, under the
Act of 1854, as to whether an assignment of trade fixtures required
registration was, ' ' had the mortgagee power to deal separately vnXh. or
disannex the fixtures?" Ex parte Daylish, L. R., 8 Ch. 1072 ; Ex parte
Barclay, L. R., 9 Ch. 576 ; Ex parte Tweedy, In re Trcthoican, 5 Ch. D.
559.
550
BILLS OF SALE.
What are
fixtiu'es ?
Growiug
crops after-
wards
severed.
cases (t), wliether tliey are assigned separately or
not ; (ii) as regards other fixtures and growing
crops only where they are separately assigned as
above.
It is often a difficult question of fact to decide what are
fixtures, and what are moveables. The question will still
arise, although it has been much reduced by the new legis-
lation as to trade machinery in sect. 5.
In a recent case, it has been held that a tramway and
steam crane placed upon a quarry and bolted to large
stones were fixtures {ii), and by previous decisions it has
been held that articles standing merely by their own
weight are not fixtures (,r), but where part of a machine is
a fixture, and another and essential part moveable, the
latter is also a fixture (//) . The fact that the things have
been affixed merely for the more convenient user of them,
and are removable without injury to the freehold, does not
make them the less fixtures (z).
Grrowing crops, if assigned together with an interest in
the land on which they grow, pass to the grantee without
registration of such assignment as a bill of sale («) ; but if
afterwards severed by the mortgagor while in his posses-
sion are no longer secured to the grantee by the deed, but
become personal chattels under it and subject to the act,
even thougli the assignment provides that the mortgagor
shall not remove them (/>).
(t) This appears to be the meaning of the section, though there has
been no decision upon it as yet. See the section, Appendix.
(u) In re Annijtagc, L. R., 11 Ch. D. 379 ; 42 L. T. 443.
(.«•) Mather v. Frascr, 2 K. & J. 536.
(//) Ibid. And for otlicr decisions as to what are fixtures, see Fisher
on Mortgages, 3rd edit. p. 30 ; and MclropolUan Cuioities Society v. Broun,
26 Beav. 454 ; E.v parte Astbunj, L. E.., 4 Ch. G30 ; Longbottom v. Bern/,
L. K., 5 Q. B. 123; Turner v. Cameron, id. 30G ; llnlland v. Hodgson,
L. R., 7 C. r. 348 ; Haley v. I[an>merslcy, 3 Dc Q., F. & J. 5S7 ; Beg. v.
Inhabitants of the J'uri.sh of Lee, L. R., 1 Q. B. 241.
(r) C'/imie v. Jf'ood, L. R., 3 Ex. 257, following Cullwick v. Swindell,
L. R., 3 Eq. 249 ; and see Holland v. Hodgson, supra, and cases there
cited.
{a) Brantom v. Grifits and Ex parte Taync, supra; In re I'hiUips, 16
Ch. D. 104.
{!>) Ex parte National Mercantile Bank, IG Ch. D. 104; SOL. J., Ch. 231.
IXSTRUMEKTS GIVIXG VOWEIIS OF DISTRESS. 551
Of those things which the act excepts from tlie definition Exceptions ;
of i")ersonal chattels a mortgage of a share and interest in
a partnership has been held a charge on a "chose in chosesin
action," and so not affected by the Bills of Sale Act, or bj ^''*''''''
the Bankruptcy Act, 1869, sect, 15(c); and "stock or stock or pro-
produce" has been suggested to mean produce already "^^'
severed from tlie land and which might be delivered,
although by the covenant or custom it ought not to be
removed from the farm (d).
Before the commencement of the present act the fol- Sect. g.
lowing transaction, by which a power of distress was given 1^^*^^^™*^^*"^
to the mortgagee, was held to be a fraud upon the bank- of distress.
rupt law as being a secret bill of sale. A mortgage of
smelting works to secure the repayment of an advance of
55,000/. contained, in addition to the ordinary clauses,
a covenant by the mortgagee that if the interest was
punctually paid as it became due, and all the covenants
contained in the deed (other than the covenant for pay-
ment of the principal) were performed, and the mortgagor
should not have become bankrupt or have taken proceed-
ings for liquidation by arrangement or composition wdth
his creditors, and should not have parted with the pos- *
session of the mortgaged property, and should not have
ceased to carry on his business thereon, then the mortgagee
would not for a period of five years require payment of
the principal. And the mortgagor attorned tenant from
year to year to the mortgagee, in respect of the mortgaged
property, at the yearly rent of 20,000/. to be paid half-
yearly on the days on which the mortgage debt was
payable. The deed was not registered under the Bills of
Sale Act. It was admitted that the letting value of the
property was not more than 8,000/. per annum. Four
months after the execution of the mortgage the mortgagor
filed a liquidation petition, and the mortgagee afterwards
(c) lie Bainhidgc, 8 Ch. D. 218.
\d) Brantom v. Griffits, 1 C. P. D. at pp. 355, 357 ; and see Hawlclns v.
Walrond, 1 C. P. D. 280 ; IVcbstrr v. Foh-o; L. R., 2 P. C. 60.
552
BILLS OF SALE.
Sect. 8.
The requi-
sites.
i. Attestalion.
Sect. 10,
subsect. 1.
Who may be
attesting
■witness.
claimed the right to distrain the chattels upon the mort-
gaged property for a year's rent under the attornment
clause : — It was held, that the arrangement was a mere
device to give the mortgagee an additional security in the
event of the mortgagor's bankruptcy, and was therefore in
that event void as a fraud upon the bankrupt law, and
that sect. 34 did not protect a distress levied for a mere
sham rent {e). This principle of the bankrupt law seems
to be by this section imported into the Bills of Sale Act,
to the operation of which transactions of the above nature,
as well as mere bare powers of distress, are now subject.
In cases where there is a tenancy the criterion will be what
is " a fair and reasonable" rent (/).
By sect. 8 (r/), the requisites of a bill of sale are set
forth ; they are attestation, registration and the statement
of the consideration ; and non-compliance with these pro-
visions renders a bill of sale void, as against the persons
and in respect of the property therein specified.
The requirement of attestation is a new provision, and
the mode of conforming to it is set out in sect. 10, sub-
sect 1 (//), which requires a solicitor to attest the execution,
and to state in his attestation that lie has explained the
effect of the bill of sale to the grantor (/).
A grantee under a ])ill of sale, though a solicitor, cannot
liimself be the attesting witness to such bill of sale (/.•) ;
but the grantee's solicitor (/) or his clerk [m) may. The
subsection is satisfied by the attesting solicitor's statement
that he has explained the bill of sale without having done
{e) Ex parte Wdliams, In re TJtompmn, 7 Ch. D. 138.
(/) Stockton Iron Furnace Com pinu/. In re, 10 Ch. D. 335; 48 L. J.,
Ch. 417. And see Morton v. Woods] L. R., 4 Q. B. 293, at p. 307.
[g) See Appendix, post. The proposed act provides for the repeal of
this section and tlie enactment of new provisions, see post, p. 565.
(/;) See Appendix.
(j) The attestation may be proved by tlir attesting- solicitor, or by an
oiiice copy under sect. l(j, see Appendix. See sect. 9 of the projiosed act,
post, p. 5GG.
(A) Seal V. Claridge, 7 Q. B. D. olG.
(/) Pencm-den v. Roberts, W. N. 1882, 38.
(w) milv. Kirkwood, W. N. 1880, 23; 28 W. R. 358. But sec the
proposed alteration in the law, post, p. 5GC, sect. 9.
REGISTRATION. 653
SO in fact (o), though, semble, in such case the attesting
BoHcitor would render himself liable to civil and penal
consequences (o) ,
Section 10, subsection 2 (;;), provides the mode of regis- ii. Rcgistra-
tering a bill of sale under this act. It must be registered '''""•
within seven clear days after its execution. Under the subsect.'2.
Act of 1854, it was twenty-one days. The original bill of
sale, as well as a copy, and the affidavit, are to he presented
to the registrar ; but it seems that only the bill or a copy
need be Jiled with the affidavit (q). The affidavit in
addition to the matters hitherto necessary must swear to
the due execution and attestation of the bill of sale (r).
The bill of sale or copy, as the case may be, and the affi-
davit must be filed at the same time («) .
The requirements of a description of the residence and Description
,. r, ,-, , ^ 11 1' •: • of residence
occupation oi the grantor and every attesting witness is a and occu-
re-enactment of the previous law (f). The extent of parti^ pation.
cularity required in the statement of residence is " a reason-
ably sufficient description of a residence which would
guide the inquiries of a person who may be interested in
knowing whether the individual whom he proposes to
trust has made any disposition of property by way of a
bill of sale" (u), and of the description of the occupation it
has been said, " the object of 17 & 18 Yict. c. 30, s. 1, is
to give the assignee and creditor a true idea of the position
in life of the assignor, and misdescription or absence of
(o) Ex parte Xaiional Meycantile Bank, 15 Cli. D. 42.
(ju) See Appendix. The proposed act provides for local registration,
see post, p. 567.
{q) See Appendix, sect. 10, subsect. 2, and sect. 12, in Ex parte Carter,
12 Ch. D. 908, a copy only seems to have been filed, see ihid. page 909.
By sect. 16, office copies of the bills of sale or copies filed, and of the
affidavits filed therewith, and of the affidavits of renewal on prima facie
evidence thereof, and of the fact and date of registration.
(r) For instances of sufficient and insufficient affidavits, see Ex parte
Carter, 12 Ch. D. 908 ; Sharpe v. Birch, 8 Q. B. D. 111.
{h) See the section, and GrimlM v. Brcndoii, 6 C. B., N. S. 698; 28
L. J., Ex. 333.
(t) Sect. 10, subsect. 2, see Appendix. And see 17 & 18 Vict. c. 36.
\n) Jones V. Harris, L. R., 7 Q. B. 157 ; Briggs v. Boss, L. E,., 3 Q. B.
268 ; Tlior}}e v. Browne, L. R., 2 H. L. 220. See also Heicer v. Cox, 8 E.
&E. 428; 30 L. J., Q. B. 73.
554 BILLS OF SALE.
true description in regard to the occupation is substan-
tial" (c). It is not sufficient that the bill of sale contains
the required descriptions, the affidavit must also contain
them (.r), and tlie description of every attesting witness is
necessary if there are more than one (y). If, however, the
affidavit sufficiently refers to the description in the bill of
sale or copy to which it is annexed, and of which it forms
part {z) , to incorporate it by reference, an incomplete de-
scription or even omission of description in such affidavit
may be thus supplemented (r/). A contradictory descrip-
tion, however, or mis-statement cannot be thus corrected
by reference {b) .
The description in the affidavits of the residence and
occupation of the grantor must be that which is true at
the time of swearing the affidavit, not of giving the bill of
sale (f). A statement in the affidavit that the grantor
" was until lately" a commercial traveller was held insuffi-
cient, as being vague and misleading {d). It is a sufficient
description of the residence of the grantor or attesting
witness to state his place of business, or if he be a clerk
that of his employer {c) . An erroneous addition appended
to a description itself sufficient will not vitiate it (_/").
Thus " New Street, Blackfriars, in the coimty of Middle-
sex," and " AetoTi, in the city of London," were held good,
a sufficiently certain description remaining after rejection
of the erroneous additions (/).
(;•) Alkn V. Thompson, 1 H. k N. 16 ; 25 L. J., Ex. 249.
\x) Hatton \. English, 1 E. & B. 94 ; 26 L. J., Q. B. 161 ; FIckard v.
Ftrbi/, 5 H. & N. 9 ; 29 L. J., Ex. 18 ; Brodrick v. Seal,; L. R., 6 C. V. 98.
(,y) See the subseet. Appendix. Xlchohon v. Cooper, 27 L. J., Ex.
393 ; I'lcard v. Blarringc, 1 Ex. D. 364.
(z) Baiibun/v. White, 2 II. & C. 300; 32 L. J., Ex. 2r)8.
[a) Routhv. Roublot, 1 E. & E. 850; 28 L. J., Q. B. 240; Jones \.
Harris, supra; Ex parte Maelcenzie, 42 L. J., Bank. 25.
{h) Murray v. Mackenzie, L. R., 10 C. P. 625.
{c) Button V. O^Keill, 4 C. P. D. 354, disapproving' of The London and
Westminster Loan, ^-c. Co. v. Chase, 12 C. B., N. S. 730 ; 31 L. J., C. P.
310.
(d) Castle v. Boicnton, 5 C. P. D. 56.
(r) Grant v. Shaic, L. R., 7 Q. B. 700; Attcnhorouqh v. Thompson, 2 H.
& N. 659 ; 27 L. J., Ex. 23 ; Blaekwell v. England, 27 L. J., Q. B. 124.
(/) Hewer \. Cox, 30 L. J., Q. B. 73; Blottnt v. Llarris, 4 Q. B. D. 603.
DESCRIPTION OF RESIDENCE AND OCCUPATION. 665
A company has been held properly described as re-
siding at its principal office {g). Casual or temporary
occupation need not l)e stated, but only the fixed business
or avocation by which a man gains his living (/). "Where
the description is prima facie sufficient, the onus lies on
those who say it is not to show that the person is not wliat
he is described (/.•). Apparent absence of occupation will
not, if there be in fact occupation, justify non-description
of it (/), but if no occupation is stated, the onus of proving
occupation is on those who impugn the validity of the Inll
of sale (m).
"Grentleman" has been held to sufficiently describe a
person who had formerly been a coal agent, but at the
time of the bill of sale was out of employment {ii), and a
medical student who had only occasionally acted as a sur-
geon's assistant (o), but not to be a sufficient description
of a solicitor's clerk (p), though formerly practising as
an attorney (q), or where he was retained to make out the
accounts, and send out the bills of a dissolved firm to which
he had been clerk {>•), nor of a clerk in the audit office,
though in respect of the furniture at his private house (s).
(ff) S/iears y. Jacob, L. E., 1 C. P. 513; and for other decisions upon
the siifiiciency of the description of residence, see M'C'iie v. James, 19 W.
R. 158; BriggsY. Boss, L. E., 3 Q. B. 268; Be Hans, 10 Ir. Ch. Rep.
100; 1 L. T., N. S. 467; Kc payfc McHaltle, In re Wood, 10 Ch. D. 398 ;
48 L. J., Bank. 26 ; Cooper v. Ibhcrso», 44 L. T., N. S. 309 ; Ex parte Wolfe,
44 L. T., N. S. 321.
{i) Sutton V. Bath, 3 H. & N. 382; 27 L. J., Ex. 388; Ex jjarte
Xational 3IcrcantUc Bank, 15 Ch. D. at p. 50.
{Ic) Grant v. Shaw, L. R., 7 Q. B. 700.
[I) Adams v. Graham, 33 L. J., Q. B. 31.
(;h) Smith v. Chase, supra, at p. 60; and Siftton v. Bath, supra. But
see a doubt expressed on this point in Castle v. Doicnton, 5 C. P. D. at
p. 57.
(«) Morewood v. Soath Yorkshire Railtvarj and River Dun Compa:i\j, 3 H.
&N. 798; 28 L. J., Ex. 114.
(o) Sutton V. Bath, supra ; and see, for other instances of sufficient
descriptions, Smith v. Chase, 1 C. P. D. 60 ; Lamb v. Britce, 45 L. J.,
Q. B. 538 ; Grant v. Shaw, L. R., 7 Q. B. 700 ; Ex parte Xational Deposit
Bank, 26 W. R. 024 (C. A.).
{p) Bryden v. Hope, 9 W. R. 18 ; Brodriek v. Scale, L. R., 6 C. P. 98.
\q) Tuton V. Sanoner, 27 L. J., Ex. 293.
(?■) Benle v. Tennant, 29 L. J., Q. B. 188.
(*) Allen Y. Thompson, 25 L. J., Ex. 249.
556 . BILLS OF SALE.
An attesting witness's description of himself as deponent
is a sufficient affidavit of his description {f). An affidavit
describing the grantor's residence and occupation to the
best of the belief of the deponent was held sufficient {u).
Shareholders in a company cannot be attesting witnesses
to a bill of sale given by the company (;r) .
Sect. 10, If a bill of sale is given subject to a defeasance, condi-
subsect. 3. ^-Q^ Qj, declaration of trust not inserted in the body of the
coBdition or bill, such defeasance, condition or declaration of trust must
declaration of -j^g written ou the same deed as the bill itself, and before
registration, and must be also set forth in the copy (z).
This is a re-enactment of the same provision in sect. 2 of
the Act of 1854, under which it has been decided that it
is not necessary to disclose, on the face of the bill of sale,
the fact that the person appearing as the grantee is only
the trustee for the person who really lent the money {a) ;
that when a bill of sale was given to secure a sum of
money payable on demand, and a parol agreement existed
for the payment of the debt by small w^eekly instalments,
this parol agreement amounted to a defeasance or condition
within the act, and the want of registration of it avoided
the bill of sale against the tntstee in bankruptcy (b) ; that,
where a bill of sale was given to secure 130/., 100/. only
being advanced, 30/. being charged for interest and bonus,
and a written memorandum was signed at the same time
by the mortgagor engaging to pay the 30/. in full, not-
withstanding the money secured might be repaid on the
mortgagee's rights enforced before the expiration of the
time limited for payment, this memorandum was neither
defeasance, trust, nor condition within the meaning of the
act, and did not in any way affect the validity of the bill
(0 ,Sl(idd('>i V. Scrjanit, 1 F. cS: F. 3-22 ; 27 L. J., Ex, 392; Wilcoxon v.
Searbij, 29 L. J., Ex. Ii34.
(!<) Roe V. Bradshaw, L. R., 1 Ex. 10(3.
{x) Shears v. Jacob, L. R., 1 C. P. 513 ; DetJ'dl v. White, L. R., 2 C. T.
144.
{z) Sect. 10, subs. 3, post, Appendix.
\a) Rohimon v. Co/linfjwoo>/, 17 C. B., N. S. 777.
(A) Ex parte Sonlhani, L. R., 17 Eq. 578.
PRIORITIES, 557
of sale (c). " If this is in suLstanco any tiling, it is an
additional bill of sale, of whicli the grantee cannot avail
himself if it is not registered, but the non-registration
of an additional bill of sale does not affect a previous
registered one" (d). "A condition in every case denotes Condition,
something which prejudicially affects the interest of the
donee" {e), or, in other words, " the subsection being meant
to provide only for cases where some benefit is reserved to
the grantor" (/).
Provision is made in sect. 10 that where two or more Priority,
bills of sale are given in respect of the same chattels they ^^^ "^^ y^*^*-
shall have priority by the date of their registration [y).
This applies not only as between registered but as between
registered and unregistered bills of sale {h), Registration,
therefore, is now necessary as between mortgagees, even
within the seven days' limit. Under the Act of 1854, ^^ & 18 Vict.
. . c. 36.
however, the operation of which is preserved as to bills of
sale executed before 1st January, 1879, the priorities of
bills of sale in respect of the same goods were determined
by the date of their execution, for imder that act, as under
the present (i) independently of the priority clause which
is new, registration was necessary only as against the per-
sons mentioned in the act (A-). A bill of sale, therefore,
though unregistered gave a valid title as against a subse-
quent registered bill of sale (/), but this rule was affected
by the event of the grantor's bankruptcy, or of execution
upon his goods, in which cases the unregistered bill would
be entirely displaced (except as regards any goods the
holder might have seized under it before the bankruptcy
(f) Ex parte Collins, In re Lees, L. R., 10 Cli. 307.
{(l) Ibid., per James, L. J.
[e] Ibid., at p. 372.
(/) Robinson v. Colling icood, supra.
{g) Sect. 10. See post, Appendix.
\h) ConeUij V. Steer, 7 Q. B. D. 520 ; Lyons v. Tucker, id. 523.
(0 Davis V. Goodman, L. R., 5 C. P. D. 128 ; 49 L. J., C. P. 344.
[k) Ex imrte Allen, In re Middleton, L. R., 11 Eq. 211 ; Uills v.
Shepherd, 1 F. & F. 191 ; Barker v. Aston, id. 192. The proposed act,
however, provides for the absolute avoidance of all bUls of sale, unless
attested and registered. See p. 56G.
(/) Richards v. James, L. R., 2 Q. B. 285, at p. 291.
5o8
BILLS OF SALE.
Transfer or
assignment of
registered
bill of sale.
Sect. 11.
Rene-R-al of
registration.
Sect. 14.
Rectification
of register
or execution) {m), and the later registered bill would be
good against the trustee or execution creditor, and thus
obtain a priority which, but for such bankruptcy or execu-
tion, it would not have had («).
A transfer or assignment of a registei'ed bill of sale need
not be registered. Thus where by a deed, between the two
parties to a bill of sale (part of the sum secm'ed by which
had been paid off) and the plaintiff, the security was
transferred and the goods assigned to him on his paying
off the amount remaining due on the bill, and making a
further advance to the grantor ; it was held by the Court
of Appeal that, whether or not the deed was an effectual
security, without registration, for the fresh advance, it was,
as to the amount which remained due on the former bill of
sale, a transfer and valid to that extent without registra-
tion under the Bills of Sale Act, 1878, so as to entitle the
plaintiff to the goods (o) .
Sect. 11 (p) provides for the renewal of registration
every five years. A transfer or assignment of a bill of
sale does not of itself necessitate a renewal of registration,
and we have seen that such transfer or assignment does
not itself require registration (). Assignees of bills of
sale are in the same position as their assignors. If a bill
of sale is assigned before registration it must be registered
by the assignee to make it good, if after registration the
assignee must renew the registration in due course to keep
it good (r) . The provisions of this act as to renewal of
registration are retrospective (s).
Sect. 14 empowers a judge of the High Court to order
rectification of the register imder the cu'cumstances therein
{in) In re Barraud, Ex parte Cochrane, 3 Ch. D. 334 ; 4 Ch. D. 23.
[u) In re Barraitd, Ex parte Cochrane, 3 Ch. D. 324; 4 Ch. D. 23;
liichards v. James, L. R., 2 Q. B. 285; Edu-ards v. English, 7 E. & B.
564; 26 L. J., Q. B. 193.
(o) Home v. Hughes, 6 Q. B. D. 67G.
{p) Post, Appendix.
{q) Sect. 10, post, Appendix. ITorne v. Hughes, supra.
(r) Karet v. Kosher Meat SuppJ;/ Association, 2 Q. B. D. 361.
(*) Sect. 23. post. Appendix,
THE STATEMENT OF THE COXSIDERATIOX. 559
specified, and to extend the time for registration in that and extension
behalf (0- "^*™'-
Sect. 22 provides for registration when the time expirees Sect. 22.
on a Smiday, or other day when the office is closed {>().
Grreat care must ho taken in accurately complying with iii- The con-
ike requirement that the consideration must be set forth (x).
It must be set forth in the body of the deed ; if not truly
stated there, a correct statement contained in a receipt at
the foot of the deed will not satisfy the statute, such re-
ceipt not being part of the deed (?/). The consideration
required to be stated is that which the grantor receives for
giving the bill of sale, not necessarily the amount to be
seciu-ed by the deed (;;) . If part of the consideration stated
in a bill of sale is, by the grantor's direction given at the
time of the execution of the deed, applied in satisfaction
of a then existing debt owing by him, the money so paid
may be properly stated in the deed to be then paid to
him {a).
The amount of the expenses incident to the preparation
of the bill of sale, is not such a " then existing debt owing
by the grantor," and the deduction of it from the amount
stated to be advanced will invalidate the biU of sale {b) ;
so also will deductions by way of future interest (c), bonus,
or commission {d). Subject to the above restrictions, and
to the necessity of setting forth the real consideration, the
act does not require a collateral agreement between the
grantor and grantee as to the application of the considera-
{t) Post, Appendix, sect. 14.
[it] Post, Appendix.
(sc) Sect. 8, see Appendix.
(i/) Ex jMi'te Charinfj Cross Bank, 16 Ch. D. 35.
{z) Ex parte CkaUhior, 16 Ch. D. 260.
[a) Ex parte Erith, In re Coichion, W. N. 1882, p. 5, overruling J.r
parte National Mercantile Bank, 15 Ch. D. 42, and Ex parte ChalUnor, 16
Ch. D. 260, so far as they decided that the expenses incidental to the deed
might be deducted from the amount stated to be advanced. And see In
re Spindler, 19 Ch. D. 98.
[b) Id., and see Ex parte Molph, In re Spindler, 19 Ch. D. 98.
[c) Ex parte Charing Cross Bank, 16 Ch. D. 35; Re Barker, 44 L. T.
113.
[d) Hamilton v. C/iaine, 7 Q. B. D. 1, 319.
560 • BILLS OF SALE.
tlon to be set forth (e), and it is quite competent to the
grantor to direct Avhat shall be paid to himself, and what
shall be paid to others on his behalf (/'). A distinction
has also been made between strict literal accuracy, and
accuracy with respect to either the legal or the business or
mercantile effect of the matters set forth {g). Thus, where
the consideration was stated to be 7,'VjOI. now paid, though
in fact no money passed, but during several years there
had been several loans and advances to the grantor by the
grantee, and upon a statement of account between them
this sum was found to be the balance due, which sum with
interest the grantor by the bill of sale promised to pay to the
grantee on demand, by notice in writing ; — it was held, that
the consideration was stated with substantial accuracy, the
legal and mercantile and business effect of the transaction
being given, vi^., that the giving of the deed wiped out
the old debt, and constituted the balance thus found due
a new debt payable only after demand in writing — thus
giving a new credit {(j) .
Avoidance. Non-compliance with the requirements of the act as to
attestation, registration and trutliful statement of con-
sideration renders a bill of sale void, not as against all
(1) As against the world, but only as against trustees or assignees in
'^'^n^^/'^'^" bankruptcy or liquidation, or under assignments for
the benefit of the creditors of the grantor ; Sheriffs'
officers or other persons seizing in execution of any pro-
cess of Court ; Execution creditors {/i). This want of
attestation and explanation does not avoid a bill of sale
(2) In respect as between grantor and grantee (/) ; and in respect of
pos?esfioi%r chattels which after the expiration of seven days from the
apparent giving a bill of sale of them are found, in the event of a
possession, of °
grantor.
(f) Ex parte National 3[erca)itUe Bank, 15 Ch. D. 42; Ex parte Eolph,
In re Spindlcr, 19 Ch. D. 98.
(/) Hamlijn v. Bdtelci/, h C. P. D. 327.
{g) Credit Company v. I'ott, G Q. B. D. 29.5.
(/t) Sect. 8, see Appendix. See, however, sect. 8 of the proposed act,
p. 565.
(i) Davis V. Goodman, 5 C. P. D. 128; 49 L. J., C P. 341; and see
In re Knott, 7 Ch. D. 549, n. 1 ; In re d'Epineal, 20 Ch. D. 217.
APPARENT POSSESSION. 561
bankruptcy or liquidation petition being filed (J), or an as-
signment made for the benefit of creditors, or an execution
levied, in the possession or apparent possession of the
grantor (A-).
Apparent possession is defined by sect. 4 (l) . The words Apparent
of this interpretation clause are the same as in the Act of P"''^°^^^°°-
1854, and the meaning of them has been said to be, " that
the goods shall be deemed to be in the apparent possession
of the vendor as long as they are on the premises occupied
by him, if nothing more has been done to them than mere
formal possession taken" {m). Thus, where a person sold
by a written agreement some timber on a private wharf
and some timber on a public wharf, and by another written
agreement some furniture in a house belonging to him,
part of which he had previously used as an office, and
occasionally slept in ; and the vendee took possession of
the key of the private wharf and sold some of the timber
lying there, and took persons to the public wharf (the key
of which remained in the hands of the wharfinger) to look
at the timber with a view to sale, and occasionally used the
rooms, the use of which the vendor had discontinued, and
paid the servant's wages as stipulated ; it was held that
there was no possession or apparent possession of the timber
either at the private or public wharf, or of the furniture
within the Bills of Sale Act, so as to render them liable to
seizure under an execution against the vendor. Bram-
well, B., saying, " Here a great deal more had been done
to them than formal possession taken" {n).
It is "formal possession" only, for instance, where a Distinction
between for-
(./) Under the Act of 1854 it was as to goods in the apparent possession
of the grantor at the time of the bankruptcy, and the title of the trustee
had relation back to the commencement of the bankruptcy. '^Ex parte
Attwater, 5 Ch. D. 27. The protecting clauses of the Bankruptcy Act,
1869, ss. 94, 95, have no operation as regards a transaction which is made
void by the Bills of Sale Act. Ibid.
(k) Sect. 8, see Appendix. See sects. 8 and 9 of the proposed act, post,
pp. 565, 566.
(l) See Appendix.
(>«) Gouffh V. Everard, 32 L. J., Ex. 210.
(«) Ibid., and Smith v. Wall, 18 L. T., N. S. 183.
G.
562 BILLS OF SALE.
mal and real "broker is simply put in to prevent removal, and allows tlie
possession. debtor and his family to use the goods and everything to go
on as before (o) . But dealing with the goods as by packing
them up for removal is among other things an assertion of
actual possession (7;), and so where the grantee of a bill of
sale takes possession of the goods comprised in it, and
advertizes them for sale £fe the goods of the grantor sold
under a bill of sale, the goods, though still in the house of
the grantor, are no longer in his apparent possession {q) ;
but where, in a similar case, a sale was announced by
placards, from which, however, it could not be inferred
that the sale was made under a bill of sale, and not by the
grantor himself, it was held there was nothing more than
formal possession {)■).
There must bo The "occupation" rcfeiTed to in the definition of appa-
Eictnal lie facto . , . . 117/., ;• /a mi
occupation, rent possession [s) is actual ae facto occupation [t). Inus
the grantor of a bill of sale, not registered, was tenant of
rooms where the goods comprised in it were, but he resided
elsewhere. Having made default, he gave the keys of the
rooms to the grantee, who opened them and put his name
on some of the goods. None, however, were removed : —
Held, that the grantor did not "occupy" within the
meaning of the act, and that the bill of sale was valid
as against the execution creditor {u).
Demand of When the grantor, after default in payment, and after
possession bv^ ^^^^^^^ 0^ possession and threat by the grantee, remained
grantee. in possession until the filing a liquidation petition, it was
held that the grantee's title to and demand of possession
did not take the goods out of the possession of the grantor
(0) Ex parte Jay, L. E., 9 Ch. 697, at p. 701 ; Ex parte Ilooman, L. R.,
10 Eq. 63 ; Ex parte Zcivis, L. R., 6 Ch. 626 ; >Scal v. Claridgc, 7 Q. B. D.
516.
{p) Ex parte Jarf, supra. And see Ex parte Mortlock, In re Basham,
W. N. 1881, p. 161.
{q) Emanuel \. Bridgcr, L. R., 9 Q. B. 286.
(/■) Ex parte Leivis, L. R., 6 Ch. 626. And see also Elclcard v. Mar-
riage, 1 Ex. D. 364, and Js/iton v. lUackshaw, L. R., 9 Eq. 510,
(a) Sect. 4, post. Appendix.
(/) liol'uison V. Jir'ujfjs, L. R., 6 Ex. 1.
[i() Ibid. But sec Ancona v. Hogen, infra.
DUPLICATE BILLS OF SALE. 563
witliin the act (x). Semble, if, in the same circumstances,
the goods were held for the grantor hy a bailee, the
grantor would still be in possession within the act {//).
Possession by the sheriif under an execution issued Possession by
either by the grantee or by a third person, even though l^^,^^ api^i-'ent
the grantee has himself taken no possession, takes the possession,
goods out of the apparent possession of the grantor (s) .
Under the Act of 1854, goods that were left in the Order and
apparent possession of a grantor of a bill of sale, but
which were protected by the registration of the bill, were
still liable to be claimed by the trustee in bankruptcy by
the application of the order and disposition clause of the
Bankruptcy Act, 1869 {a). By sect. 20 of the present act, Sect. 20.
chattels comprised in a duly-registered bill of sale are
exempted from the application of that principle (i).
By sect. 9 subsequent bills of sale executed in renewal Sect. 9.
of prior unregistered bills within or on the expiration of f^^^^^^f^*^
seven days from their execution are rendered void, except
so far as they may be bona fide given to correct mistake {c).
This has put an end to the practice which prevailed under
the former act of executing successive bills of sale each
within twenty-one days from the execution of a prior bill,
and so avoiding the necessity of registration {d). It has
been held, however, that this section does not apply to
duplicate bills of sale executed after the expiration of the
seven days therein mentioned {e). Of course, in the event
of bankruptcy, a duplicate or the last bill of sale of a series
(.r) Ancona v. Holers, 1 Ex. D. 285.
ly) Bid. But this seems doubtful and was not necessary for the deci-
sion of the case.
[z) Ex imrte Saffery, 16 Ch. D. 668; Ex parte Mutton, L. E., 1-1 Eq.
178, not followed.
(a) 32 & 33 V^ict. c. 71, s. 15, subs. 5.
\b) See post, Appendix. The proposed act, however, provides for the
repeal of this sect. See post, p. 565.
(c) See sect. 9, post, Appendix.
{d) Smalev. Bun; L. E., 8 C. P. 64; Ramsdeii v. Lnpton, L. R., 9
Q. B. 17 ; Ex parte Harris, L. R., 8 Ch. 48.
[e) Carrard v. Meelc, 43 L. T. 760.
oo2
564
BILLS OF SALE.
1. Landlord's
right of dis-
tress.
2. Grantor
left in posses-
sion of goods
of trade.
3. The bank.
ruptcy laws.
would be liable to be avoided, as being given for a past
consideration (/).
Independently of the provisions of the Bills of Sale Act
the grantee of goods under a bill of sale is subject to cer-
tain risks affecting tbe value of bis security.
1. The landlord's right of distress is paramount.
2. Where the goods which are the subject of the bill of
sale are trade goods or things which a person in possession
may be presumed to have the right to dispose of in the
ordinary course of business, if such goods are left in the
possession of the grantor a sale by him in the ordinary
course of his trade or business will give to a bond fide
vendee, who has taken possession of them, a good title to
them against the grantee under his bill of sale, although
registered ({/). If the sale to and removal by the vendee
be not in the ordinary course of business he will have no
title against the biU of sale holder (//).
3. Under the bankruptcy laws a bill of sale, though
complying with all the requisites of the act, may some-
times be declared void as a fraud upon those laws.
Thus, a conveyance of a person's whole (/) property
to secure a past debt is an act of bankruptcy, and a
bill of sale so given will be declared void against the
trustee in bankruptcy (A-) . Within the principle above
mentioned, and therefore void against the trustee, is a bill
of sale which is the last of a series of successive bills given
in renewal or substitution (/). A bill of sale, however,
(/) Ex parte Cohen, L. E., 7 Ch. 20 ; Ex parte Stevens, L. E., 20 Eq.
786 ; Ex parte Furber, f, Ch. D. 181 ; Ex parte Payne, 11 Ch.^D. 539.
(g) National Mercantile Bank v. Hampson, 5 Q. B. D. 177 ; Taylor v.
M'Keand, 5 C. P. D. 358.
(/i) I'aync v. Fern, G Q. B. D. 620 ; Taylor v. M'Keand, supra.
(«■) Book debts must be taken into consideration. Ex parte Burton, 13
Ch. D. 102 ; and see Ex parte Uaivkcr, L. R., 7 Ch. 214.
(A) Ex parte Uawker, aw^va.; In re n'ood, 1,. E,., 7 Ch. 302; Ex parte
Fisher, id. 636; Ex parte Bolland, 8 Ch. D. 230; Ex parte Kilner, 13 Ch.
D. 245 ; Ex parte Burton, id. 102 ; Crcnccour v. Salter, 18 Ch. D. 30. And
see 32 & 33 Vict. c. 71, s. 6, subs. 2. Independently of the bankruptcy
law a past debt is a sufficient consideration, see cases cited.
(/) Vide ante, p. 563. And see Ex parte Cohen, L. E., 7 Ch. 20; Ex
parte Stevens, L. E., 20 Eq. 786 ; Ex parte Furber, 6 Ch. D. 181 ; Ex parte
Tayne, 11 Ch. D. 539.
AGREEMENT TO GIVE BILL OF SALE, 565
will not be void as given for a past debt if there be at the
same time a substantial fresh advance, of which the debtor
has the advantage (m), nor if it is executed in pursuance
of an agreement made at the time the consideration arose
or the money was advanced (;i). But such agreement to
give the bill of sale must be absolute and peremptory (o) ;
if made upon a condition that the bill was not to be exe-
cuted till the lender "lost confidence" in the borrower (^;),
or if the execution of the bill of sale to be given in pur-
suance of it is purposely postponed until the trader is in a
state of insolvency, in order to prevent the destruction of
his credit, the agreement will not support such bill of sale
against the trustee in bankruptcy ($■).
Note. — There is a bill of tliis session in progi-ess entitled the BUls of
Sale Act (1878) Amendment Bill, by which, if jjassed into law, Tery
considerable changes will be effected with regard to bills of sale.
The principal provisions of it are the following : —
"Every biU of sale made or given in consideration of any sum under EiU of sale
fifty pounds shaU be void" (sect. 12). lender oQl. to
The repeal of ss. 8 and 20 of the Act of 1878, and all other enactments ^ ^ "^ *
of that act which are inconsistent with this act ; but the validity of any- „ P •,' ^„ n
thing done or suffered under that act before the commencement of this, is j^(,^ gf i878.
not to be affected (sect. 1 7) .
In place of sect. S of the Act of 1878 it proposes that —
"Every bill of sale shall be duly attested, and shall be registered imder BiU of sale to
the principal act within seven clear days after the execution thereof, or if ^^ '^oi'^ unless
it is executed in any place out of England then witliin seven clear daj-s ' ^.. , . ■,
after the time at which it would in the ordinary course of post arrive in
England if posted immediately after the execution thereof ; and shall
truly set forth the consideration for which it was given ; otherwise such
bin of sale shall be void in respect of the personal chattels comprised
therein" (sect. 8).
(m) matonv. Cnitficell, 1 E. & B. 15 ; 22 L. J., Q. B. 78; Zoinax v.
Buxton, L. R., 6 C. P. 107 ; Ex parte Sheen, In re Winstanlcij, 1 Ch. D.
560 ; Ex parte King, 2 Ch. D. 256.
[n) Ex parte Homan, L. E,., 12 Eq. 598 ; Ex parte Fisher, supra ; In re
Jackson, Ex parte Eall, 4 Ch. D. 682.
(o) Ex parte Fisher, supra ; Ex parte Burton, supra ; Ex parte Kilncr,
supra.
{p) Ex parte Burton, 13 Ch. D. 102.
\q) Ex parte Fisher, L. E.., 7 Ch. 636 ; Ex parte Kiiner, 13 Ch. D. 245 ;
Ex parte Bollind, In re Gibson, supra.
566
BILLS OF SALE.
Ante, p. 560
(n. 1).
Execution of
bills of sale.
Eill of sulo
with power to
seize except in
certain events
to be void.
Void in
respect of
chattels not
specified.
After-
acquired
property.
Exceptions.
See ante,
p. 548.
Order and
disposition.
Ante, p. 5C3,
Bill of salo
void us
This win render a biU of sale void for want of due attestation, registra-
tion or tiaie statement of the consideration absolutely in respect of all
goods comprised in it. — And the decisions of Davis v. Goodman, 5 C. P. D.
128 ; In re Knott, 7 Ch. D. 549, n. (1) ; and In re D'Epineul, 20 Ch. D.
217, will no longer apply.
The bill further proj)oses that —
' ' A bill of sale shall be void unless the same is executed in the presence
of a person who has authority to take oaths in the Supreme Court of
Judicature in England, and, if the bill is executed in England, who is
also a certificated solicitor, and unless such person shall carefully explain
to the grantor the nature and effect of the bill of sale, and shall state in
the attestation of the execution of the bill of sale that he has before the
execution of the bill of sale made such explanation ; and further, if the
bill is executed in England, that he was appointed by the grantor to be
and is the solicitor of the grantor and not the solicitor of the grantee for
this piu-pose ' ' (sect. 9) .
That—
' ' Personal chattels assigned imder a bUl of sale shall not be liable to
seizure by the grantee for any other than the following causes : —
(I.) If the grantor shall make default in payment of the siim or sums
of money thereby secured at the time therein pro\dded for pay-
ment ;
(2.) If the grantor shall become a bankrupt, or suffer the said goods or
any of them to be distrained for rents, rates, or taxes ;
(3.) If the grantor shall fraudulently remove or suffer the said goods,
or any of them, to be removed from the premises ;
(4.) If the gTantor shall not, without reasonable excuse, upon demand
in writing by the grantee, deliver to him his last receipts for rent,
rates, and taxes" (sect. 7).
That a bill of sale shall be void in respect of any personal chattels not
eniunerated in the schedule which is to be annexed to it (sect. 4) ; and
that a bill of sale shall be void in respect of property after acquired, or
of which the grantor was not true owner at the time of execution (sect. 5) ;
except — ■
"(1) Any growing crops separately assigned or charged where sucb
crops were actually growing at the time when the bill of salo
was executed ;
* ' (2) Any fixtures separately assigned or charged, and any plant, or
trade machinery where such fixtures, plant or trade machinery
arc used in, attached to or brought upon any land, fai'm, factory,
workshop, shoji, house, warehouse or other place in substitution
for any of the like fixtures, jilant or trade machinery enumerated
in the schedule to such bill of sale ' ' (sect. 6) .
The renewed application of the order and disposition doctrine of the
bankruptcy law, Avliich had been expressly excepted in the Act of 1878
(sect. 20 to be repealed, see supra), is also proposed in sect. 13 of the bill,
' ' Where a person, within twelve months after ho has executed a bill
BILLS OF SALE. 567
of sale, becomes subject to the provisions of the law for the time being in against _
force relating to bankruptcy or any similar proceeding, whether he is trustee in
adjudged bankrupt or has his affairs liquidated by arrangement, or enters ^
into a composition or otherwise, such bQl of sale shall, as against the
trustee or other person entitled to the estate of such person under the said
law, be void in respect of any personal chattels which, at or after the
commencement of the bankruptcy or liquidation, or other date, at or to
which the proceedings under the said law are deemed to commence or to
relate, are in the possession or apparent possession, or the order and dis-
position of the person executing such bill of sale."
And an analogous provision with respect to biUa of sale given by
companies is contained in sect. 15 : —
" "Where a company is wound up luider the Companies Act, 1862, and Bill of sale to
the acts amending the same, any bill of sale given by such company be void as to
within twelve months next preceding the commencement of the winding personal cnat-
up shall, as against the liquidators of the company, be void in respect of ^oggg
any personal chattels which, at or after the commencement of the winding
up, are by the consent and permission of the true owner in the possession
or apparent possession, or the order and disposition of the said company."
The security afforded by a bill of sale is to be further diminished by a
provision that —
"A bill of sale to which this act applies shall be no protection in BiU of sale
respect of personal chattels included in such bUl of sale which but for ^ot to protect
such bill of sale would have been liable to distress under a warrant for ^ ^ . ® ,^
against poor
the recovery of poor and other parochial rates. and parochial
Further, a gi-antee of a bill of sale (whether registered before or after rates,
the commencement of this act) who has seized goods imder it is not to be Grantee not
allowed to remove them from the premises on which they were seized, or to remove
sell them until the expiration of five clear days from such seizure. f°° ^ ~°^ ^®
These provisions, together -with a provision for the local registration of seizure,
the contents of bills of sale, and amended aiTangements for inspection of
the register from the substance of the proposed act, and by them, if they
become law, the security afforded by bills of sale will be seriously affected.
AN
COXTAIKIXO
THE STATUTES IN FOECE EELATING TO BANKEES,
BANK NOTES AND BANKING COMPANIES IN ENG-
LAND, SCOTLAND AND lEELAND EESPECTIVELY.
I. Relating to England, Scotland and Ireland.
17 GrEo. 3, c. 30.
Ati Act for further restraining the Negotiation of Promissorg
Notes and Inland Bills of Exchange, under a limited Sum,
tvithin that Part of Great Britain called England. ... 574
39 & 40 Geo. 3, c. 28, s. 15.
An Act for establishing an Agreement loith the Governor and
Compang of the Bank of England for advancing the Sum of
Three Millions toicards the Supplg for the Service of tlie
Year 1800 578
48 Geo. 3, c. 88.
An Act to restrain the Negotiation of Promissoi'y Notes and
Inland Bills of Exchange, under a limited Sum, in Eng-
land 579
55 Geo. 3, c. 184.
An Act for repealing the Stamp Duties on Deeds, Law Proceed-
ings and other icritten or printed Instruments, ^'c. , . 583
7 Geo. 4, o. 6.
An Act to limit, and after a certain Period to prohibit, the
issuing of Promissory Notes, under a limited Sum, in Eng-
land 585
7 Geo. 4, c. 46.
An Act for the better regidating Copartnerships of certain
Bankers in England, and for amending so much of an Act
of the 39th and 40th Years of the Reign of his late Majesty
King Geo. 3, intituled "An Act for establishing an Agree-
meyit with the Governor and Company of the Bank of Eng-
land for advancing the Sum of Three Millions toicards the
Supplg for the Service of the Year 1800," as relates to the
same 588
570 APPENDIX OF STATUTES.
9 Geo. 4, c. 23.
An Act to enable Banhers in Enc/land to issue certain unstamped
Pi'omissory Notes and Bills of Exchange, vjjon 2}(ij/ment of
a Composition in lien, of Stamp Duties thereon 600
9 Geo. 4, c. 65.
A.n Act to restrain the Negotiation, in Eiigland, of Promissory
Notes and Bills, tinder a limited Sum, issued in Scotland
or Ireland 606
3 & 4 Will. 4, c. 83.
An Act to compel Banks issuing Promissory Notes payahle to
Bearer on Demand, to make Returns of their Notes in Cir-
culation, and to authorize Banks to issue Notes payable in
London for less than 501 607
3 & 4 Will. 4, c. 98.
An Act for giring to the Corporation of the Governor and Com-
jniny of the Bank of England certain Privileges, for a limited
Period, under certain Conditions 609
1 & 2 YiOT. C. 96.
An Act to amend, until the end of the next Session of Par-
liamoit, the Law relative to Legal Proceedings by certain
Joint Stock Banking Companies against their own Jlembers,
and by such Members against the Compatiies 615
3 &4 Vict. c. 111.
An Act to continue, until the 3\st day of August, 1842, and to
extend the Provisions of an Act of the 1st and 2nd Years
of her present Majesty, relating to Legal Proceedings by
certain Joint Stock Banking Cotnpanies against their own
Members, and by such Jlembers against the Companies 617
4 Vict. c. 14.
An Act to make good certain Contracts zvhich have been or may
be entered into by certain Banking and other Copartner-
ships 618
7 & 8 Vict. c. 32.
An Act to regidate the Issue of Bank Notes, and for giving to
the Governor and Company of the Bank of England certain
Privileges for a limited Period 619
8 & 9 Vict. c. 76.
An Act to amend an Act of the last Session of
Parliament for regulating the Issue of Bank Notes in Eng-
land 633
16 & 17 Vict. c. 59.
An Act to repeal certain Stamp Duties, and to grant others in
lieu thereof; to amend the Laws relating to Stamp Duties ;
and to make perpetual certain Stamp Duties in Ireland 635
CONTENTS. 671
17 & 18 YiCT. c. 83.
An Act to amend the Laws relating to the Stamp Duties , . 635
19 YiCT. c. 20.
An Act to eontitiue certain Compositions payable to Bankers ivho
have ceased to issue Batik JVutes 630
19 & 20 Vict. c. 100.
An Act respecting the Election of Directors of Joint Stock
Banks 637
23 & 24 YiCT. c. 111.
An Act for granting to her Majesty certain Duties on Stamps,
and to amend the Laws relating to Stamp Duties .... 638
24 & 25 YicT. c. 91.
An Act to amend the Laivs relating to the Ltiland Bevemie. 638
25 & 26 YiCT. c. 89.
An Act for the Incorporation, Regulation and IVitiding-V]) of
Trading Co7npanies and other Associations 639
27 & 28 YiCT. c. 32.
An Act to enable certain Banking Copartnerships ivhich shall
discontinue the issue of their own Bank Notes to sue and be
sued by their Public Oj/icer 641
30 YiCT. c. 29.
A71 Act to amend the Law in respect of the Sale and Purchase
of Shares in Joint Stock Banking Coiytpanies 642
33 & 34 YicT. c. 97.
An Act for granting certain Stamp Duties in lieu of Duties of
the same kind now payable under various Acts and con-
solidating and amending Provisions relating thereto . . 643
34 YicT. c. 17.
An Act to make Provision for Bank Holidays, and respecting
Obligations to make Payments, and do other Acts on such
Baiik Holidays 652
34 & 35 YicT. c. 74.
An Act to abolish Days of Grace in the case of Bills of Exchange
and Promissory Notes payable at Sight or on Presenta-
tion 654
39 & 40 YiCT. c. 81.
An Act for amending the Law relating to Crossed Cheques 654
40 YiCT. c. 2.
An Act to provide for the Preparation, Issue and Payment of
Treasury Bills, and to make further Provision respecting
Exchequer Bills 655
572 appendix of statutes.
40 & 41 Vict. c. 59.
An Act to amend the Laio icith respect to the Transfer of Stock
forming part of the Public Debt of any Colony, and the
Stamp Duty on such Transfer 658
41 & 42 Vict. c. 31.
An Act to consolidate and amend the Laiv for preventing Frauds
iipon Creditors by secret Bills of Sale of Personal
Chattels 660
42 Vict. c. 11.
An Act to amend the Laio of Evidence with respect to Bankers*
Books 668
42 & 43 Vict. c. 76.
An Act to amend the Law with respect to the Liability of
Members of Banking and other Joint Stock Companies^ and
for other purposes 670
43 Vict. c. 11.
A71 Act to make Powers of Attorney and Requests for Trans-
mission of Dividend ITarrants by Post relating to India
Five per Cent. Stock applicable to India Four per Cent.
Stock 673
43 & 44 Vict. c. 20.
An Act to grant and alter certain Duties of Inland Revenue, and
to amend the Laws in relation to certain other Duties 674
II. Relating to Scotland exclusively.
5 Geo. 3, c. 49.
An Act to prevent the Inconveniences arising from the present
Method of issuing Notes and Bills by the Banks, Banking
Comjmnies and Bankers in that Part of Great Britain
called Scotland 674
7 Geo. 4, c. 67.
Ati Act to regtdate the Mode in zvhich certain Societies or
Copartnerships for Banking ifi Scotland may sue and be
sued 675
8 & 9 Vict. c. 38.
An Act to regulate the issue of Bank Notes in Scotland , . 682
CONTENTS. 673
IG «& 17 Vict. c. 63, s. 7.
An Act to repeal certain Stamp Duties and to grant others in
lieu thereof, to give Relief with respect to the Stamp Duties
on Newspapers and Supplements thereto, to repeal the Laiv
on Advertisements, and otherwise to amend the Laws re-
lating to Stamp Duties 693
17 & 18 Vict. c. 73.
An Act to amend the Acts for the Regulation of Joint Stock
Banks in Scotland 694
19 Vict. c. 3.
An Act to extend the Period for which her Majesty may grant
Letters Patent of Jncorporation to Joint Stock Banks in
Scotland existitig before the Act of 1846 695
III. Relating to Ireland exclusively.
55 Geo. 3, c. 100.
An Act to provide for the Collection and Management of Stamp
Duties jiayahle on Bills of Exchange, Promissory Notes,
Receipts and Game Certificates, in Ireland 696
1 & 2 Geo. 4, c. 72.
A71 Act to establish an Agreement %vith the Governor and Com-
pany of the Bank of Ireland for advancing the Sum of
500,000^. Irish Currency, and to empower the said Governor
and Company to enlarge the Capital Stock or Fund of the
said Bank to Three Millions 697
6 Geo. 4, c. 42.
Ail Act for the letter Regulation of Copartnerships of certain
Bankers in Ireland 698
9 Geo. 4, c. 80.
An Act to enable Bankers in Ireland to issue certain unstamped
Promissory Notes, upon Payment of a Composition in lieu
of the Stamp Duties thereon 710
9 Geo. 4, c. 81.
An Act for making Promissory Notes payable, issued by Banks,
Banking Companies or Bankers in Ireland, at the Places
xohere they are issued 716
574 ArPENDIX OF STATUTES.
11 Geo. 4 & 1 Will. 4, c. 32.
An Act to explain two Acts of his present Majesty for estahlish-
imj an Agreement ivith the Governor and Company of the
Bank of Ireland, for advancincj 500,000^. Irish Currency,
and for the better Regulation of Copartnerships of certain
Bankers in Ireland 717
5 & 6 Vict. c. 82.
An Act to assimilate the Stamp Duties in Great Britain and
Ireland, and to make Regulations for collecting and
managing the same, until the 10th day of October,
1845 725
8 & 9 YicT. c. 37.
A71 Act to regulate the issue of Bank Notes in Ireland, and to
regulate the Repayment of certain Sums advanced by the
Governor and Company of the Bank of Ireland for the
Public Service ". , 726
16 & 17 Vict. c. 59, s. 20.
An Act . . . to make pcrpetxial certain Stamp Duties in
Ireland 740
27 & 28 Vict. c. 86.
An Act to permit, for a limited Period, Compositions for
Stamp Duty on Bank Post Bills of 51. and upioards, in
Ireland 741
30 & 31 Vict. c. 89.
An Act to render perpetual an Act passed in the Session holden
in the 21th and 28th Years of her jyresent Majesty, intituled
"An Act to permit, for a limited Period, Compositions for
Stamp Duty on Bank Post Bills of 51. and ujncards in
Ireland^'' " 742
I. Eelating to England, Scotland and Ireland.
Restraining the Negotiation of Bills and Notes under a
Limited Sum.
17 Geo. 3, c. 30.
An Act for further restraining the N'egotiaiion of Promissory
Notes and Inland Bills of Exchange, under a limited Sum,
tvithin that part of Great Britain called England.
Preamble. AViiEREAs by a certain act of parliament, passed in the 15tlx
Act lo Geo. 3 year of the reign of his present Majesty (intituled "An Act
recited. to restrain the negotiation of promissory notes and inland bills
of exchange, under a limited sum, within that part of Groat
17 Geo. 3, c. 30. 575
Britain called England"), all negotiable promissory or other
notes, bills of exchange, or drafts, or uudertakiugs in waiting,
for any sum of money less tban the sum of 20s. in the whole,
and issued after the 24th day of June, 1775, were made void,
and the publishing or uttering and negotiating of any such
notes, bills, di-afts, or undertakings, for a less sum than 205.,
or on which less than that sum should be due, was, by the
said act, restrained under certain penalties or forfeitures
therein mentioned ; and all such notes, bills of exchange,
drafts, or undertakings in writing, as had issued before the
said 24th day of June, were made paj-able upon demand, and
were directed to be recovered in such manner as is therein
also mentioned : and whereas the said act hath been attended
with very salutary effects, and in case the provisions therein
contained were extended to a further sum (but yet without
j)rejudice to the convenience arising to the public from the
negotiation of promissory notes and inland bills of exchange
for the remittance of money in discharge of any balance of
account or other debt), the good purposes of the said act
woidd be fiu'ther advanced; be it therefore enacted, &c., that ^Ul negotiable
all promissory or other notes, bills of exchange, or drafts, or promissory
undertakings in writing, being negotiable or transferable, for ^? ' V^:
the payment of 205., or any sum of money above that sum thaiio^ -whToh
and less than 5^. ; or on which 20s., or above that sum and shall be issued
less than 5/., shall remain undischarged, and which shall be in England
issued, within that part of Great Britain called England, at ^ll^y ''^i'-^- ^»
any time after the 1st day of January, 1778, shall specif}^ the sip^jf^ +v,
names and places of abode of the persons respectively to names &c. of
whom, or to whose order, the same shall be made payable ; the persona
and shall bear date before or at the time of drawing or to whom
issuing thereof, and not on any day subsequent thereto ; and P^y^ol^.
shall be made payable within the space of 21 days next
after the day of the date thereof ; and shall not be transfer-
able or negotiable after the time thereby Hmited for payment
thereof ; and that every indorsement to be made thereon shall
be made before the expiration of that time, and to bear date
at or not before the time of making thereof ; and shall specify
the name and place of abode of the person or persons to
whom, or to whose order, the money contained in every such
note, bill, draft, or undertaking, is to be paid; and that the The signing
signing of every such note, bill, di'aft, or undertaking, and of every such
also of every such indorsement, shall be attested by one ^°**^ '^^^ l^'
• cioi'SGmGiiL to
subscribing witness at the least ; and which said notes, bills y^^ attested by
of exchange, or di-afts, or undertakings in writing, may be one witness,
made or drawn in words to the purport or etfect as set out in
the schedule hereunto annexed, Kos. I. and II. : and that all
promissory or other notes, bills of exchange, or drafts, or
undertakings in writing, being negotiable or transferable, for
576
APPENDIX OF STATUTES.
Penalty on
publishing or
negotiating
any such
notes, &c.
contrary to
the method
prescribed by
this act.
All negotiable
promissory
notes, &c.
between 20.9.
and ol. which
shall be issued
before Jan. 1,
1778, shall be
payable on
demand.
the payment of 20s., or any suna of money above that sum
and less than 51. ; or on which 20s., or above that sum and
less than 51., shall remain undischarged, and which shall be
issued within that part of Great Britain called England at
any time after the said 1st day of January, 1778, in any other
manner than as aforesaid ; and also every indorsement on any
such note, bill, draft, or undertaking, to be negotiated under
this act other than as aforesaid shall and the same are hereby
declared to be absolutely void ; any law, statute, usage, or
custom to the contrary thereof in anywise notwithstanding.
2. That the publishing, uttering, or negotiating, within
that part of Great Britain called England, of any promissory
or other note, bill of exchange, draft, or undertaking in
writing, being negotiable or transferable, for 20s., or above
that sum and less than 51., or on which 20s., or above that
sum and less than 51., shall remain undischarged, and issued
or made in any other manner than notes, bills, drafts, or
undertakings, hereby permitted to be published or negotiated
as aforesaid ; and also the negotiating of any such last-men-
tioned notes, bills, drafts, or undertakings, after the time
appointed for payment thereof, or before that time in any
other manner than as aforesaid, by any act, contrivance, or
means whatsoever, from and after the said 1st day of January,
1778, shall be, and the same is hereby declared to be, pro-
hibited or restrained, under the like penalties or forfeitures,
and to be recovered and applied in like manner as by the said
act is directed, with respect to the uttering or publishing or
negotiating of notes, bills of exchange, drafts, or imdertakings
in writing, for any sum of money not less than the simi of 20s.,
or on which less than that sum shoidd be due.
3. Tliat, from and immediately after the passing of this act,
all promissory or other notes, bills of exchange, drafts, or
undertakings in writing, for the payment of any greater sum
of money than 20s., and less than the sum of 51., or on which
20s. and less than the sum of 51., shall remain imdischarged,
and being negotiable or transferable, as shall be issued before
the said 1st day of January, 1778, shall be, and the same ai'o
hereby declared and adjudged payable, within that part of
Great Britain called England, on demand, any terms, restric-
tions, or conditions therein contained to tlio contrary thereof
notwithstanding ; and shall be recoverable in such manner, or
by the like means, as is or are directed in or by the said act
with respect to notes, bills of exchange, or drafts, or under-
takings in writing therein mentioned to have issued previous
to the said 24tli day of June, 1775; and tliat all and every
other the powers, provisoes, limitations, restrictions, penalties,
clauses, matters and things whatsoever in tlie said former act
contained with respect thereto, and also with respect to all
17 Geo. 3, c. 30. 577
sucli notes, bills of exeliange, drafts, or undertakings in
writing-, issued after the said 24tli day of June, 1775, shall
be, and the same are hereby declared to be in force, within
that part of Great Britain called England, as to all notes,
bills of exchange, or drafts, or undertakings in writing, for
20s., or any greater sum and less than the sum of -5/., or on
which 20s., or above that sum and less than 5/., shaU remain
undischarged, issued after the said 1st day of January, 1778,
and previous thereto respectively, and in like manner as if
the same respectively had been the object of the said act at
the time of making thereof, save so far as the same or any of
them are altered or varied b}' this present act.
4. Tliat the said former, and also this present act, shall Continuanpe
continue in force, not only for the residue of the term of five of this act
3'ears in the said former act mentioned, and from thence to Joj-Q^g/act (o).
the end of the then next session of parliament, but also for
the fiu'ther term of five years, and from thence to the end of
the then next session of parliament («).
SCHEDULE.
No. I.
[Place] Idciij'] [month'] [i/ear]
Twenty-one days after date, I promise to pay to A. B. of _
[jDlace] or his order, the sum of for value received by
Witness, E. F. C. D.
And the indorsement, toties quoties.
[Day] [month] [,'/f«^]
Pay the contents to G-. H. of [place^ or his order.
Witness, J. K. A. B.
No. II.
[Place] [day] [month] [year]
Twenty-one days after date, pay to A B. of [])lace]
or his order, the sum of value received, as advised by
To E. F. of [place:] . C. D.
Witness, G. H.
And the indorsement, toties quoties.
[Day] [month] [year]
Pay the contents to J. K. of [place'] or his order.
Witness, L. M. A. B.
(a) These acts were afterwards made pei-petual by 27 Geo. 3, c. IG.
The recited act of 15 Geo. 3, c. 51, was, however, repealed by 48 Geo. 3,
c. 88, s. 1. But by 26 & 27 Vict. c. 105, the 17 Geo. 3, c. 30, was^tem-
porarily repealed, and the repeal is continued by 36 k 37 Vict. c. 75, to
the 2Sth July, 1874. By 17 & IS Vict. c. 83, s. 9, these acts are not to
extend to cheques.
G. Pr
578
APPENDIX OF STATUTES.
No other
bank shall be
erected by
parliameut
during the
coutiuuance •
of the said
privilege, nor
shall any
niunber of
bankers in
partnership
exceeding six
be allowed.
Conditions of
redemption.
Ban]; of England Restriction Act.
39 & 40 Geo. 3, c. 28, s. 15.
An Act for establishinff an Agreement wilh the Governor and
Company of the Bank of England for advancing the Sum
of Three Millions towards the Sajij^ly for the Service of the
Year 1800 {a). [28tli March, 1800.]
15. And to prevent any doubts that may arise concerning
the privilege or power given, by former acts of parliament, to
the said governor and company, of exclusive banking, and
also in regard to the erecting any other bank or banks by
parliament, or restraining other persons from banking during
the continuance of the said privilege, granted to the Governor
and Company of the Bank of England as before recited, it is
hereby further enacted and declared, that it is the true intent
and meaning of this act, that no other bank shall be erected,
estabhshed or allowed by parliament ; and that it shall not be
lawful for any body, politic or corporate, whatsoever, erected
or to be erected, or for any other persons, united or to bo
united in covenants, or partnership, exceeding the number of
six persons in that part of Great Britain called England, to
borrow, owe, or take up any sum or sums of money on their
bills or notes, payable on demand, or at any less time than
six months from the borrowing thereof, during the continu-
ance of the said privilege to the said governor and company ;
who are hereby declared to be and remain a corporation, with
the privilege of exclusive banking, as before recited, subject
to redemption on the terms and conditions before mentioned ;
that is to say, on one year's notice to be given after the 1st
day of August, 1833, and repayment of the said sum of
3,200,000/., and all arrears of the said 100,000/. per anmun ;
and also upon repayment of the said sum of 8,486,800/., and
the interest or annuities payable thereon or in respect thereof,
and all the principal and interest money that shall be owing
on all such tallies, excheciuer orders, exchequer bills, parlia-
mentary funds, or other government securities, which the said
governor and company, or their successors, shall have remain-
ing in their hands, or be entitled to, at the time of such
notice to be given as aforesaid, and not otherwise, anything
in this act or any former act or acts of parliament to the con-
trary in anywise notwithstanding.
(«) By 34 & 3o Vict. c. IIG, the Statute Law Reviwon Act, 1871, the
■whole of this act, " except from the said Governor and Company of the
Bank of I'^ngland and their tucccssors for ever," in sect. 13 to the end of
the act, is rcp,< aled. Tlic above section (15) is therefore still in force.
48 aEO. 3, c. 88. 579
Hcsf raining Negotiation of Bills and Notes under a limited
Sum.
48 Geo. 3, c. 88.
An Act to restrain the Negotiation of Promissory Notes and
Inland Bills of Exchange, tinder a limited Sam, in
England (a). [23rd June, 1808.]
2. And be it furtlior enacted, that all promissory or otlier Promissory
notes, bills of exchange or drafts, or undertakings in Avritiug, ^j^^^^^.^^J ^*^®^
being negotiable or transferable for the payment of any sum ^^^^ " *"
or sums of money, or any orders, notes or undertakings in
writing, being negotiable or transferable for the delivery of
any goods, specifying their value in money, less than the sum
of 20s. in the whole, heretofore made or issued, or which shall
hereafter be made or issued, shall from and after the first
day of October, 1808, be and the same are hereby declared to
be absolutely void and of no effect.
3. That if any person or persons shall after the 1st day of Persons utter-
July, 1808, by any art, device, or means whatsoever, publish ™°bmg^fOT°^^^
or utter any such notes, bills, drafts, or engagements as afore- less thaii°20s.,
said, for a "less sum than 205., or on which less than thesum &c. shaU
of 20s. shall be due, and which shall be in anywise negotiable forfeit not
or transferable, or shall negotiate or transfer the same, every exceeding 201.
such person shall forfeit and pay, for every such offence, any ^^IJ^^l
sum not exceeding 20^., nor less than 5^., at the discretion of
the justice of the peace who shall hear and determine such
offence.
4. That it shall be lawful for any justice or justices of the Justices em-
peace, acting for the county, riding, city or place within which powered to
any offence against this act shall be committed, to hear and ^^^^^^.^5^6
determine the same in a summary way, at any time within offences,
twenty days after such offence shall have been committed ; and
such justice or justices, upon any information exhibited or
complaint made upon oath in that behalf, shall summon the
party accused, and also the witnesses on either side, and shall
examine into the matter of fact, and upon due proof made
thereof, either by the voluntary confession of the party or by
the oath of one or more credible witness or witnesses, or other-
wise (which oath such justice or justices is or are hereby
authorized to administer) shall convict the offender, and
adjudge the penalty for such offence.
(r/) By the Statute Law Revision Act, 1872 (No. 2) (35 & 3G Vict.
c. 97), sects. 1 and 11 arc repealed. By 2G & 27 Viet. c. 10.5, continued
by 3G & 37 Vict. c. 75, the act is repealed viutil 28th Ju'v, 1874. By
17 & 18 Vict. c. 83. s. 9, the act is not to extend to drafts on hankers.
p p 2
580
APPENDIX OF STATUTES.
Penalty on
witnesses not
attendina".
Form of con
\-iction.
5. That if any person shall be summoned as a witness to
o-ive evidence before such justice or justices, either on the
part of the prosecutor or the person accused, and shall neglect
or refuse to appear at the time or place to be for that purpose
appointed without a reasonable excuse for such his neglect or
refusal, to be allowed by such justice or justices, then such
person shall forfeit for every such offence the sum of 40*., to
be levied and paid in such manner and by such means as are
directed for recovery of other penalties under this act.
6. That the justice or justices, before whom any offender
shall be convicted as aforesaid, shall cause the said conviction
to be made out, in the manner and form following ; (that is to
" Be it remembered, that on the day of m the
year of our Lord A. B. having appeared before me l_or,
us] one [or more] of his Majesty's justices of the peace [as the
case may be] for the county, riding, city or place \_as the case
may be'] and due proof having been made upon oath by one or
more credible witness or witnesses, or by confession of the
party [fis the case may be] is convicted of \_specifying the
offence]. Given under my hand and seal [or, our hands and
seals] the day and year aforesaid."
Convictions to "Which conviction the said justice or justices shall cause to be
be returned to returned to the then next general quarter sessions of the peace
the quarter q£ ^q county, riding, city or place where such conviction was
sessions. n>ade, to be filed by the clerk of the peace, to remain and be
kept among the records of such county, riding, city or j^lace.
7. Provided always, that it shall be lawful for any clerk of
the peace for any count}', riding, city or place, and he is here-
by required, upon application made to him by any person or
persons for that purpose, to cause a copy or cojiies of any
conviction or convictions filed by him under the directions of
this act, to be forthwith delivered to such person or persons
upon payment of Is. for every such coj)y.
IIow penalties 8. That the pecuniary penalties and forfeitures hereby
shall be levied incurred and made payable upon any conviction against this
and applied, ^ct shall be forthwith paid by the person convicted, as follows ;
one moiety of the forfeiture to the informer, and the other
moiety to the poor of the parish or place where the offence
shall be committed : and in case such person shall refuse or
neglect to pay the same, or to give sufficient security to the
satisfaction of such justice or justices to prosecute any appeal
against such conviction, such justice or justices shall by warrant
under his or their hand and seal or liands and seals, cause the
same to l)e levied by distress and sale of the ort'ender's goods
and chattels, together with all costs and charges attending
such distress and sale, returning the overplus (if any) to the
owner ; and which said warrant of distress the said justice or
Oerks of the
peace to give
copies of con-
victions on
payment
of Is.
48 Geo. 3, c. 88. 581
justices shall cause to be made out in the manner and form
following ; (that is to say, )
" To the constable, headborough, or tythingman of . Form of tho
" Whereas A. B. of in the county of is this day J^™* °*
convicted before me [or, us] one [or more] of his Majesty's
justices of the peace [_as the case mat/ be'] for the county
of [or, for the riding of the county of York], or for
the town, liberty, or district of [«s the case mat/ be^ upon
the oath of or a credible witness or witnesses \_or,
by confession of the party, as the case mat/ be] for that the said
A. B. hath [Acre set forth the ajfence] contrary to the statute in
that case made and provided by reason whereof the said A. B.
hath forfeited the sum of to be distributed as herein is
mentioned, which he hath refused to pay : these are therefore,
in his Majesty's name, to command you to levy the said sum
of by distress of the goods and chattels of him the said
A. B., and if within the space of five days next after such
distress by you taken, the said sum. together with the reason-
able charges of taking the same, shall not be paid, then that
you do sell the said goods and chattels so by you distrained,
and out of the money ai'ising by such sale, that you do pay
one-half of the said sum of to of who infomied
me [or, us, as the case shall be] of the said offence, and the
other half of the said sum of to the overseer of the poor
of the parish, township or place where the offence was com-
mitted, to be employed for the benefit of such poor, returning
the overplus (if any) upon demand, to the said A. B. the
reasonable charges of taking, keeping, and selling the said
distress being first deducted ; and if sufficient distress cannot
be found of the goods and chattels of the said A. B. whereon
to levy the said sum of that then you certify the same
to me [or, us, as tJie case shall be] together with this warrant.
Given under my hand and seal [or, our hands and seals] the
day of in the year of our Lord ."
9. That it shall be lawful for such justice or justices to order Security may
such offender to be detained in safe custody until return may ^e *^^^^_JJ^^°^
conveniently be had and made to such warrant of distress, ^PP^^^^^
unless the party so convicted shall give sufficient secm-ity, to
the satisfaction of such justice or justices, for his appearance
before the said justice or justices on such day as shall be
appointed by the said justice or justices for the day of the
return of the said warrant or distress (such day not exceeding
five days from the taking of such security) ; which security the
said justice or justices is and are hereby empowered to take
by way of recognizance or otherwise.
10. That if upon such return no sufficient distress can be Offenders
had, then and in such case the said justice or justices shall may be com-
' mitted for
582
APPENDIX OF STATUTES.
•want of dis-
tress.
Convictions
not to be re-
moved.
General issue
may be
l)leaded.
and may commit such offender to the common gaol or house
of correction of the county, riding, division or place where the
offence shall be committed, for the space of three calendar
months, unless the money forfeited shall be sooner paid, or
unless or vmtil such off ender thinking him or herself aggrieved
by such conviction, shall give notice to the informer that he or
she intends to appeal to the justices of the peace at the next
general quarter sessions of the peace to be holden for the
county, riding or place wherein the offence shall be com-
mitted, and shall enter into recognizance before some justice
or justices, with two sufficient sureties conditioned to try
such appeal, and to abide the order of and pay such costs as
shall be awarded by the justices at such quarter sessions
(which notice of appeal, being not less than eiglit days before
the trial thereof, such person so aggrieved is hereby empowered
to give); and the said justices at such sessions, upon due proof
of such notice being given as aforesaid, and of the entering
into such recognizance, shall hear and finally determine the
causes and matters of such appeal in a summary way, and
award such costs to the parties appealing or appealed against
as they the said justices shall think proper; and the deter-
mination of such c[uarter session shall be final, binding, and
conclusive, to all intents and purposes.
12. Provided always, that no proceedings to bo had, touch-
ing the conviction or convictions of any oft'ender or offenders
against this act, shall be cjuashed for want of form, or be
removed by writ of certiorari, or any otlier writ or process
whatsoever, into any of his Majesty's Courts of Eecord at
Westminster.
13. That if any action or suit shall be commenced against
any person or persons for any thing done or acted in pur-
suance of this act, then and in every such case such action or
suit shall be commenced or prosecuted within three calendar
months after the fact committed, and not afterwards ; and the
same and every such action or suit shall be brought within
the county wliere tlie fact was committed, and not elsewhere ;
and the defendant or defendants in every such action or suit
shall and may plead the general issue, and give this act and
the S2:)ecial matter in evidence at any trial to be had thereupon,
and tliat the same was done in piu-suance and by the autho-
rity of this act ; and if the same shall appear to have been
so done, or if any sucli action or suit shall bo brouglit after
the time limited for l)ringing tlie same, or be brought or
laid in any other place than as aforementioned, then the jury
shall find for the defendant or defendants ; or if tlie plaintiff
or plaintiff's shall become nonsuit, or discontinue his, her, or
their action after the defendant or defendants shall havo
appeared, or if upon demurrer judgment shall bo given
55 Geo. 3, c. 184. 683
against the plaintiff or plaintiffs, tlio defoudant or defendants
shall and may recover treble costs (ordinary costs by 5 & 6
Vict. c. 97, s. 2). V J J
Issue of Bank Notes on unsfain^ml Fapcv and Bankers^
Licences.
55 Geo. 3, c. 184.
An Act for repealing the Stamp Duties o?i Deeds, Law Pro-
ceedings, and other written or printed histruments, &;c. (a).
[11th July, 1815.]
2. That there shall be raised, levied and paid unto and for Duties speci-
tho use of his Majesty, his heirs and successors, in and through- ^ed in schc-
out the whole of Groat Britain, for and in respect of the in- ing payment of such copartnership; and that such
copartnership and every member thereof, and the capital
stock and effects of such copartnership, and the effects of
every member of such copartnership, shall in all cases, not-
Qq2
59G APPENDIX OF STATUTES.
w-lfhstanding the bankruptcy, insolvency, or stopping payment
of any such, public officer, be attached and attachable, and bo
in all respects liable to the lawful claims and demands of the
creditor and creditors of such copartnership, or of any member
or members thereof, as if no such bankruptcy, insolvency, or
stopping payment of such public officer of such copartnership
had happened or taken place.
Execution 13. That execution upon any judgment in any action
upon judg- obtained against any public officer for the time being of any
mcut may be ^^^^^.j^ corporation or copartnership carrying on the business of
imy member banking under the provisions of this act, whether as plaintiff
of the copart- or defendant, may be issued against any member or members
nership. for the time being of such corporation or copartnership ; and
that in case any such execution against any member or
members for the time being of any such corporation or co-
partnership shall be ineffectual for obtaining payment and
satisfaction of the amount of such judgment, it shall be lawful
for the party or parties so having obtained judgment against
such public officer for the time being, to issue execution
against any person or persons who was or were a member or
members of sucli corporation or copartnership at the time
when the contract or contracts or engagement or engagements
in which such judgment may have been obtained was or were
entered into, or became a member at any time before such
contracts or engagements were executed, or was a member at
the time of the judgment obtained: provided always, that no
such execution as last mentioned shall be issued without leave
first granted, on motion in open court, by the court in which
such judgment shall have been obtained, and when motion
shall bo made on notice to the person or persons sought to be
charged, nor after the expiration of three years next after any
such person or persons shall have ceased to be a member or
members of such corporation or copartnership.
Officer, &c. in 14. Provided always, that every such public officer in whose
such cases name any such suit or action shall have been commenced,
lu emui cd. prosecuted, or defended, and every person or persons against
wliom execution upon any judgment obtained or entered up as
aforesaid in any such action shall be issued as aforesaid, shall
always be reimbursed and fully indomuiiied for all loss,
damages, costs, and charges, without deduction, which any
such officer or person may liave incurred by reason of such
execution, out of the funds of such copartnership, or in failure
thereof, by contribution from the other members of such co-
partnership, as in the ordinary cases of copartnership.
Governor aiid 15. And to prevent an}^ doubts that might ariso whether the
Company of g;a(i governor and company, under and by virtue of tlieir
F ^,ri "li ' - charter, and the several acts of parliament which have been
empower ' ' i^^^^c; and passed in relation to tlie aff'airs of the said governor
7 Geo. 4, c. 46. 597
and company, can lawfully carry on the trade or business of agents to
banking, otherwise than under the immediate order, manage- carry on
ment and direction of the court of directors of the said gover- ^-'^iitii^o busi-
nor and company ; be it therefore enacted, that it shall and pf;ice^in^°^
maj' be lawfiil for the said governor and company to authorize Eimhmd.
and empower an}' committee or committees, agent or agents,
to carr}' on the trade and business of banking, for and on be-
half of the said governor and company, at any place or places
in that part of the united kingdom called England, and for
that purpose to invest such committee or committees, agent or
agents, with such powers of management and superintendence,
and such authority to appoint cashiers and other officers and
servants as may be necessarj' or convenient for carrying on
such trade and business as aforesaid ; and for the same pur-
pose to issue to such committee or committees, agent or agents,
cashier or cashiers, or other officer or officers, servant or ser-
vants, cash, bills of exchange, bank post bills, bank notes,
jiromissory notes, and other securities for payment of money :
provided alwa3-s, that all such acts of the said governor and
company shall be done and exercised in such manner as may
be aj)pointed b}' any bj'e-laws, constitutions, orders, rules, and
directions, from time to time hereafter to be made by the
general court of the said governor and company in that behalf,
such bye-laws not being repugnant to the laws of that part of
the united kingdom called England : and in all cases where
such bye-laws, constitutions, orders, rules, or directions of the
said general court shall be wanting, in such manner as the
governor, deputy-governor, and directors, or the major part of
them assembled, whereof the said governor or deputy-governor
is always to be one, shall or may direct, such directions not
being repugnant to the laws of that part of the united kingdom
called England ; anything in the said charter or acts of parlia-
ment, or other law, usage, matter, or thing to the contrary
thereof notwithstanding : provided always, that in an}' place
"where the trade and business of banking shall be carried on
for and on behalf of the said governor and company of the
Bank of England, any promissory note issued on their account
in such place shall be made payable in coin in such place as
well as in London.
16. That if any cori:)oration or copartnership carrying on the Copartner-
trade or business of bankers under the authority of this act ?^^P^ ™^y
shall be desirous of issuing and re-issuing notes in the nature g^an^pe(j"
of bank notes, payable to the bearer on demand, without the notes, on
same being stamped as by law is required, it shall be lawful ghing bond.
for them so to do on giving security by bond to his Majesty,
his heirs and successors, in which bond two of the directors,
members, or partners of such corporation or copartnership,
shall be the obligors, together with the cashier or cashiers, or
598 APPENDIX OF STATUTES.
accountant or accountants employed by sucli corporation or co-
partnership, as tlio said commissioners of stamps shall require ;
and such bonds shall be taken in such reasonable sums as the
duties may amount unto during the period of one year, with
condition to deliver to the said commissioners of stamps, with-
in 14 days after the 5th day of January, the 5th day of April,
the 5th day of July, and the 10th day of October, in every
3' ear, whilst the present stamp duties shall remain in force, a
just and true account, verified upon the oaths or affirmations
of two directors, members, or partners of such corporation or
copartnership), and of the said cashier or cashiers, accountant
or accountants, or such of them as the said commissioners of
stamps shall require, such oaths or affirmations to be taken
before any justice of the peace, and which oaths and affirma-
tions any justice of the peace is hereby authorized and em-
j)owored to administer, of the amount or value of all their
promissory notes in circulation on some given day in every
week, for the space of one quarter of a year prior to the
quarter day immediately preceding the delivery of such
account, together with the average amount or value thereof
according to such account ; and also to pay or cause to be paid
into the hands of the receivers general of stamp duties in
Great Britain, as a composition for the duties which would
otherwise have been payable for such promissory notes issued
within the space of one year, the sum of 7s. for every 100/.,
and also for the fractional part of 100/. of the said average
amount or value of such notes in circulation, according to the
true intent and meaning of this act ; and on due performance
thereof such bond shall ])e void ; and it shall be lawful for the
said commissioners to fix the time or times of making such
payment, and to specify the same in the condition to every
such bond ; and every such bond may be required to bo re-
newed from time to time, at the discretion of the said commis-
sioners or the major part of them, and as often as the same
shall bo forfeited, or the i^arty or parties to the same, or any
of them, shall die, become bankrupt or insolvent, or reside in
parts beyond the seas.
No corpo- 17. Provided always, that no such cori-)oration or copartner-
ration com- ship shall be obliged to take out more than four licences for
m^f ^r,t^ ii *^^^ issuing of any promissory notes for money payable to the
out more than i '^ -, in t i ^ ,i k ^ "^ , . ■,■, „
four liceuccM. ^^aror on demand, allowed by law to be re-issued in all for
any number of towns or places in England ; and in case any
such corporation or copartnership shall issue such promissor^^
notes as aforesaid, by themselves or their agents, at more than
four different towns or places in England, then after. taking
out three distinct licences for three of sucli towns or places,
snch corporation or coparlnershij) shall be entitled to have all
the rest of such towns or places included in a fourth licence.
7 CIeo. 4, c. 46. 599
18. That if any sucli corporation or copartnorsliip cxceocling Penalty on co-
tli© number of six persons in England, sliall begin to issue partnership
any bills or notes, or to borrow, owe or take up any money on neglecting to
their bills or notes, without having caused such account or f^^^^ letums,
return as aforesaid to bo made out and deliver in the manner
and form directed by this act, or shall neglect or omit to cause
such account or return to be renewed yearly and every year
between the days or times hereinbefore appointed for that
purpose, such corporation or copartnership so offending shall,
for each and every week they shall so neglect to make such
account and return, forfeit 500/.; and if any secretary or other Penalties for
officer of such corporation or copartnership shall make out or making false
sign such false account or return, or any account or return ^"^ ^^n^-
which shall not truly set forth all the several particulars by
this act rec[uired to be contained or inserted in such account
or return, the corporation or copartnership to which such
secretary or other officer so offending shall belong shall for
every such offence forfeit the sum of 500/., and the said secre-
tary or other officer so offending shall also for every such
offence forfeit the sum of 100/. ; and if any such secretary or Raise oath
other officer making out or signing any such account or return pei'jmy.
as aforesaid, shall knowingly and wilfully make a false oath of
or concerning any of the matters to be therein specified and
set forth, every such secretary or other officer so offending and
being thereof lawfully convicted, shall be subject and liable
to such pains and penalties as by any law now in force per-
sons convicted of wilful and corrupt perjury are subject and
liable to.
19. That if any such corporation or copartnership exceeding Penalty on
the number of six persons, so carrying on the trade or busi- copartnership
noss of bankers as aforesaid, shall, either by any member of v/ti,^^^"\"?T
or person belonging to any such corporation or copartnership, ^^^ demand •
or by any agent or agents, or any other person or persons on
behalf of any such corporation or copartnership, issue or re-
issue in London, or at any place or places not exceeding the
distance of 65 miles from London, any bill or note of such
corporation or copartnership which shall be payable on de-
mand ; or shall draw upon any partner or agent or other or drawing
person or persons who may be resident in London, or at any ^"_ ^ °^ '^^'^
j)laee or places not exceeding the distance of Go miles from ai^i" on de- "
London, any bill of exchange which shall bo payable on de- mand, or for
mand, or which shall be for a less amount than fifty pounds ; less than 50/. ;
or if any such corporation or copartnership ex;ceeding the or horrowino-
number of six persons, so carrying on the trade or business of money on
bankers in England as aforesaid, or any member, agent or ^^^H except
agents of any such corporation or copartnership, shall borrow, "'^ \"i*^"i^
owe, or take up in London, or at any place or places not
exceeding the distance of 65 miles from London, any sum or
600
A^rE^•Inx of statutes.
Not to affect
the rights of
Bank of
Ed gland, ex-
cept as herein
(specially
altered.
Penalties,
how reco-
Tcred.
sums of money on any Lill or promissory note of any such
corporation or coj)artnersliip payable on demand, or at any
less time than six months from the borrowing thereof, or shall
make or issue any bill or bills of exchange or promissory note
or notes of such corporation or copartnership contrary to the
jirovisions of the said recited act of the 39th and 40th years of
King George the Third, save as pro\'ided by this act, such
corporation or copartnership so offending or on whose account
or behalf any such offence as aforesaid shall be committed,
shall for every such offence forfeit the sum of 50/.
20. Provided also, that nothing in this act contained shall
extend or be construed to extend to prejudice, alter, or affect
any of the rights, powers, or privileges of the said Governor
and Company of the Bank of England ; except as the said
exclusive privilege of the said governor and company is by
this act specially altered and varied.
21. I'hat all j^ccuniary penalties and forfeitures imposed by
this act shall and may be sued for and recovered iii his Majesty^ s
Court of Exchequer at Westminster, in the saine manner as
2)e7ialties inctirred wider any act or acts relating to stamp duties
may be sued for and recovered in such court. (Repealed by
36 & 37 Yict. c. 91.)
Certain
bankers may
issue un-
btumped pro-
Bank Notes and Bills Composition Stamp Dalies.
9 Geo. 4, c. 23.
An Act to enable Bankers in England to issue certain unstamped
Promissory Notes and Bills of Exchange, upon Payment of
a Comjwsition in lieu of the !Stamp Duties thereon {a).
[19th June, 1828. J
"WiiEEEAs it is expedient to permit all persons carrying on the
business of bankers in England (except within the city of
London or within three miles thereof), to issue their pro-
missory notes payable to bearer on demand, or to order within
a limited period after sight, and to draw bills of exchange
pa^-ablc to order on demand, or within a limited period after
sight or date, on unstamped paper, upon payment of a com-
position in lieu of the stamp duties which Avould otherwise be
payable upon such notes and bills respectively, and subject
to the regulations hereinafter mentioned ; be it therefore
enacted, &c., tliat from and after the 1st day of July, 1828, it
shall be laA\'ful for any person or persons carrying on the
('/) By the Statute Law Revision Act, 1873 (36 & 37 Vict. c. 91), sects.
16 and 17 are repealed.
9 Geo. 4, c. 23. 601
business of a banker or bankers in England (except witbin missory notes
the city of London, or within three miles thereof), having first and bills of
duly obtained a licence for that jnirpose, and given security exchange,
by bond in manner hereinafter mentioned, to issue, on iin- ^"J,^!^^; °„
stamped paper, promissory notes tor any sum of money herein men -
amounting to ol. or upwards, expressed to be payable to the tioned.
bearer on demand, or to order, at any period not exceeding
seven daj's after sight ; and also to draw and issue, on un-
stamped paper, bills of exchange, expressed to be payable to
order on demand, or at any period not exceeding seven days
after sight, or twenty-one days after the date thereof; pro-
vided such bills of exchange be drawn upon a person or per-
sons carrying on the business of a banker or bankers in
London, Westminster, or the borough of Southwark, or pro-
vided such bills of exchange be drawn by any banker or
bankers, at a town or place where he or they shall bo duly
licensed to issue unstamped notes and bills under the autho-
rity of this act, upon himself or themselves, or his or their
co-partner or co-partners, payable at any other town or place
where such banker or bankers shall also be duly licensed to
issue such notes and bills as aforesaid.
2. That it . shall be lawful for any two or more of the com- Commis-
missioners of stamps to grant to all persons carrying on the missioners of
business of bankers in England (except as aforesaid), who tra^tH^n^ces
shall require the same, licences authorizing such persons to ^q 'jgg^g ^^.
issue such promissory notes, and to draw and issue such bills stamped notes
of exchange as aforesaid, on unstamped paper ; which said and bills,
licences shall be and are hereby respectively charged with a
stamp duty of 30^. for every such licence.
3. That a separate licence shall be taken out in respect of A separate
every town or place where any such unstamped promissory licence to be
notes or bills of exchange as aforesaid shall be issued or *^^^° ^^'^
drawn : provided always, that no person or persons shall be ^^h^g^suoh
obliged to take out more than four licences in all for any notes or bills
number of towns or places in England ; and in case any sball bo
person or persons shall issue or draw such unstamped notes iss^^ed, but
or bills as aforesaid, at more than four different towns or fo^^^^^^^f^Je^^^
places, then, after taking out three distinct licences for three for any num-
of such towns or places, such person or persons shall be ber of "such
entitled to have all the rest of such towns or places included places.
in a fourth licence.
4. That every licence granted under the authority of this Regulations
act shall specify all the particulars required by law to be respecting
specified in licences to be taken out by persons issuing pro- 1^®^*^^^-
missory notes payable to bearer on demand, and allowed to
be re-issued ; and every such licence which shall be granted
between the lOtli day of October and the 11th day of Novem-
ber in any year shall be dated on the 11th day of October,
602
APPENDIX OF STATUTES.
Commis-
sioners may
cancel
licences
already taken
out, and
grant licences
under this act
in lieu
thei'eof.
Bankers while
licensed
imdcr this act
shall not
issue, for the
first time,
notes on
stamped
paper.
Bankers
licensed to
issue im-
stamped notes
or bills shall
give security
by bond, for
the due per-
fonnance of
the conditions
herein con-
tained.
and every sucTi licence wliicli shall be granted at any other
time shall bo dated on the day on which the same shall be
granted ; and every such licence shall (notwithstanding any
alteration which may take place in any copartnership of per-
sons to whom the same shall be granted) have effect and
continue in force from the day of the date thereof until the
10th day of October then next following, both inclusive, and
no longer.
5. Provided always, that where any banker or bankers
shall have obtained the licence required by law for issuing
promissory notes payable to bearer on demand, at any town
or place in England, and during the continuance of such
licence shall be desirous of taking out a licence to issue at the
same town or place unstamped promissory notes and bills of
exchange under the provisions of this act, it shall be lawful
for the commissioners of stamps to cancel and allow as spoiled
the stamp upon the said first-mentioned licence, and in lieu
thereof to grant to such banker or bankers a licence under the
authority of this act : and every such last-mentioned licence
shall also authorize the issuing and re-issuing of all promis-
sory notes payable to the bearer on demand, which such
banker or bankers may by law continue to issue or re-issue at
the same town or place, on paper duly stamped.
6. Provided always, that if any banker or bankers, who
shall take out a licence under the authority of this act, shall
issue, under the authority either of this or any other act, any
unstamped promissory notes for payment of money to the
bearer on demand, such banker or bankers shall, so long as
ho or they shall continue licensed as aforesaid, make and
issue on unstamped paper all his or their promissory notes for
payment of money to the bearer on demand, of whatever
amount such notes may be ; and it shall not bo lawful for
such banker or bankers, diiring the period aforesaid, to issue
for the first time any such promissory note as aforesaid on
stamped paper.
7. That before any licence shall bo granted to any person
or persons to issue or draw any unstamped promissory notes
or bills of exchange under the auth(n-ity of this act, such per-
son or persons shall give security, by bond, to his Majesty,
his heirs and successors, with a condition, that if such person
or persons do and shall from time to time enter or cause to bo
entered in a book or books to bo kept for that purpose, an
account of all such unstamped promissory notes and bills of
exchange as he or they shall so as aforesaid issue or draw,
specifying the amount or value thereof respectively, and the
several dates of the issuing thereof ; and in like manner also,
a similar account of all such promissory notes as having been
issued as aforesaid, shall havo been cancelled, and the dates
9 Geo. 4, c. 23. 603
of the cancelling thereof, and of all such bills of exchange as,
having been drawn or issued as aforesaid, shall have been
paid, and the dates of the payment thereof ; and do and shall
from time to time, when thereunto requested, produce and
show such accounts to, and permit the same to be examined
and inspected by, the said commissioners of stamps, or any
officer of stamps appointed under the hands and seals of the
said commissioners for that purpose ; and also do and shall
deliver to the said commissioners of stamps half-yearly, (that
is to say,) within fourteen daj's after the 1st day of January
and the 1st day of July in every year, a just and true account
in writing, verified upon the oaths or affirmations, (which any
justice of the peace is hereby empowered to administer,) to
the best of the knowledge and belief of such 2;)erson or per-
sons, and of his or their cashier, accountant, or chief clerk («),
or of such of them as the said commissioners shall require, of
the amount or value of all imstamped promissory notes and
bills of exchange, issued under the provisions of this or any
former act, in circulation vv'ithin the meaning of this act on a
given day, (that is to say,) on tSaturdaj' in every week, for
the space of half a year prior to the half-yearly day immedi-
ately preceding the delivery of such account, together with
the average amount or value of such notes and bills so in cir-
culation, according to such accoimt ; and also do and shall pay
or cause to bo paid to the receiver-general of stamp duties in
Grreat Britain, or to some other person duly authorized by the
commissioners of stamps to receive the same, as a composition
for the duties which would otherwise have been payable for
such promissory notes and bills of exchange issued or in cir-
culation during such half-year, the sum of three shillings and
sixpence for every one hundred pounds, and also for the frac-
tional part of one hundred pounds, of the said average amount
or value of such notes and bills in circulation, according to the
true intent and meaning of this act ; and on due performance
thereof such bond shall be void, but otherwise the same shall
be and remain in full force and virtue.
8. That every unstamped promissory note payable to the For -nhafc
bearer on demand, issued under the provisions of this act, period notes
shall, for the purpose of payment of duty, be deemed to be in ?^°t^ ^|^ ^^'K
circulation from the day of the issuing to the day of the can- ^^ circulation,
celling thereof, both days inclusive, excepting nevertheless
the period during which such note shall be in the hands of
the banker or bankers who first issued the same, or by whom
the same shall be expressed to be paj-able ; and that every
unstamped promissory note payable to order, and every un-
[a] The manager of tlio bank mav make the affidavdt. Hy. v. Green -
land, L. R., 1 C. C. Go ; 36 L. J., M. C. 37.
604
APPENDIX OF STATUTES.
Regulations
respecting the
bonds to bo
given pur-
suant to this
act.
Fresh bonds
to be given
on alterations
of copartner-
ships.
stamped bill of exchange so as aforesaid issued, shall, for the
purpose aforesaid, be deemed to be iu circulation from the day
of the issuing to the day of the payment thereof, both days
inclusive : provided always, that every such promissory note
payable to order, and bill of exchange as aforesaid, which
shall be paid in less than seven days from the issuing thereof,
shall, for the purpose aforesaid, be included in the account of
notes and bills in circulation on the Saturday next after the
day of the issuing thereof as if the same were then actually in
circulation.
9. That in every bond to be given pursuant to the directions
of this act the person or persons intending to issue or draw any
such unstamped promissory notes and bills of exchange as
aforesaid, or such and so many of the said persons as the
commissioners of stamps shall require, shall be the obligors ;
and every such bond shall be taken in the sum of one hundred
pounds, or in such larger sum as the said commissioners of
stamps may judge to be the probable amount of the composi-
tion or duties that will be payable from such person or persons,
under or by virtue of this act, during the period of one year ;
and it shall be lawful for the said commissioners to fix the
time or times of payment of the said composition or duties,
and to specify the same in the condition to every such bond ;
and every such bond may be required to be renewed from
time to time, at the discretion of the said commissioners, and
as often as the same shall be forfeited, or the parties to the
same, or any of them, shall die, become bankrupt or insolvent,
or reside in parts beyond the seas.
10. That if any alteration shall be made in any copartner-
ship of persons who shall have given any such security by
bond as by this act is directed, whether such alteration shall
be caused by the death or retirement of one or more of the
partners of "the firm, or by the accession of any additional or
new partner or partners, a fresh bond shall bo given by the
remaining partner or partners, or the persons composing the
new copartnership, as the case may be, which bond shall bo
taken as a security for the duties which may be due and owing,
or may become duo and owing, in respect of the unstamped
notes and bills which shall have been issued by the person?,
composing the old copartnership, and which shall be in cir-
culation at the time of such alteration, as well as for duties
which shall or may be or become due or owing in respect of
the unstamped notes and bills issued or_ to be issued by the
persons composing the new copartnership ; provided that no
such fresh bond shall be rendered necessary by any such
alteration as aforesaid in any copartnership of persons ex-
ceeding six in number, but that the bonds to be given by such
last-mentioned copartnerships shall be taken as securities for
9 Geo. 4, c. 23. 605
all the duties they may incur so long as they shall exist, or
the i^ersons composing the same, or any of them, shall carry
on business in copartnership together, or with any other
person or persons, notwithstanding any alteration in such
copartnership ; saving always the power of the said commis-
sioners of stamp»s to require a new bond in any case where
they shall deem it necessary for better securing the payment
of the said duties.
11. That if any person or persons who shall have given Penalty on
security, by bond, to his Majesty, in the manner hereinbefore tankers
directed, shall refuse or neglect to renew such bond when for- ^^o^ecting to
feited, and as often as the same is by this act required to be bonds,
renewed, such person or persons so offending shall, for every
such offence, forfeit and pay the sum of 100/.
12. That if any person or persons who shall be liceiised Penalty for
under the provisions of this act shall draw or issue, or cause postdating
to be drawn or issued, upon unstamped jiaper, any promis- u^j'tamped
sory note payable to order, or any bill of exchange Aviiich shall
bear date subsequent to the day on which it shall bo issued,
the person or persons so offending shall, for every such note
or bill so drawn or issued, forfeit the sum of 100/.
13. That nothing in this act contained shall extend, or be This act not
construed to extend, to exempt or relieve from the forfeitures ^° exempt
or penalties imposed by any act or acts now in force, upon Jerany per-
persons issuing promissory notes or bills of exchange not duly sons issuing
stamped as the law requires, any jijcrson or persons who, under unstamped
any colour or pretence Avhatsoever, shall issue any unstamped "otes or bills
j)romissory note or bill of exchange, unless such person or ^^o* ^'^''^''cord-
persons shall be duly licensed to issue such note or bill under ^ith.
the provisions of this act ; and such note or bill shall be drawn
and issued in strict accordance with the regulations and re-
strictions herein contained.
14. That all pecuniary forfeitures and penalties which may Recovery of
be incurred under any of the provisions of this act shall be penalties,
recovered for the use of liis Majesty, his heirs and successors,
in his Majesty's Court of Exchecjuer at Westminster, by action
of debt, bill, plaint or information, in the name of his Majesty's
attorney or solicitor general in England.
15. Provided always, that nothing in this act contained shall ^ot to affect
extend, or be construed to extend to prejudice, alter or aifect * 'l^"^^^^?.^^
any of the riglits, powers or privileges of the Grovernor and ^f Eno-land.
Company of the Bank of England.
16. [Where any bankers taking out licences under this act
shall have stamps in their possession which will become use-
less, the commissioners may cancel such stamps, and make
allowance for the same, if application be made within six
calendar months next after the passing of the act.]
606 APPENDIX OF STATUTES.
Restraining Negotiation of Notes under 51.
9 Geo. 4, c. 65.
An Act to restrain the Negotiation, in England, of Promissori/
Notes and Bills under a limited Sum, issued in Scotland or
Ireland. [lotli July, 1828.]
Whereas an act was passed in the 7th year of his present
7 Geo. 4, c. G. Majesty's reign, intituled " An Act to limit, and after a certain
period to prohibit, the issuing of promissory notes under a
limited sum in Eugland;" and doubts may arise how far the
provisions of the said act may be effectual to restrain the cir-
culating in England of certain notes, drafts, or undertakings
After 5th made or issued in Scotland or Ireland : be it therefore enacted,
A^jril, 1829, ^^.^ that if any body politic or corporate, or person or per-
no corpora- ^ gj^^^U ^^^^^, ^^^ ^^j^ j ^^ * .-, jg29, by any art,
tiou or person ,.' ' ,, -^ iti,, "^ ,• ,
shall utter in tievice, or means whatsoever, publish, utter, negotiate, or
England transfer, in any part of England, any promissory or other
notes or bills note, draft, engagement, or undertahing in writing, made
"T^T h' r pfiyable on demand to the bearer thereof, and being negotiable
been made or ^^ transferable, for the payment of any sum of money less
issued in than bl., or on which less than the sum of bl. shall remain
Scotland or undischarged, which shall have been made or issued, or shall
Ireland, purport to have been made or issued, in Scotland or Ireland,
Ton/ "^^ '^^ or elsewhere out of England, wheresoever the same shall or
may be payable, every such body politic or corjiorate, or person
or persons, so publishing, uttering, negotiating, or transferring
any such note, bill, draft, engagement, or undertaking, in any
part of England, shall forfeit and pay for every such offence
any sum not exceeding 2Ql. nor loss than bl., at the discretion
of the justice of the peace who shall hear and determine such
offence.
Mode of 2. That the penalties which may be incurred under the pro-
recovering visions of this act shall and may bo recovered in a summary
pcua les. Avay, by information on complaint, before a justice or justices
of the peace, and shall be levied and applied in the manner
directed by an act passed in the 48th year of the reign of his
48 Geo. 3, late Majesty King George the Third, intituled " An Act to
^- ^^- restrain the negotiation of promissory notes and inland bills
of exchange under a limited sum in England," with respect to
the penalties by the said last-mentioned act imposed ; and all
and every the clauses and provisions in the said last-mentioned
act contained, relating to the recovery and ajtplication of the
penalties thereby imposed, shall be applied and i)ut in exe-
cution for tho recovery and application of the penalties by this
act imposed, as fully and eifectually, to all intents and pur-
poses, as if such clauses and provisions had been heroin
repeated and expressly re-enacted.
3 & 4 Will. 4, c. 83. 607
3. Provided always, that it sliall and may be lawful for the The Treasmy
lord high treasurer, or for the eommiosioners of his Majesty's may order a
Treasury, or any three or more of them, to order and direct ^^l^'^^^'^o^^of
that the whole or any part of any penalty which shall be penalties.
incui-red under this act shall and may be remitted, or mitigated
or abated to such amount, and in such manner and upon such
conditions as to such lord high treasurer or commissioners of
the Treasury may seem fit and proper.
4. Provided always, that nothing herein contained shall Not to extend
extend to any draft or order drawn by any person or persons |o drafts on
on his, her, or their banker or bankers, for the payment of the uscfof°tlie
money held by such banker or bankers, person or persons, to drawer.
the use of the person or persons by whom such draft or order
shall be drawn.
Meturns of Bank Notes in Circulation.
3 & 4 Will. 4, c. 83.
An Act to compel Banks issuing Promisson/ Notes 2)ai/able to
Bearer on Demand to make Returns of their Notes in Circu-
lation, and to authorize Banks to issue Notes iJuyaMe in
London for less than 501. (a). [28th August, 1833.]
Whereas it is expedient that all corporations, copartnerships,
and persons carrying on banking business, and making and
issuing promissory notes payable to bearer on demand, should
make returns of the amount of such notes in circulation : be
it therefore enacted, &c., that all corporations and copartner- Partnerships
ships cari'ying on banking business under the provisions of an and persons
act passed in the 7th year of the reign of his late Majesty carrying on _
King George the Fourth, chapter 4G, intituled " An Act for nejfand^''^'"
the better regulating copartnerships of certain bankers in jssuin"- pro-
England" [setting forth the title of that act, ante, p. 588], as missory notes
relates to the same, and all other persons carrying on banking to keep
business, and making and issuing promissory notes payable to ff counts of _
bearer on demand, shall resi)ectivoly keep weekly accounts circuktTon ^^
from the passing of this act of the average amount of notes and make
in circulation at the end of each week of the corporation, co- periodical
partnership, or persons or person so carrying on banking returns there-
business and keeping such weekly account; and shall, within ^^°°^ to the
one month after the 31st day of December after the passing in^L^ndonT
of this act, make up from such weekly account an average
{a) Sects. 1 and 3 repealed by Statute Law Revision Act, 1874.
608
APPENDIX OF STATUTES.
Sucli returns
to be verified
ou oath.
Penalty for
default, oOO/.
False swear-
ing punished
as perjury.
Banks of
more than six
persons may
draw ou agent
in London, on
demand or
otherwise, for
less than 50/.,
notwithstand-
ing the Act
7 Geo. 4,
c. 46.
account of the amount of such, notes in circulation during the
period between the passing of this act and the mahiug up such
account ; and shall also make up a like account at the end of
each quarter ending on the 1st day of April, the 1st day of
July, the 1st day of October, and the 1st day of January in
the year 1834, and every subsequent year, of the average
amount of notes in circulation in the preceding quarter, and
shall return and deliver such account to the commissioners of
stamps at the stamp office in Loudon ; and such accounts and
returns shall be verified ujDon the oath of the secretary or
accountant or some officer of the corporation, company, or co-
l^artnershij:), or persons or person so carrying on banking
business and making such return, which oath shall be taken
before any justice of the peace, and which oath any justice of
the peace is hereby authorized to administer ; and if any cor-
poration, company, or copartnership, or persons or person so
carrying on banking business, shall neglect to keep such
weekly accounts, or to make out or to return or deliver such
averages to the commissioners of stamps at the stamp office in
London, or if any secretary, accountant, or other person veri-
fying any such account or average shall return or deliver to
the commissioners of stamps any false account or return of
such averages, the corporation, company, or copartnership, or
persons or person to whom any such account or averages, or
such secretary, accountant, or person verifying the account,
shall belong, shall forfeit for every such offence the sum of
500^., and the secretary or other person so offending shall also
forfeit for every such offence the sum of 100^. ; and any secre-
tary, accountant, or other person who shall knowingly and
wilfully take any false oath as to any such account or averages
shall be subject to such pains and i^enalties as are by any law
in force at the time of taking such oath enacted as to persons
convicted of wilful and corrupt perjury.
2. That it shall be lawful for any body politic or corporate
whatsoever, erected or to be erected, and for any other persons
xmited or to be united in covenants or partnership, exceeding
the number of six persons, carrying on business as bankers,
to make any bill of exchange or promissoiy note of such cor-
poration or copartnership payable in London by any agent of
sueli corporation or copartnership in London, or to draw any
bill of exchange or promissory note xipon any such agent in
London, pa^^able ou demand or otherwise in London, and for
any less amount than 501., any thing in the said recited act of
the 7th year of the reign of his late jNIajesty King George the
I'ourth, or in any other act, to the contrary notwithstanding.
3 & 4 Will. 4, c. 98. 609
The Bank of England Privileges Act, 1833.
3 & 4 Will. 4, c. 98.
An Act for giving to the Corporation of the Governor and Com-
pany of the Bank cf England certain Privileges for a limited
Period, under certain Conditions. [29tli August, 1833.]
Whereas an act -svas passed in the 39tli and 40tli years of the
reign of his Majesty King Greorge the Third, intituled "An 39 & 40
Act for establishing an agreement with the Grovernor and G-eo. 3, c. 2S.
Company of the Bank of England for advancing three mil-
lions towards the supply for the service of the year 1800:"
and whereas it was by the recited act declared and enacted,
that the said governor and company should be and continue
a corporation, with such powers, authorities, emoluments,
profits, and advantages, and such privileges of exclusive bank-
ing, as are in the said recited act specified, subject nevertheless
to the powers and conditions of redemption, and on the terras
in the said act mentioned : and whereas an act passed in the
7th year of the reign of his late Majesty Iving Cleorge the
Fourth, chapter 46, intituled "An Act for the better regu- 7 Geo. 4,
lating copartnerships of certain bankers in England" [setting c- 46.
out the title of the act, ante, p. 588], as relates to the sarne :
and whereas it is expedient that certain privileges of exclusive
banking should be continued to the said governor and com-
j)any for a further limited period, upon certain conditions:
and Avhereas the said Governor and Company of the Bank of
England are willing to deduct and allow to the public, from
the sums now payable to the said governor and company for
the charges of management of the public unredeemed debt,
the annual sum hereinafter mentioned, and for the period in
this act specified, provided the privilege of exclusive banking
specified in this act is continued to the said governor and com-
pany for the period specified in this act : may it_ therefore
please your Majesty that it maybe enacted; and be it enacted,
&c., that the said Governor and Company of the Bank of Bank of Eng-
England shall have and enjoy such exclusive privilege of land to enjoy
banking as is given by this act, as a body corporate, for the p^-^jj^i^^^^
period and upon the terms and conditions hereinafter men- {janking upon
tioned, and subject to termination of such exclusive privilege certain'oon-
at the time and in the manner in this act specified. _ _ ditions.
2. That during the continuance of the said privilege, no During such
body politic or corporate, and no society or company, or per- privilege, no
sons united or to be united in covenants or partnerships, ex- ^!JJJ "f jJJ°™'
ceeding six persons, shall make or issue in London, or within 1'^,^^ Tix^per-
65 miles thereof, any bill of exchange or promissory note, or go^s to issue
engagement for the payment of money on demand, or upon notes ijayable
which any person holding the same may obtain payment on on demand
G. R K
610
APPENDIX OF STATU'lES.
witliin Lon-
don, or 65
miles thereof.
Any company
or partner-
ship may
carry on busi-
ness of bank-
ing- in Lon-
don, or within
60 miles
thereof, upon
the terms
herein men-
tioned.
All notes of
the IJank of
England pay-
able on de-
mand which
shall ho issued
out of Lon-
don shall bo
payable at tlic
demand : provided always, that notliing herein or in the said
recited act of the 7th year of the reign of his late Majesty
Iviug George the Fourth contained shall be construed to pre-
vent any body politic or corporate, or any society or company,
or incorporated company or corporation, or copartnership,
carrying on and transacting banking business at any greater
distance than 65 miles from London, and not having any
house of business or establishment as bankers in London, or
within 6.5 miles thereof (except as hereinafter mentioned), to
make and issue their bills and notes, payable on demand or
otherwise, at the place at which the same shall be issued,
being more than 65 miles from London, and also in London,
and to have an agent or agents in London, or at any other
place at which such bills or notes shall be made payable for
the purpose of payment only, but no such bill or note shall be
for any sum less than 5^., or be re-issued in London, or within
65 miles thereof.
3. A]id whereas the intention of this act is, that the Governor
and Company of the Bank of England should, during the
period stated in this act (subject nevertheless to such redemp-
tion as is described in this act), continue to hold and enjoy all
the exclusive privileges of banking given by the said recited
act of the 39th and 46th years of the reign of "his Majesty King
George the Third aforesaid, as regulated by the said recited
act of the seventh year of his late IMajesty Iving George the
Fourth, or any prior or subsequent act or acts of parliament,
but no other or further exclusive privilege of banking : and
whereas doubts have arisen as to the construction of the said
acts, and as to the extent of such exclusive privilege ; and it
is expedient that all such doubts should be removed, be it
therefore declared and enacted, that any body politic or cor-
porate, or society, or company, or partnership, although con-
sisting of more than six persons, may carry on the trade or
business of banking in London, or within 65 miles thereof,
provided that such body politic or corporate, or society, or
company, or partnership do not borrow, owe, or take up in
England any sum or sums of money on their biUs or notes
payable on demand, or at any less time than six montlis from
the borrowing thereof, during the continuance of the privileges
granted by this act to the said Governor and Company of the
]5ank of England.
4. Provided always, and be it further enacted, that from
and after the 1st day of August, 1834, all jn-omissory notes
payable on demand of the Governor and Company of the
13ank of England which sluill be issued at any place in that
part of tlie United Kingdom called England out of London,
where the trade and business of banking shall be carried on
for and on behalf of the said Governor and Company of tlxo
3 & 4 Will. 4, c. 98. 611
Bank of England, shall be made payable at the place where pbico where
such promissory notes shall bo issued; and it shall not bo issued, iSic.
lawful for the said governor and company, or any committee,
agent, cashier, officer, or servant of the said governor and
company, to issue, at any such place out of London, any pro-
missory note payable on demand which shall not be mado
payable at the place where the same shall be issued, anything
in the said recited act of the seventh year aforesaid to the
contrary notwithstanding.
5. That upon one year's notice given within six months Exclusive
after the expiration of ten years from the 1st day of August, privileges
1834, and upon repayment by parliament to the said governor ht-^'eljy given
and company, or their successors, of all principal money, Qj^g ye^.^^°"
interest, or annuities which may be due from the public to notice o-ivcn
the said governor and company at the time of the expiration at the end of
of such notice, in like manner as is hereinafter stipulated and ten years
provided, in the event of such notice being deferred until after ^^^^J August,
the 1st day of August, 1855, the said exclusive privileges of
banking granted by this act shall cease and determine at the
expiration of such year's notice ; and any vote or resolution What shall
of the House of Commons, signified by the speaker of the said be deemed
house in writing, and delivered at the public office of the said sufficient
governor and company, or their successors, shall be deemed
and adjudged to be a sufficient notice («).
6. That from and after the 1st day of August, 1834, unless Banknotes to
and until parliament shall otherwise direct, a tender of a note ^^ ^ ^y^^
or notes of the Governor and Company of the Bank of Eng- jjt^^^e'banif^'
land, expressed to be payable to bearer on demand, shall be a and branch
legal tender, to the amount expressed in such note or notes, banks.
and shall be taken to be valid as a tender to such amount for
all sums above 51. on all occasions on which any tender of
money may be legally made, so long as the Bank of England
shall continue to pay on demand their said notes in legal coin :
provided always, that no such note or notes shall be deemed a
legal tender of pajonent by the Governor and Company of the
Bank of England, or any branch bank of the said governor
and company ; but the said governor and company are not to
become liable or be required to pay and satisfy, at any branch
bank of the said governor and company, any note or notes of
the said governor and company not made specially payable at
such branch bank ; but the said governor and company shall
be liable to pay and satisfy at the Bank of England in London
all notes of the said governor and company, or of any branch
thereof.
(«) Repealed by Statute Law Revision Act, 187-i.
R R 2
612
APPENDIX OF STATUTES.
Accounts of
bullion, &c.
unci of notes
in circulation
to be sent
Aveekly to the
chancellor of
the ex-
chequer, (S:c.
Public to pay
the bank one
fourth part of
the debt of
U,G86,800/.
Capital stock
of the bank
may bo
reduced.
7 (b). [Bills not having more than three months to run, not
suhject to usury laws.]
8. That an account of the amount of hullion and securities
in the Bank of England belonging to the said governor and
company, and of notes in circulation, and of deposits in the
said Lank, shall be transmitted weekly to the chancellor of the
exchequer for the time being, and such accounts shall be con-
solidated at the end of every month, and an average state of
the bank accounts of the preceding three months, made from
such consolidated accounts as aforesaid, shall be published
every month in the next succeeding London Gazette.
(c) 9. Tliat one fourth part of the debt of 14,G8G,800^., now
due from the public to the Governor and Company of the
Bank of England, shall and may be repaid to the said
governor and company.
(c) 10. That a general court of proprietors of the said
Governor and Company of the Bank of England shall be held
at some time between the passing of this act and the 5th day of
October, 1834, to determine upon the propriety of dividing and
ajDpropriating the sum of 3,638,2oOl^., out of or by means of
the sum to be repaid to the said governor and company
as hereinbefore mentioned, or out of or by means of the
fund to be provided for that purpose, amongst the several
persons, bodies politic or corporate, who may be proprietors
of the capital stock of the said governor and company on the
said 5th day of October, 1834, and upon the manner and the
time for making such division and appropriation not incon-
sistent with the provisions for that piu"pose herein contained ;
and in case such general court, or any adjourned general
court, shall determine tliat it will be proper to make such
division, then, but not otherwise, the capital stock of the said
governor and company shall be and the same is hereby de-
clared to be reduced from the sum of 14,553,000/., of which
the same now consists, to the sum of 10,914,750/., making a
reduction or difference of 3,038,250/. capital stock, and such
reduction shall take place from and after the said 5th day of
October, 1834 ; and thereupon, out of or by means of the sum
to be repaid to the said governor and company as hereinbefore
mentioned, or out of or by means of the fund to be provided
for that purpose, the simi of 3,638,250/. sterhng, or such pro-
portion of the said fund as shall represent the same, sliall be
apjDropriated and divided amongst the several persons, bodies
politic or corporate, who may be projirietors of the said sum
of 14,553,000/. bank stock on the said 5th day of October,
{l>) Repealed by the Statute Law Ecvision Act, 18G1 (21 & 25 Vict.
c. 101).
{r) Sects. 9—13 repealed by Statute Law Revision Act, 1874.
3 Si 4: Will. 4, c. 98. 613
1834, at the rate of 2.5/. sterling for every 100/. of bank stock
•which such persons, bodies politic and corporate, may then bo
proprietors of or shall have standing in their respective names
in the books kept by the said governor and company for the
entry and transfer of such stock, and so in proportion for a
greater or lesser sum.
(c) 11. That the reduction of the share of each proprietor of Governor,
and in the capital stock of the said Governor and Company of clep^ity
the Bank of England, by the repayment of such one fourth f^pcctors not
part thereof, shall not disqualify the present governor, deputy to be dis-
governor, or directors, or any or cither of them, or any qualified In'
governor, deputy governor, or director who may be chosen in reduction of
the room of the present governor, deputy governor, or direc- J^^g'^jf'^^l °
tors at any time before the general court of the said governor gtock.
and company to be held between the 2-jth day of March and
the 25th day of April, 1835 : provided that at the said general
court, and from and after the same, no governor, deputy
governor, or director of the said corporation shall be capable
of being chosen such governor, deputy governor, or director,
or shall continue in his or their respective offices, unless he or
they respectively shall at the time of such choice have, and
during such his respective office continue to have, in his and
their respective name, in his and their own right, and for his
and their own use, the respective sums or shares of and in the
capital stock of the said corporation in and by the charter of
the said governor and company prescribed as the qualification
of governor, deputy governor, and directors respectively.
(c) 12. That no proprietor shall be disqualified from attending Proprietors
and voting at any general court of the said governor and com- not to be dis-
pany to be held between the said 5th day of October, 1834, q^^alihed.
and the 25th day of April, 1835, in consequence of the share
of such proprietor of and in the capital stock of the said
governor and company having been reduced by such repay-
ment as aforesaid below the sum of 500/. of and in the said
capital stock ; provided such proprietor had in his own name
the full sum of 500/. of and in the said capital stock on the said
5th day of October, 1834; nor shall any proprietor be re-
quired, between the said 5th day of October, 1834, and the
25th day of April, 1835, to take the oath of qualification in
the said charter.
(c)13. That from and after the said 1st day of August, 1834, ^auk to
the said governor and company, in consideration of the privi- '^f^^^^^^^ ^^^
leges of exclusive banking given by this act, shall, during the '^^ 120,000^
continuance of such privileges, but no longer, deduct from the ivom sum
sums now payable to the said governor and company, for the aUowed for
charges of management of the public unredeemed debt, the ^^J^g^^^^j'^*
" debt.
{(■) See last note.
614
APPENDIX OF STATUTES.
remain in
force, except
as altered by
this act.
annual sum of 120,000/., anything in that act or acts of par-
liament or agreement to the contrary not-^ithstanding : pro-
vided always, that such deduction shall in no respect prejudice
or affect the right of the said governor and company to be paid
for the management of the public debt at the rate and accord-
ing to the terms provided in an act passed in the 48th year of
48Geo. 3, c. 4. his late Majesty King George the Third, intituled "An Act
to authorize the advancing for the public service, upon certain
conditions, a proportion of the balance remaining in the Bank
of England for payment of unclaimed dividends, annuities,
and lottery prizes, and for regulating the allowances to be
made for the management of the national debt."
Provisions of 14. That all the powers, authorities, franchises, privileges,
act of 39 & 40 and advantages given or recognized by the said recited act of
Geo. 3, to ^]^Q 39th and 40tli years aforesaid, as belonging to or enjoyed
by the Governor and Company of the Bank of England, or
by any subsequent act or acts of parliament, shall be, and the
same are hereby declared to be. in full force and continued by
this act, except so far as the same are altered by this act, sub-
ject nevertheless to such redemption upon the terms and con-
ditions following ; (that is to say), that at any time, upon
twelve months' notice to be given after the 1st day of August,
1855, and upon repayment by parliament to the said governor
and company, or their successors, of the sum of 11,015,100/.,
being the debt which will remain due from the public to the
said governor and company after the payment of the one
fourth of the debt of 14,686,800/., as hereinbefore provided,
without any deduction, discount, or abatement whatsoever,
and upon payment to the said governor and company and
their successors of all arrears of the sum of 100,000/. per
annum in the said act of the thirty-ninth and fortieth years
aforesaid mentioned, together with the interest or annuities
payable upon the said debt or in respect thereof, and also upon
repayment of all the principal and interest which shall be
owing unto the said governor and company and their succes-
sors upon all such tallies, exchequer orders, exchequer bills,
or parliamentary funds which the said governor and company
or their successors shall have remaining in their hands or be
entitled to at the time of such notice to be given as last afore-
said, then and in such case, and not till then (unless under the
proviso hereinbefore contained), the said exclusive privileges
of banking granted by this act shall cease and determine at
the expiration of such notice of twelve months.
1 & 2 Vict. c. 9G. 615
Legal Procedure by Joint Stock Baiikii.
1 & 2 YicT. c. 96.
An Act to amend, until the end of the next Session of Parlia-
ment, the Law relative to Legal Proceedings hxj certain Joint
Stock Banking Companies against their own Members, and by
such Members against the Companies.
[14th August, 1838.]
Whereas by an act passed in the 7th year of the reign of his
late Majesty King Cfeorge the Fourth, chapter 46, intituled
"An Act for the better regulating copartnerships of certain 7 Geo. 4, c. 46.
bankers in England" [setting forth the title of the act, ante,
p. 588], as relates to the same, it was amongst other things
enacted, that it should be lawful for any body politic or cor-
porate erected for the purposes of banking, or for any number
of persons united in covenants or copartnerships, although
such persons so united or carrying on business together
should consist of more than six in mimber, to carry on (sub-
ject to certain provisions therein contained) the trade or
business of bankers in England, in like manner as copart-
nerships of bankers consisting of not more than six persons
in number might lawfully do •, and it was further enacted,
that aU actions and suits against any persons who might be
at any time indebted to any such copartnership carrying on
business under the provisions of the said act, and all other
proceedings at laAV and in equity to be instituted on behalf
of any such copartnership against any persons, bodies poHtic
or corporate, or others, whether members of such copartner-
ship or otherwise, for recovering any debts or enforcing
any claims or demands due to such copartnership, or for
any other matter relating to the concerns of such copartner-
ship, might be commenced and prosecuted in the name of any
one of the public officers for the time being of such copartner-
ship, to be nominated as therein is mentioned, as the nominal
party on behalf of such copartnership, and that actions or
suits, and proceedings at law or in equity, to be instituted by
any persons, bodies politic or corporate, or others, whether
members of such copartnership or otherwise, against such
copartnership, should be commenced and prosecuted against
any one or more of the public officers for the time being of
such copartnership as the nominal defendant on behalf of
such copartnership, and that the death, resignation, removal,
or any act of such public officer should not abate or prejudice
any such action, suit, or other proceeding commenced against
or on behalf of such copartnership, but that the same might
be continued in the name of any other of the public officers
of such copartnership for the time being : and whereas an act
616
APPENDIX OF STATUTES.
Banking co-
partnerships
may sue and
be sued.
was passed in the 6tliyear of the reign of his said late Majesty,
6Geo. 4, c. 42. intituled "An Act for the better regulation of copartnerships
of certain banters in Ireland:" and whereas it is expedient
that the said acts should for a limited time be amended so far
as relates to the powers enabling any such copartnership, not
being a body corporate, to sue any of its own members, and
the powers enabling any member of any such copartnership,
not being a body corporate, to sue the said copartnership : be
it therefore enacted, &c., that any person now being or having
been, or who may hereafter be or have been, a member of any
copartnership now carrying on or which may hereafter carry
on the business of banking under the provisions of the said
recited acts may at any time during the contimiance of this
act («), in resj)ect of any demand which such pei'son may
have, either solely or jointly Avith any other person, against
the said copartnership, or the funds or property thereof,
commence and prosecute, either solely or jointly with any
other person (as the case may rec[uire), any action, suit,
or other proceeding at law or in ecj^uity against any public
officer appointed or to be appointed under the provisions
of the said acts to sue and be sued on the behalf of
the said copartnership ; and that any such public officer
may in his own name commence and prosecute any action,
suit, or other jn'oceeding at law or in equity, against any
person being or having been a member of the said copartner-
ship, either alone or jointly with any other person, against
whom any such copartnership has or may have any demand
whatsoever ; and that every person being or having been a
member of any such copartnership shall, either solely or
jointly with any other jierson (as the case may reqviire), be
capable of proceeding against any such copartnership by their
public officer, and be liable to be proceeded against, b}^ or for
the benefit of the said copartnership, by such public officer as
aforesaid, by such proceedings and with the same legal conse-
quences as if such person had not been a member of the said
copartnershij) ; and that no action or suit shall in anywise be
afi'ected or defeated by reason of the plaintiffs or defendants
or any of them respectively, or any other person in Avhom any
interest may be averred, or who may be in anywise interested
or concerned in such action, being or having been a member
of the said copartnership ; and that all such actions, suits, and
proceedings shall be conducted and have effect as if the same
had been between strangers.
Proceedings 2. That in case the merits of any demand by or against any
in an action such copartnership shall have been determined in any action
may be _ qj. g^j{. j^y q^ against any such public officer, the proceedings
(a) Repealed by Statute Law Kevision Act, 1874.
. 3 & 4 Vict. c. 111. 617
in such action or suit may be pleaded in bar of any other bar of any
action or suit bj' or against the public officer of the same co- other action,
partnership for the same demand.
3. That all the provisions of the said recited acts relative to Extending
actions, suits, and proceedings commenced or prosecuted under provisions of
the authority thereof, shall be applicable to actions, suits, and [o*^pr*esent^^
proceedings commenced or prosecuted under the authority of ^ct.
this act.
4. That no claim or demand which any member of any such A m(>mbcr'8
copartnershiji may have in respect of his share of the capital ^^'''1'^ ^"
or joint stock thereof, or of any dividends, interest, profits, or partnership'"
bonus paj-able or apportionable in respect of such share, shall not to be set
be capable of being set off, either at law or in equit}', against off against
any demand which such copartnership may have against such any demand
member on account of any other matter or thing whatsoever ; '^''^^^'^ ^^^\n
but all proceedings in respect of such other matter or thing ^^^^ Ymve
may be carried on as if no claim or demand existed in respect against him.
of such capital or joint stock, or of any dividends, interest,
profits, or bonus payable or apportionable in respect thereof.
5. That this act shall continue in force until the end of the Continuance
next session of parliament ; and that any such action, suit, or °^ ^°* (")•
other proceeding as aforesaid, which during the continuance
of this act may have been commenced or instituted, shall
(notwithstanding this act may have expired) be carried on in
all respects whatsoever as if this act had continued in force («).
Legal Procedure hy Joint Sfocic Banks.
3 & 4 Vict. c. 111.
A71 Act to continue until the Z\st day of August, 1842, and to
extend, the Provisions of an Act of the First and Second
Years of Her present JIaJestt/, relating to Legal Proceed-
ings by certain Joint Stock Banking Companies against
their own Members, and by such Members against the Com-
panies. [11th August, 1840.]
Whereas an act was passed in the 1st and 2nd years of the
reign of her present Majesty, intituled "An Act to extend, l & 2 Vict,
until the end of the next session of parliament, the law
relative to legal proceedings by certain joint stock banking
companies against their own members, and by such members
against the companies:" and whereas the said act has been
continued until the 31st day of August, 1840, by an act passed
{a) This act was continued by 2 & 3 Vict. c. 68, and by 3 & 4 Vict.
Q. Ill, and was made perpetual by 5 & 6 Vict. c. 85. Sect. 5 has been
repealed by Statute Law Re^-ision Act, 1874.
90.
618
APPENDIX OF STATUTES.
Recited act
continued.
Punishing
members of
banking- con
panies em-
bezzling
notes, &c.
3 & 4 Will. 4,
c. 98.
in the last session of parliament, and it is expedient tliat the
same should be further continued : be it therefore enacted, &g.,
that the said first-recited act shall be further continued until
the 31st day of August, 1842 (a).
2. And Avhereas it is ex]iedient to extend the provisions of
the said act hereby continued in manner hereinafter stated ;
be it enacted, that if any person or persons, being a member
or members of any banking copartnership within the meaning
of the said act, or of any other banting copartnership con-
sisting of more than six persons, formed under or in pursuance
of an act passed in the 3rd and 4th years of the reign of King
William the Fourth, intituled "An Act for giving to the
corporation of the Governor and Company of the Bank of
England certain privileges, for a limited period, under certain
conditions," shall steal or embezzle any money, yoods, effects,
hills, notes, securities, or other property of or bclonyiny to any
such copartner shij), or («) shall commit any fraud, forgery,
crime, or offence against or with intent to injure or defraud
any such copartnership, such member or members shall be
liable to indictment, information, prosecution, or other pro-
ceeding in the name of any of the officers for the time being
of any such copartnership in whose name any action or suit
might be lawfully brought against any member or members
of any such copartnership for every such fraud, forgery,
crime, or offence, and may thereupon be lawfully convicted,
as if such person or persons had not been or was or were not
a member or members of such copartnership ; any law, usage,
or custom to the contrary notwithstanding.
Spiritual Persons 2)yohibited being Members of Joint Stock
Banks.
4 Vict. c. 14.
An Act to make yood certain Contracts xohich have been or may
he entered into by certain Bankiny and otlier Copartner-
shipsib). [18th May, 1841.]
Whereas divers associations and copartnerships, consisting of
more than six members or shareholders, have from time to
time been formed for the purpose of being engaged in and
carrying on the business of banking and divers other trades
[a) Repealed, as to sect. 1, and the words in i^a/ws in sect. 2, by Statute
Law Revision Act, 1874.
(/') This statute is a ro-cuactmcnt of 1 Vict. c. 10, oi'igiually temporary
and limited in operation, and repealed by the Statute Law Revision Act,
18G1 (24 & 2.5 Vict. c. 101).
7 & 8 YicT. c. 32. 619
and doaliugs for gain and profit, and liavo accordingly for
some time past been and are now engaged in carrying on the
same by means of boards of directors or managers, committees
or other officers, acting on belialf of all the members or share-
holders of or j)ersons otherwise interested in snch associations
or copartnerships : and whereas divers spiritual persons,
having or holding dignities, prebends, canonries, benefices,
stipendiary curacies, or lectureships, have been and are mem-
bers or shareholders of or otherwise interested in divers of
such associations and copartnerships : and whereas it is expe-
dient to render legal and valid all contracts entered into by
such associations or copartnerships, although the same may
now be void by reason of such spiritual persons being or
having been such members or shareholders or otherwise
interested as aforesaid; be it therefore enacted, &c., that no No associa-
such association or coj)artnership already formed or which tion or co-
may be hereafter formed, nor any contract either as between paftnership,
the members, partners, or shareholders composing such asso- entered '^uto
elation or copartnership for the purposes thereof, or as between by any of
such association or copartnership and other persons, heretofore them, to be
entered into, or which shall be entered into by any such asso- iUeg-il or void
ciation or copartnership already formed or hereafter to be by^'^ason
formed, shall be deemed or taken to be illegal or void, or to smritual pcr-
occasion any forfeiture whatsoever, by reason only of any such sons being
spiritual person as aforesaid being or having been a member, members
partner, or shareholder of or otherwise interested in the same, thereof.
but all such associations and copartnerships shall have the
same validity and all such contracts shall and may be enforced
in the same manner to all intents and purposes as if no such
spiritual person had been or was a member, partner, share-
holder of or interested in such association or copartnership :
provided always, that it shall not be lawful for any spiritual No spiritual
person holding any cathedral preferment, benefice, curacy, or person bene-
lectureship, or who shall bo licensed or allowed to perform need or^per-
the duties of any ecclesiastical office, to act as a director or ccc^sii^tical '
managing, partner, or to carry on such trade or dealing as duty to act as
aforesaid in person. director.
Bank Notes Issue Eegulation, and Bank of England
Privileges Act.
7 & 8 YicT. c. 32.
An Act to regulate the Issue of Bank Notes, and for giving to the
Governor and Company of the Bank of England certain
Privileges for a limited Period. [19th July, 1844.]
Whereas it is expedient to regulate the issue of bills or notes
payable on demand : and whereas an act was passed in the
620
API^ENDIX OF STATUTES.
3 & 4 Will. 4,
c. 98.
Bank to
establish a
separate de-
partment for
the issue of
notes.
Management
of the issue
by Bank of
England.
4th year of the reign of his late Majesty King William the
Fourth, intituled " An Act for giving to the corporation of the
Governor and Company of the Bank of England certain privi-
leges for a limited period, under certain conditions ;" and it is
expedient that the privileges of exclusive banking therein
mentioned should be continued to the said Governor and Com-
pany of the Bank of England, with such alterations as are
herein contained, upon certain conditions : may it therefore
please your Majesty that it may be enacted ; and be it enacted,
&c., that from and after the 31st day of August, 1844, the
issue of promissory notes of the Governor and Company of the
Bank of England, payable on demand, shall be separated and
thencefortli kept wholly distinct from the general banking
business of the said governor and company ; and the business
of and relating to such issue shall be thenceforth conducted
and carried on by the said governor and company in a separate
department to be called " The Issue Department of the Bank
of England," subject to the rules and regulations hereinafter
contained ; and it shall be lawful for the court of directors of
the said governor and company, if they shall think fit, to
appoint a committee or committees of directors for the conduct
and management of such issue department of the Bank of
England, and from time to time to remove the members and
define, alter, and regulate the constitution and powers of such
committee, as they shall think fit, subject to any bye-laws,
rules or regulations which may be made for that purj)ose :
j)rovided nevertheless, that the said issue department shall
always be kept separate and distinct from the banking depart-
ment of the said governor and company.
2. That upon the 31st day of August, 1844, there shall be
transferred, appropriated, and set apart by the said governor
and company to the issue department of the Bank of England
securities to the value of fourteen million pounds, whereof the
debt due by the public to the said governor and company shall
be and be deemed a part ; and there shall also at the same
time be transferred, appropriated, and set apart by the said
governor and company to the said issue department so much
of the gold coin and gold and silver bullion then held by the
Bank of England as shall not be required by the banking
department thereof ; and thereupon there shall be delivered
out of the said issxie department into the said banking depart-
ment of the Bank of England such an amoimt of Bank of
England notes as, together with the ]3ank of England notes
then in circulation, shall be equal to the aggregate amount of
the securities, coin, and bullion so transferred to the said issue
department of the liank of England ; and the whole amount
of Bank of England notes then in circulation, including those
delivered to the banldng department of the Bank of England
7 & 8 Vict. c. 32. G2l
as aforesaid, shall be deemed to be issued on tlie credit of such
securities, coin, and bullion so appropriated and set apart to
the said issue department ; and from thenceforth it shall not
be lawful for the said governor and company to increase the
amount of securities for the time being in the said issue
department, save as hereinafter is mentioned, but it shall be
lawful for the said governor and company to diminish the
amount of such securities, and again to increase the same to
any sum not exceeding in the whole the sum of fourteen
million pounds, and so from time to time as they shall see
occasion ; and from and after such transfer and appropriation
to the said issue department as aforesaid it shall not be lawful
for the said governor and company to issue Bank of England
notes, either into the banking department of the Bank of
England, or to any persons or person whatsoever, save in
exchange for other Bank of England notes, or for gold coin
or for gold or silver bullion received or purchased for the said
issue department under the provisions of this act, or in
exchange for securities acquired and taken in the said issue
department under the provisions herein contained : provided
always, that it shall be lawful for the said governor and com-
pany in their banking department to issue all such Bank of
England notes as they shall at any time receive from the said
issue department or otherwise, in the same manner in all
respects as such issue would be lawful to any other person or
persons.
3. And whereas it is necessary to limit the amount of silver Proportion of
bullion on which it shall be lawful for the issue department of silver bullion^
the Bank of England to issue Bank of England notes ; be it r ^^J^^^^^^"^
therefore enacted, that it shall not be lawfid. for the Bank of department.
England to retain in the issue department of the said bank at
any one time an amount of silver bullion exceeding one fourth
part of the gold coin and bullion at such time held by the
Bank of England in the issue department.
4. That from and after the 31st day of August, 1844, all All persons
persons shall be entitled to demand from the issue department ^\^^g ^^^3
of the Bank of England Bank of England notes in exchange department
for gold bullion, at the rate of 3/. 17s. 9f/. per ounce of standard notes for gold
gold : provided always, that the said governor and company bullion,
shall in all cases be entitled to require such gold bullion to be
melted and assayed by persons approved by the said governor
and company at the expense of the parties tendering such gold
bullion.
5. Provided always, that if any banker who on the 6th day Power to in-
of May, 1844, was issuing his own bank notes shall cease to crease sceuri-
issue his own bank notes, it shall be lawful for her Majesty g^f, "depart-
in council at any time after the cessation of such issue, ui)_on ^^j^^^ ^nd
the application of the said governor and company, to authorize issue addi-
tional notes.
622 APPENDIX OF STATUTES.
and empower the said governor and company to increase the
amount of securities in the said issue department heyond the
total sum or vakie of fourteen million pounds, and thereupon
to issue additional Bank of England notes to an amount not
exceeding such increased amount of securities specified in
such order in council, and so from time to time : provided
always, that such increased amount of securities specified in
such order in council, shall in no case exceed the proportion
of two-thirds the amount of bank notes which the banker so
ceasing to issue may have been authorized to issue under the
provisions of this act ; and every such order in council shall be
published in the next succeeding London Gfazette.
Account to bo 6. That an account of the amount of Bank of England notes
+1" "R^^ V '^ issued by the issue department of the Bank of England and
Euo-land '^^ gold coin and of gold and silver bullion respectively, and of
securities in the said issue department, and also an account of
the capital stock, and the deposits, and of the monoj^ and se-
curities belonging to the said governor and company in the
banking department of the Bank of England, on some day in
every week to be fixed by the commissioners of stamps and
taxes, shall be transmitted by the said governor and company
weekly to the said commissioners in the form prescribed in the
schedide hereto annexed marked (A.) («), and shall be pub-
lished by the said commissioners in the next succeeding
London Gazette in which the same may be conveniently
inserted.
Bank of 7. That from and after the said 31st day of August, 1844,
England the said Governor and Company of the Bank of England shall
exempted y^Q released and discharged from the payment of any stamp
d^itvupon^^ duty, or comx^osition in respect of stamp duty, upon or in
their notes. respect of their promissory notes payable to bearer on demand ;
and all such notes shall thenceforth be and continue free and
wholly exempt from all liability to any stamp duty whatso-
ever.
Bank to allow 8. That from and after the said 31st day of August, 1844,
180,000^. per the payment or deduction of the annual sum of 180,000^. made
by the said governor and company, under the provisions of
the said act passed in the fourth year of the reign of liis late
Majesty King William the Eourth, out of the sums payable to
them for the charges of management of the public unredeemed
debt, shall cease, and in lieu thereof the said governor and
company, in consideration of the privileges of exclusive bank-
ing, and the exemption from stamp duties, given to them by
this act, shall, during the continuance of such privileges and
such exemption respectively, but no longer, deduct and allow
to the public, from the sums nov,' payable by law to the said
(«) See note («), post, p. G23.
annnm.
7 & 8 Vict. c. 32.
623
governor and company for the cliarges of management of tlie
public uiu-edeemed debt, the annual sum of 180,000^., anything
in any act or acts of parliament, or in any agreement, to the
contrary notwithstanding : provided alvrays, that such deduc-
tion shall in no respect prejudice or affect the rights of the
said governor and company to bo paid for the management of
the public debt at the rate and according to the terms provided
in an act passed in the 48th year of the reign of his late
Majest}' King George the Third, intituled "An Act to authorize 48 Geo. 3,
the advancing for the public service, upon certain conditions, ^- *•
a proportion of the balance remaining in the Bank of England,
for the payment of unclaimed dividends, annuities, and
lottery prizes, and for regulating the allowances to be made
for the management of the national debt " (b).
9. That in case, imder the provisions hereinbefore contained, Bank to allow
the securities held in the said issue department of the Bank of ^^^ public the
England shall at any time bo increased beyond the total Profits of in-
amount of fourteen million pounds, then and in each and lation.
every year in which the same shall happen, and so long as
such increase shall continue, the said governor and company
(a) The following is tlie schedule referred to : —
SCHEDULE (A.)
Bank of England.
An Account pursuant to the act 7 & 8 Vict. cap.
ending on the day of
Issue Department.
£
Notes issued
for the week
Government debt . , .
Other secmitics
Gold coin and bullion .
Silver bullion ,
Dated the
day of 18 .
Banking Department.
£
cashier.
Proprietors' capital
Rest
Public deposits (to include
exchequer, savings banks,
commissioners of national
debt and dividend accounts)
Other deposits
Seven-day and other bills . .
Government securities (in-
cluding dead weight an-
nuity)
Other securities
Notes
Gold and silver coin
Dated the day of 18 .
(J) Kepealed by Statute Law Revision Act, 1874.
cashier.
62i
ArPEXDIX OF STATUTES.
No new bank
of issue.
Restriction
against issue
of bank notes.
shall, in addition to the said annual sum of 180,000?., mate a
further payment or allowance to the public, equal in amount
to the net profit derived in the said issue department during
the current year from such additional securities, after deduct-
ing the amount of the expenses occasioned by the additional
issue during the same period, "^liich expenses shall include
the amount of any and every composition or payment to be
made by the said governor and company to any banker in
consideration of the discontinuance at any time hereafter of
the issue of bank notes by such banker; and skcIi further pay-
ment or allo2va>ice to the jiiihlic hy the said (jovernor and com-
pany shall, in every year while the iruhlic shall he entitled to
receive the same, he deducted from the amount hy law payahle to
the said governor and company for the charges of management
of the unredeemed public debt, in the same maimer as the said
annual sum of 180,000/. is hereby directed to he deducted there-
from («).
10. That from and after the passing of this act no person
other than a banker who, on the 6th day of May, 1844, was
lawfully issuing his own bank notes shall make or issue bank
notes in any part of the United Kingdom.
11. That from and after the passing of this act it shall not
be lawful for any banker to draw, accejit, make, or issue, in
England or "Wales, any bill of exchange or promissory note
or engagement for the j)ayment of money payable to bearer
on demand, or to borrow, owe, or take up, in England or
"Wales, any svims ot sum of money on the bills or notes of
such banker payable to bearer on demand, save and except
that it shall be lawful for any banker who was on the 6th day
of May, 1844, carrying on the business of a banker in Eng-
land or Wales, and was then lawfully issuing, in England or
Wales, his own bank notes, under the aiithority of a licence
to that eif ect, to continue to issue such notes to the extent and
under the conditions hereinafter mentioned, but not further
or otherwise ; and the right of any company or partnership
to continue to issue such notes shall not be in any manner
prejudiced or affected by any change which may hereafter
take place in the personal composition of such company or
partnershij), either by the transfer of any shares or share
therein, or by the admission of any new partner or member
thereto, or by the retirement of any present partner or mem-
ber therefrom : provided always, that it shall not be lawful
for any company or partnership now consisting of only six
or less than six persons to issue bank notes at any time after
the number of partners therein shall exceed six in the whole.
(a) Repealed, as to words in italics, by Statute Law Revision Act,
1874.
7 & 8 YicT. c. 32. G2o
12. That if any banker in any part of the United Kingdom Bankers
■who, after the passing of this act, shall be entitled to issue ceasing to
bank notes shall become bankrupt, or shall cease to carry on ^^^'^^ ^°*''^
the business of a banker, or shall discontinue the issue of ^'^g'^*^*^ ^^'
bank notes, either by agreement with the Governor and
Company of the Bank of England or otherwise, it shall not
be lawful for such banker at any time thereafter to issue any
such notes.
13. That every banker claiming under this act to continue Existing-
to issue bank notes in England or Wales shall, within one ^anks of issue
month next after the passing of this act, give notice in writing *^ continue
to the commissioners of stamps and taxes, at their head office limitations'*^^
in London, of such claim, and of the place and name and firm
at and under which such banker has issued such notes during
the twelve weeks next preceding the 27th day of April last ;
and thereupon the said commissioners shall ascertain if such
banker was, on the 6th day of May, 1844, carrjdng on the
business of a banker, and lawfully issuing his own bank
notes in England or Wales, and if it shall so appear then the
said comxnissioners shall proceed to ascertain the average
amount of the bank notes of such banker which were in cir-
culation during the said period of twelve weeks preceding the
27th day of April last, according to the returns made by such
banker in pursuance of the act passed in the 4th and 5th
years of the reign of her present Majest}-, intituled " An Act 4 & 5 Vict,
to make further provision relative to the returns to be made c. 50.
by banks of the amount of their notes in circulation;" and the
said commissioners, or any two of them, shall certify under
their hands to such banker the said average amount, when so
ascertained as aforesaid ; and it shall be lawful for every such
banker to continue to issue his own bank notes after the pass-
ing of this act : provided nevertheless, that such banker shall
not at any time after the lOtli day of October, 1844, have in
circulation upon the average of a period of four weeks, to be
ascertained as hereinafter mentioned, a greater amount of
notes than the amount so certified.
14. Provided always, that if it shall be made to appear to Provision for
the commissioners of stamps and taxes that any two or more united banks,
banks have, by written contract or agreement (which contract
or agreement shall be produced to the said commissioners),
become imited within the twelve weeks next preceding such
27th day of April as aforesaid, it shall be lawful for the said
commissioners to ascertain the average amount of the notes
of each such bank in the manner hereinbefore directed, and
to certify the average amount of the notes of the two or more
banks so imited as the amount which the united bank shall
thereafter be authorized to issue, subject to the regulations of
this act.
G. S S
G26
APPENDIX OF STATUTES.
Duplicate
certificate to
be publislied
in the
Gazette.
Gazette to be
evidence.
In case banks
become
united, com-
missioners to
certify the
amount of
bank notes
■which each
bank was
authorized to
issue.
Penalty on
banks issiaiusr
Issuing banks
to render
accounts.
15. That the commissioners of stamps and taxes shall, at
the time of certifying to any banker such particulars as they
are hereinbefore required to certify, also publish a duplicate
of their certificate thereof in the next succeeding London
Gazette in which the same may be conveniently inserted ; and
the gazette in which such publication shall be made shall be
conclusive evidence in all courts whatsoever of the amount of
bank notes which the banker named in such certificate or
duplicate is by law authorized to issue and to have in circula-
tion as aforesaid.
16. That in case it shall be made to appear to the commis-
sioners of stamps and taxes, at any time hereafter, that any
two or more banks, each such bank consisting of not more
than six persons, have, by written contract or agreement
(which contract or agreement shall be produced to the said
commissioners), become united subsequently to the passing of
this act, it shall be lawful to the said commissioners, iqion the
application of such united bank, to certify, in manner herein-
before mentioned, the aggregate of the amounts of bank notes
which such separate banks were previously authorized to issue,
and so from time to time ; and every such certificate shall be
published in manner hereinbefore directed ; and from and
after such publication the amount therein stated shall be and
be deemed to be the limit of the amount of bank notes which
such united bank may have in circulation : provided always,
that it shall not be lawful for any such united bank to issue
bank notes at any time after the number of partners therein
shall exceed six in the whole.
17. That if the montlily average circulation of bank notes
of any banker, taken in the manner hereinafter directed, shall
at any time exceed the amount which such banker is autho-
rized to issue and to have in circulation under the provisions
of this act, such banker shall in every such case forfeit a sum
equal to the amount by which the average monthly circulation,
taken as aforesaid, shall have exceeded the amount which
such banker was authorized to issue and to have in circulation
as aforesaid.
18. That every banker in England and "Wales who, after
the 10th day of October, 1844, shall issue bank notes shall
on some one day in every week after the 19th day of
October, 1844 (such day to be fixed by the commissioners
of stamps and taxes) transmit to the said commissioners
an account of the amount of the bank notes of such banker
in circulation on every day during the week ending on
the next preceding Saturday, and also an account of the
average amount of the bank notes of such banker in circu-
lation during the same week ; and on completing the fii-st
period of four weeks, and so on completing each successive
period of four weeks, every such banker shall annex to such
7 & 8 Vict. c. 32. 627
account the average amount of bank notes of such banker in
circulation during the said four weeks, and also the amount
of bank notes which such banker is authorized to issue under
the provisions of this act ; and every such account shall be
verified by the signatiire of such banker or his chief cashier,
or, in the case of a company or partnership, by the signature
of a managing director or j^artner or chief cashier of such
company or partnership, and shall be made in the form to this
act annexed marked (B.) («) ; and so much of the said return
as states the weekly average amount of the notes of such bank
shall be published by the said commissioners in the next suc-
ceeding London Gazette in which the same may be conveni-
ently inserted ; and if any such banker shall neglect or refuse
to render any such account in the form and at the time
required by this act, or shall at any time render a false account,
such banker shall forfeit the sum of 100^. for every such
offence.
19. That for the purpose of ascertaining the monthly Mode of
average amount of bank notes of each banker in circulation ascertaimng
the aggregate of the amount of bank notes of each such banker amount of
in circulation on every day of business during the first com- bank notes of
each banker
(«) The schedule is as follows : —
SCHEDULE (B.)
Name and title as set forth | ■Rnnlc
in the licence j
Name of the firm Firm.
Insert head of&ce or prin- ) PItop
cipal place of issue . , . . /
An Account pursuant to the act 7 & 8 Vict. cap. of the notes of the
said bank in circulation during the week ending Saturday the
day of 18 .
Monday
Tuesday
Wednesday
Thursday
Friday
Saturday
6)
Average of the week ....
[To be annexed to this account at the end of each period of four iceeks.'}
Amount of notes authorized by law £
Average amount in circulation during the f oxu* ) ^
weeks ending as above j
I, being [the banker, chief cashier, managing dii-ector, or partner of
the bank, as the case maij k], do hereby certify that the above is a
true account of the notes of the said bank in circidatiou dui-ing the Aveek
above written.
(Signed)
Dated the day of 18 .
ss2
628
APPENDIX OF STATUTES.
in circulation
during the
first f our
•weeks after
10th October,
1844.
Commis-
sioners of
stamps and
taxes em-
powered to
cause the
books of
bankers con-
taining ac-
counts of
their bank
notes in cir-
culation to be
inspected.
Penalty for
refusing to
allow such
inspection.
All bankers
to return
names once a
year to the
stamp office.
plete period of four weeks next after the lOth. day of October,
1844, sucli period ending on a Saturday, shall be divided by
the number of days of business in such four weeks, and the
average so ascertained shall be deemed to be the average of
bank notes of each such banker in circulation during such
period of four weeks, and so in each successive period of four
weeks, and such average is not to exceed the amount certified
by the commissioners of stamps and taxes as aforesaid.
20. And whereas, in order to insure the rendering of true
and faithful accounts of the amount of bank notes in circu-
lation as directed by this act, it is necessary that the commis-
sioners of stamps and taxes should be empowered to cause the
books of bankers issuing such notes to be inspected, as here-
inafter mentioned : be it therefore enacted, that all and every
the book and books of any banker who shall issue bank notes
under the provisions of this act in which shall be kept, con-
tained, or entered any account, minute, or memorandum of or
relating to the bank notes issued or to be issued by such
banker, or of or relating to the amount of such notes in circu-
lation, from time to time, or any account, minute, or memo-
randum, the sight or inspection whereof may tend to secure
the rendering of true accounts of the average amount of such
notes in circulation, as directed by this act, or to test the truth
of any such account, shall be open for the inspection and
examination, at all seasonable times, of any officer of stamp
duties authorized in that behalf by writing, signed by the
commissioners of stamjis and taxes or any two of them ; and
every such officer shall be at liberty to take copies of or
extracts from any such book or account as aforesaid ; and if
any banker or other person keeping any such book, or having
the custody or possession thereof, or power to produce the
same, shall, upon demand made by any such officer, showing
(if required) his authority in that behalf, refuse to produce
any such book to such officer for his inspection or examina-
tion, or to permit him to inspect and examine the same, or to
take copies thereof or extracts therefrom, or of or from any
such account, minute, or memorandum as aforesaid kept, con-
tained, or entered therein, every such banker or other person
so offending shall for every such offence forfeit the sum of
100^. : provided always, that the said commissioners shall not
exercise the powers aforesaid without the consent of the com-
missioners of her Majesty's Treasury.
21. That every banker in England and "Wales who is now
carrying on or shall hereafter carry on business as such shall
on the 1st day of January in each year, or within fifteen days
thereafter, make a return to the commissioners of stamps and
taxes at their head office in London of his name, residence,
and occupation, or in the case of a company or partnership, of
7 & 8 Vict. c. 32. 029
the name, residence, and occupation of every person composing
or being a member of such, company or partnership, and also
the name of the firm imder which such banker, company, or
partnership carry on the business of banking, and of every
place where such business is carried on ; and if any such
banker, company, or partnership shall omit or refuse to make
such return within fifteen days after the said 1st day of
January, or shall wilf ulty make other than a true return of the
persons as herein required, every banker, company, or part-
nership so offending shall forfeit and pay the sum of 50/. ;
and the said commissioners of stamps and taxes shall on or
before the 1st day of "March in every year publish in some
newspaper circulating within each town or county respectively
a copy of the return so made 'by every banker, company, or
partnership carrying on the business of bankers within such
town or county respectively, as the case may be.
22. That every banker who shall be liable by law to take Bankers to
out a licence from the commissioners of stamps and taxes to ^^^^ °^* *
authorize the issuing of notes or bills shall take out a separate if^j^^c'e for
and distinct licence for every town or place at which he shall, every place at
by himself or his agent, issue any notes or bills requiring which they
such licence to authorize the issuing thereof, any thing in any i«sue notes or
former act contained to the contrary thereof notwithstanding : " ^■
provided always, that no banker who on or before the 6th day Proviso in
of May, 1844, had taken out four such licences, which on the fj^'^T"' °* ,
said last-mentioned day were respectively in force, for the ^^^ ^^^ g^^,]^
issuing of any such notes or bills at more than four separate licences in
towns or places, shall at any time hereafter be required to force on the
take out or to have in force at one and the same time more 6th of May,
than four such licences to authorize the issuing of such notes
or bills at all or any of the same towns or places specified in
such licences in force on the said 6th day of May, 1844, and at
which towns or places respectively such bankers had on or
before the said last-mentioned daj' issued such notes or bills
in pursuance of such licences or any of them respectively.
23. And whereas the several bankers named in the schedule Compensation
hereto annexed marked (C.) (a) have ceased to issue their own to certain
bank notes under certain agreements with the Governor and ^^^g'^'j^ q^.^
Company of the Bank of England ; and it is expedient that schedule,
such agreement should cease and determine on the 31st day
of December next, and that such bankers should receive by
way of compensation such composition as hereafter mentioned ;
and a list of such bankers, and a statement of the maximum
sums in respect of which each such banker is to receive com-
pensation, hath been delivered to the commissioners of stamps
and taxes, signed by the chief cashier of the Bank of Eng-
((7) See note (o), post, p. 630.
630
APPENDIX OF STATUTES.
land ; he It therefore enacted, that the several agreements suh-
sisting hetiveen the said governor and company and the several
bankers mentioned in the schedule hereto relating to the issue of
Banli of England notes shall cease and determine on the ^\st
day of December next ; and from and after that day {h) the said
governor and company shall i^ay and allow to the several
hankers named in the schedule hereto marked (C.) (c), so long
as snch hankers shall he willing to receive the same, a com-
position at and after the rate of \l. per centum per anmmi on
the average amount of the Bank of England notes issued hy
such hankers respectively and actually remaining in circula-
tion, to he ascertained as follows; (that is to say,) on sorne
day in the month of April, 1845, to be determined by the said
governor and company, an account shall be taken of the Bank
of England notes delivered to such bankers respectively by
the said governor and company within three months next
preceding, and of such of the said Bank of England notes as
shall have been returned to the Bank of England, and the
balance shall be deemed to be the amount of the Bank of
England notes issued by such bankers respectively and kept
in circulation; and a similar account shall be taken at in-
(i) As to words in italics repealed by Statute Law Revision Act, 1874.
(r) SCHEDULE (C.)
Banks which have ceased to issue their own bank notes under certain
agreements with the Governor and Company of the Bank of Enghmd.
Bank of Liverpool.
J. Earned & Co.
Biddtdph, Brothers & Co.
Birmingham Banking Co.
Birmingham Tovni and District
Bank.
Birmingham and Midland Banking
Co.
Burgess & Son.
Coopers fcTiu-ton.
CunclifEes, Brookes & Co.
Deane, Littlehales & Deanc.
Dendy, Comper & Co.
Devon and Cornwall Banking Co.
Grants k GiUman.
Hampslaire Banking Co.
James W. B. HaU.
J. M. Head & Co.
Henty, TJpperton & Olliver.
Thomas Kinnersly & Sons.
E. J. Lamb ton & Co.
Liverpool Commercial Banking Co.
Liverpool Union Bank.
Liverpool Borough Bank.
Manchester and Liverpool District
Banking Co.
Manchester and Salf ord BankingCo.
Monmouth and GlamorganBanking
Co.
Moss & Co.
Mangles, Brothers.
Newcastle Commercial Banking Co.
Ne^\-castle-on-Tyne Joint Stock
Banking Co.
North of England Joint Stock
Banking Co.
Northumberland and Dm-ham Dis-
trict Bank.
Portsmouth and South Hants Bank
Co.
T. & R. Eaikcs & Co.
Robinson & Brodhurst.
Sheffield Union Bank.
John Stovcld.
Sunderland Joint Stock Banking
Co.
TugweU & Co.
Union Bank of Manchester.
Vivian, Ivitson & Co.
Watts, Whitcway & Co.
J. & J. C. Wright & Co.
Webb, Holbrook & Spencer.
7 & 8 Vict. c. 32. 631
tervals of three calendar montlis ; and the average of the
balances ascertained on taking four such accounts shall be
deemed to be the average amount of Bank of England notes
issued by such bankers respectively and kept in circulation
during the year 1845, and on which amount such bankers are
respectively to receive the aforesaid composition of one per
centum for the year 1845 ; and similar accounts shall be taken
in each succeeding year ; but in each year such accounts shall
be taken in diiferent months from those in which the accounts
of the last preceding year were taken, and on different days
of the month, such months and days to be determined by the
said governor and company ; and the amount of the compo-
sition payable as aforesaid shall be paid by the said governor
and company out of their own funds ; and in case any differ-
ence shall arise between any of such bankers and the Grovernor
and Company of the Bank of England in respect of the com-
position payable as aforesaid, the same shall be determined
by the chancellor of the eschec^uer for the time being, or by
some person to be named by him, and the decision of the
chancellor of the exchequer, or his nominee, shall be final and
conclusive : provided always, that .it shall be lawful for any
banker named in the schedule hereto annexed marked (0.) (d)
to discontinue the receipt of such composition as aforesaid, but
no such banker shall by such discontinuance as aforesaid
thereby acquire any right or title to issue bank notes.
24. That it shall be lawful for the said governor and com- ^ank of
pany to agree with every banker who, under the provisions ^g^^f Jfo" e^°to
of this act, shall be entitled to issue bank notes, to allow to compound
such banker a composition at the rate of one per centum per with issuing
annum on the amount of Bank of England notes which shall banks.
be issued and kept in circulation by such banker, as a con-
sideration for his relinquishment of the privilege of issuing
his own bank notes ; and all the provisions herein contained
for ascertaining and determining the amount of composition
payable to the several bankers named in the schedule- hereto
marked (0.) (r/), shall apply to all such other bankers with
whom the said governor and company are hereby authorized
to agree as aforesaid ; provided that the amount of composition
payable to such bankers as last aforesaid shall in every case in
which an increase of securities in the issue department shall
have been authorized by any order in council be deducted out
of the amoimt payable by the said governor and company to _ _
the public under the provisions herein contained : provided Limitation of
always, that the total sum payable to any banker, under the compositions,
provisions herein contained, by way of composition as afore-
said, in any one year, shall not exceed, in case of the bankers
(d) See note (c), ante, p. 630.
G32
APPENDIX OF STATUTES.
Compositions
to cease on
1st August,
1856.
Banks witliin
65 miles of
London may
accept, &:c.
bills.
Bank to enjoy
privileges,
subject to re-
demption.
mentioned in the schedule hereto marked (C.) («), one per
centum on the several sums set against the names of such
bankers respectively in the list and statement delivered to the
commissioners of stamps as aforesaid, and in the case of other
bankers shall not exceed one per centum on the amount of
bank notes which such bankers respectively would otherwise
be entitled to issue under the provisions herein contained.
25. That all the compositions payable to the several bankers
mentioned in the schedule hereto marked (C.) (a), and such
other bankers as shall agree with the said governor and com-
pany to discontinue the issue of their own bank notes as afore-
said, shall, if not previously determined by the act of such
banker as hereinbefore provided, cease and determine on the
1st day of August, 185G, or on any earlier day on which
parliament may prohibit the issue of bank notes (b).
26. That from and after the passing of this act it shall be
lawful for any society or company or any persons in partner-
ship, though exceeding six in number, carrying on the busi-
ness of banking in London, or within 65 miles thereof, to
draw, accept or indorse bills of exchange, not being payable
to bearer on demand, any thing in the hereinbefore recited
act passed in the 4th year of the reign of his said Majesty
Iving AVilliam the Fourth, or in any other act, to the contrary
notwithstanding.
27. That the said Grovernor and Company of the Bank of
England shall have and enjoy such exclusive privilege of
banking as is given by this act, upon such terms and conditions,
and subject to the termination thereof at such time and in
such manner as is by this act provided and specified ; and all
and every the powers and authorities, franchises, privileges
and advantages, given or recognized by the said recited act
passed in the 4th year of the reign of his Majesty King
William the Fourth, as belonging to or enjoyed by the said
Governor and Company of the Bank of England, or by any
subsecjuent act or acts of parliament, shall be and the same
are hereby declared to be in full force, and continued by this
act, except so far as the same are altered by this act ; subject
nevertheless to redemption upon the terms and conditions
following; (that is to say,) at anytime uj)ou twelve months'
notice to be given after the 1st day of August, 1855, and upon
repayment by parliament to the said governor and company
or their successors of the sum of 11,015,100/., being the debt
now due from the public to the said governor and company,
(«) See note (c), ante, j). 630.
[h) By 19 Vict. c. 20, s. 1, sect. 25 was repealed, and right to compound
continued ; but by 38 & 3'J Vict. c. 61, sect. 1 of 19 Vict. c. 20, has in its
turn been repealed.
8 & 9 ViLT. c. 76. 633
without any deduction, discount or abatement whatsoever, and
upon jDayment to the said governor and company and their
successors of all arrears of the sum of 100,000/. per annum, in
the last-mentioned act mentioned, together with the interest
or annuities payable upon the said debt or in respect thereof,
and also upon repa^Tnent of all the principal and interest
which shall be owing unto the said governor and company and
their successors upon all such tallies, exchequer orders, ex-
chequer bills or parliamentarj'- funds which the said governor
and company or their successors shall have remaining in their
hands or be entitled to at the time of such notice to be given
as last aforesaid, then and in such case, and not till then, the
said exclusive privileges of banking granted by this act shall
cease and determine at the expiration of such notice of twelve
months ; and any vote or resolution of the House of Commons,
signified under the hand of the speaker of the said house in
writing, and delivered at the public office of the said governor
and company, shall be deemed and adjudged to be a sufficient
notice.
28. That the term "bank notes" used in this act shall ex- Interpreta-
tend and apply to all bills or notes for the payment of money tion clause,
to the bearer on demand other than bills or notes of the
Governor and Company of the Bank of England ; and that the
term " Bank of England notes " shall extend and apply to the
promissory notes of the Grovernor and Company of the Bank
of England payable to bearer on demand ; and that the term
" banker " shall extend and appty to all corporations, societies,
partnerships and persons, and every individual person carrying
on the business of banking, whether by the issue of bank
notes or otherwise, except only the Governor and Company of
the Bank of England ; and that the word "person" used in
this act shall include corporations ; and that the singidar
number in this act shall include the plural number, and the
plural number the singular, except where there is anything in
the context repugnant to such construction ; and that the
masculine gender in this act shall include the feminine, except
where there is anything in the context repugnant to such con-
struction.
Recovery and Ajiplication of Penalties under 7 (^' 8 Vict.
c. 32.
8 & 9 Vict. c. 76.
An Act . ... to amend an Act of the last Session of
Parliament for rec/idating the Isszte of Bank Notes in Eng-
land. [4th August, 1845.]
5. And whereas an act was passed in the last session of Provision for
parliament, intituled "An Act to regulate the issue of bank recovery and
application of
634 APPENDIX OF STATUTES,
penalties notes, and for giving to tlie Governor and Company of the
under 7 & 8 Bank of England certain privileges for a limited period," and
Vict. c. 32. certain penalties are thereby imposed for oifences against the
provisions of the same act, and it is expedient to provide for
the recovery and application of such penalties : be it enacted,
that from and after the passing of this act all pecuniary
penalties imposed by or incurred under the said last-recited
act may be sued or prosecuted for and recovered, for the use
of her Majesty, in the name of her Majesty's attorney-general
or solicitor-general, or of any person authorized to sue or
prosecute for the same by writing under the hands of the
commissioners of stamps and taxes, or in the name of any
officer of stamp duties, by action of debt, bill, plaint or infor-
mation in the Court of Exchequer at Westminster, in such
and the same manner as any penalties imposed by any of the
laws now in force relating to the duties under the manage-
ment of the said commissioners ; and it shall be lawful in all
cases for the said commissioners, either before or after any
proceedings commenced for recovery of any such penalty, to
mitigate or compound any such penalty as they shall think
fit, and to stay any such proceedings after the same shall have
been commenced, and whether judgment may have been
obtained for such penalty or not, on payment of part only of
any such penalty, with or without costs, or on payment only
of the costs incurred in such proceedings, or of any part
thereof, or on such terms as such commissioners shall judge
reasonable : provided always, that in no such proceeding as
aforesaid shall any essoign, protection, wager of law, or more
than one imparlance, be allowed ; and all pecuniary penalties
imposed by or incurred under the said last-recited act, by
whom or in whose name soever the same shall be sued or
prosecuted for or recovered, shall go and bo applied to the
use of her Majesty, and shall be deemed to be and shall bo
accounted for as part of her Majesty's revenue arising from
stamp duties, anything in any act contained, or any law or
usage to the contrary, in anywise notwithstanding : provided
always, that it shall be lawful for the said commissioners, at
their discretion, to give all or any part of such penalties as
rewards to any person or persons who shall have detected the
offenders, or given information, which may have led to their
prosecution and conviction.
17 & 18 Vict. c. 83. 635
Drafts on Bankers imyahle to Order on Demand.
16 & 17 YicT. c. 59.
An Act to repeat certain Stamp Duties, and to grant others in
lieu thereof; to amend the Lairs relating to Stamp Duties,
and to make perpetual certain Stamp Duties in Ireland {a).
[4tli August, 1853.]
19, Provided always, tliat any di-aft or order drawn upon a Drafts on
banker for a sum of money payable to order on demand which. bd.
205. After the commencement of this act there shall be
repealed the several acts specified in the first part of the third
schedule hereto, with this qualification, that so much of the
said acts as is set forth in the second part of the said third
schedule shall be hereby re-enacted and continued in force as
if unrepealed.
THIRD SCHEDULE.
First Part.
An Act to regulate Joint Stock Banks in
England.
An Act to regulate Joint Stock Banks in
Scotland and Ireland.
An Act to amend the Law relating to
Banking Companies.
An Act to amend the Joint Stock Banking
Companies Act, 1857.
An Act to enable Joint Stock Banking
Companies to be formed on the principle
of Limited LiabiUty.
Secoio) Part.
7 (fe 8 Yict. c. 113, s. 47.
Every company of more than six persons established on the 6th
day of May, 1844, for the purpose of carrj'ing on the trade or
business of bankers within the distance of sixty-live miles from
London, and not within the provisions of the act passed in the
session holden in the 7th and 8th years of the reign of her present
Majesty, chapter 113, shall have the same jjowers and pri\'ileges of
suing and being sued in the name of any one of the pubhc officers
of such copartnership as the nominal plaintiff, petitioner, or de-
fendant on behalf of such copartnership ; and all judgments,
decrees, and orders made and obtained in any such suit may be
enforced in like manner as is provided with respect to such com-
panies carrj'ing on the said trade or business at any place in
England exceeding the distance of sixty-five miles from London,
irndfu- the provisions of an act jiassed in the 7th year of the reign
of Geo. 4, c. 4G, intituled " An Act for the better regulating co-
partnerships of certain bankers in England, and for amending so
much of an act of the 3U & 40 Geo. 3, intituled ' An Act for
7 & 8 Vict. c. 113 .
9 & 10 Vict. c. 75 .
20 & 21 Vict. c. 49 .
21 & 22 Vict. c. 60.
21 & 22 Vict. c. 91 .
27 & 28 YicT. c. 32. 641
establisliing an agreement with the Governor and Company of the
Bank of England for advancing the sum of three millions towards
the supply for the service of the year 1800,' as relates to the same,"
provided that such first-mentioned company shall make out and
deliver from time to time to the commissioners of stamps and taxes
the several accounts or returns required bj* the last-mentioned act,
and all the provisions of the last-recited act as to such accounts or
returns shall be taken to apply to the accounts or returns so made
out and delivered by such first-mentioned companies as if they had
been originally included in the provisions of the last-recited act.
20 & 21 Vict. 0. 49, Part of Section Xn.
Xotwithstanding anything contained in any act passed in the Power to
session holden in the 7th and 8th years of the reign of her present form banking
Majesty, chapter 11 o, and intituled "An Act to regulate joint stock copartner-
banks in England," or in any other act, it shall be lawful for any ships of ten
number of persons, not exceeding ten, to carry on in jtartnership Persons,
the business of banking, in the same manner and upon the same
conditions in all resj^ects as any company of not more than six
23ersons could before the passing of this act have carried on such
business.
Banhing Copaiincrsliips suing and sued hi/ PtiUic Officer.
27 & 28 Vict. c. 32.
An Act to enahle certain Banking Copartnersliips which shall
discontinue the issue of their own Bank Notes to sue and be
sued brj their Public Officer. [30th June, 1864.]
Whereas by the 7 Geo. 4, c. 46, banking copartnerships, 7 Geo. 4,
registered and carrying on "business under that act, and ^- ^^•
entitled to issue their own bank notes under the 7 & 8 Vict. 7 & 8 Vict.
c. 32, have certain powers and privileges of suing and being ^- ^-•
sued in the name of any one of their public officers, so long
as such copartnerships carry on business under the provisions
of the first-recited act : and whereas by the secondly-recited Section 2i.
act such copartnerships are empowered to agree with the
G-overnor and Company of the Bank of England to discon-
tinue the issue of bank notes, and it is thereby enacted, that
if any such banking copartnerships shall discontinue the issue
of bank notes, either by agreement with the Governor and
Company of the Bank of England or otherwise, it shall not
be lawful for such copartnerships at any time thereafter to
issue such notes: and whereas doubts are entertained whether Section 12,
the powers and privileges so given by the first-recited act will
extend to such of the said banking cojiartnerships as shall
discontinue the issue of bank notes, and shall afterwards com-
mence and carry on the trade or business of bankers in London,
or within 6.3 miles from London, in such manner as they will
then by law be authorized to do, and it is expedient that such
G. T T
642
APPENDIX OF STATUTES.
Banks dis-
coutiuuing
the issue of
bank notes
empowered
to sue and bo
sued by their
jDublic officer.
And not to
empower any
bank to carry
on business in
London.
doubts bo removed : bo it tliereforo declared and enacted as
follows :
1. From and after the passing of this act, every banking
copartnership registered and carrying on business under the
first-recited act, and entitled to issue their own bank notes
under the secondly-recited act, which shall discontinue the
issue of such bank notes, and shall afterwards commence and
carry on the trade or business of bankers in London, or within
G5 miles from London, in such manner as they shall be autho-
rized to do, shall have the same powers and privileges of suing
and being sued in the name of one of their public officers of
such copartnership, as the nominal plaintiif, petitioner, or
defendant, on behalf of such copartnership : and all judg-
ments, decrees and orders made and obtained in any such suit
may bo enforced in like manner as is provided by the first-
recited act with respect to copartnerships carrying on business
imder the provisions of that act : provided that nothing in
this act contained shall empower any copartnership to carry
on tlie trade or business of bankers in London, or within 6.5
miles therefrom, in any case where by the existing law they
are not authorized so to do.
Contracts for
sale, &c. of
sliaves to be
void unless
the numbers
by which
such sliares
arc distin-
guished are
set forth in
contract.
Sale and Purchase of Shares in Joint Sfoch Banking ■
Companies.
30 Vict. c. 29.
An Act to amend the Laio in respect of the Sale and Purchase
of Shares in Joint Stock Bankiiig Compa7}ies.
[17th Jimo, 1867.]
WiiEiiEAS it is expedient to make provision for the prevention
of contracts for the sale and purclmso of shares and stock in
joint stock banking companies of which the sellers are not pos-
sessed or over which they have no control : be it enacted, &c.
1. That all contracts, agreements, and tokens of sale and
purchase which shall, from and after the 1st day of July,
1867, be made or entered into for the sale or transfer, or pur-
porting to be for the sale or transfer, of any share or shares,
or of any stock or other interest, in any joint stock banking
company in the United Kingdom of Great Britain and Ireland
constituted under or regulated by the provisions of any act of
parliament, royal charter, or letters patent, issuing shares or
stock transferable by any deed or written instrument, shall bo
null and void to all intents and purposes whatsoever, imless
such contract, agreement, or other token shall set forth and
designate in writing such shares, stock, or interest by the
33 <) For 3 and 4 read 4 and .') (38 Vict. c. 13, s. 3). *
40 YicT. c. 2. C55
Treasury and Exchequer Bills.
40 Vict. c. 2.
An Act to provide for the Preparation, Issue, and Payment of
Treasury Bills, and make further Provision respectiny
Exchequer Bills. [IGtli March, 1877.]
Wheeeas it is expedient to provide for tlie issue of Treasury
bills in cases -u-here the issue of excliequer bills by tlio
treasury is authorized :
Be it therefore enacted by the Queen's most excellent
Majesty, by and with the advice and consent of the lords
spiritual and temporal, and commons, in this present parlia-
ment assembled, and by the authority of the same, as follows :
1. This act may be cited as the Treasury Bills Act, 1877. Short titles.
The act of the session of the twenty-ninth and thirtieth
years of the reign of her present Majesty, chapter twenty-
five, intituled "An Act to consolidate and amend the several
laws for regulating the preparation, issue, and payment of
exchequer bills and bonds," is in this act referred to and
may be cited as the Exchequer Bills and Bonds Act, 1866,
and that act and this act may be cited together as the Ex-
chequer and Treasury Bills Acts, 1866 and 1877.
2. In this Act, — _ _ Definitions.
The expression "Treasury" means the Commissioners of
Her Majesty's Treasury.
The expression "Bank of England" means the Governor
and Company of the Bank of Eng-land.
The expression ' ' Comptroller and Auditor General of the
receipt and issue of Her Majesty's Exchequer " includes, in
case of the illness or absence of the comptroller, the assistant
comptroller and auditor.
The expression "financial year " means the twelve months
beginning on the first day of April and ending on the following
thirty-first day of March.
The expression "prescribed" means prescribed by regula-
tions made under this act.
3. Where the Treasury have authority under any act of Raisin of
parliament (passed either before or after the passing of this money by
act) to raise money by the issue of exchequer bills or of treasmy
treasury bills, the treasury may, if they think fit, raise such bilis.
money or any part thereof by the issue of bills under this
act.
4. A bill under this act (referred to in this act as a trea- Form and
sury bill) shall bo a bill in the prescribed form, for the pay- length of
ment of the principal sum named therein in the manner and and ii!tei-est
at the date therein mentioned, so that the date be not on treasury
more than twelve months from the date of the bill. bills.
656
APPEXDIX OF STATUTES.
Payment of
proceeds of
treasury bill
into exche-
quer, and
cliarge of bill
on consoli-
dated fund.
Power to
issue exche-
quer bills or
treasury bills
in lieu of bills
paid off
during same
financial
year.
Application
of 38 & 39
Vict. c. 45,
ss. 3, .5, to
treasury
bills.
Mode of
issue of
treasury
bills.
Regulations
by treasury
as to prepa-
ration, issue,
Interest sliall bo payable in respect of a treasury bill at
such rate and in such manner as the treasury direct.
5. All money raised by the issue of any treasury bill shall
bo paid into the exchequer.
The principal money of and interest on any treasury bill
sliall be charged on and payable out of the consolidated fund
of the United Kingdom, or the growing produce thereof, at
the time and iu the manner prescribed.
6. AVhere in any financial year any exchequer bills or
treasury bills are or are about to bo paid off, the treasury
may, during that financial year, for the purpose of paying off,
or of replacing the amount expended (otherwise than out of
the new sinking fund) in paying off the principal money of
such bills, or of any of them, raise a sum not exceeding the
amount of such principal money by the issue of treasury bills
or of exchequer bills, or partly of treasiiry bills and partly
of exchequer bills, according as they think most beneficial
for the public service.
Where in any financial year any exchequer bills are paid
in for duties the treasury may during that financial year for
the purpose of replacing the principal money of such bills, or
any of them, raise a sum not exceeding the amount of such
principal money by the issue of treasury bills or of exchequer
bills, or partly of treasury bills and partly of exchequer bills,
according as they think most beneficial for the public service.
This section shall apply in the case of exchequer bills
issued before as well as of those issiied after the passing of
this act.
Section twelve of the Excliec[uer bills and Bonds Acts, 1866,
is hereby repealed, without prejudice to anything previously
done under that section.
7. Sections three and five of the Sinking Fund Act, 1875,
which relate to the application of the old and new sinking
funds, shall apply to treasury bills in like manner as if they
were excheqiier bills.
8. AVith respect to the issue of treasury bills the following
provisions shall have effect :
(1.) Treasury bills shall be issued by the bank of England
nnder the authority of a warrant from tlie treasury,
countersigned by the comptroller and auditor general
of the receipt and issue of her Majesty's excliccjuer ;
(2.) Each treasury bill shall be for the amount directed by
the treasury ;
(;].) Eacli treasury bill shall bo signed by the said comptroller
and auditor general in his own name.
9. Tlie treasury may from time to time make, and when
made rescind, alter, and add to, regulations for carrying into
oifect this act, and in particular —
40 Vict. c. 2. 057
(1.) For regulating (subject to the provisions of this act) and cancoUa-
the preparation, form, mode of issue, mode of pay- tion of and
ment, and cancellation of treasury hills ; ?!!°^?^*^!T
(2.) For regulating- the issue of a no\\^ hill in lieu of one Treasury
defaced, lost, or destroyed ; and bilk.
(3.) For preventing, hy the use of counterfoils or of a special
description of paper or otherwise, fraud in relation to
treasurjr hills ; and
(4.) For the proper discharge to he given upon the payment
of a treasury hill.
Every regulation under this act shall ho laid before both
houses of parliament within one month after it is made, if
parliament he then sitting, or if not, within one month after
the then next meeting of parliament.
Every regulation purporting to be made in pursuance of
this section shall be deemed to be within the powers of this
act, and shall have effect as if it were enacted in this act.
10. Sections eight, nine, ten, and eleven of the act of the Application
twenty-fourth and twenty-fifth years of the reign of her pre- to Treasury-
sent Majesty, chapter ninety-eight, intituled " An act to con- ^4. ^ 95 yjct
solidate and amend the statute law of England and Ireland <,_ gg ss. 8
relating to indictable offences hy forgery," (which sections 11, relating
relate to the forgery of and other frauds relating to exchequer to forgery
hills,) shall apply to treasury bills, and shall have effect as if ^^^ other
" exchequer bill " in those sections included " treasury bill."
11. There shall be paid to the Bank of England out of the Payment to
consolidated fund of the United Kingdom, or out of the ^^^^ °^, „
growing produce thereof, for the management of the un- n^aua^ment
redeemed public debt in treasury bills for the year commenc- ^nd expenses,
ing on the first day of December one thousand eight hundred
and seventy-seven, an allowance at the rate of one hundred
pounds for every million of treasury bills outstanding on that
da}"-, and such payment shall be made on the first day of
December one thousand eight hundred and seventy-eight,
and the allowance for the management of treasury bills shall
he computed and paid in like manner in every succeeding
year until parliament otherwise direct.
The treasury shall also on the application of the Bank of
England reimburse out of the consolidated fund, or the
growing produce thereof, any expenses incurred by the Bank
of England for paper and printing in respect of the issue of
treasury bills.
12. Where any act passed before the passing of this act Application
authorizes the raising of money by exchequer bills, and the o^. '"^^ ^ ^^,
interest on such exchequer bills is in pursuance of the direc- . V^ " ^1 '^' *^
PI rri- -nTAi^i)-- ii interest on
tions 01 that act, or 01 the bmlang inind Act, Ib/o, payable and allow -
out of the permanent annual charge for the national debt, auce for
G. U U
658
APPENDIX OF STATUTES.
management
of treasury
bills.
the interest on treasury bills issued to raise tlio said money
shall be paid out of the said permanent annual charge.
The allowance and expenses paid to the Bank of England
in pursuance of this act shall be deemed to be loart of the
annual sums payable for the management of the national
debt within the meaning of the Sinking Fund Act, 1875, and
shall be paid accordingly out of the permanent annual charge
for the national debt.
13. The Bank of England may lend to her Majesty, upon
England may q^q credit of treasury bills, any sum or sums not exceeding in
o7tL°a'su?y'^^*^ whole the principal sums named in such bills.
bills.
Bank of
Stock certifi-
cate to
bearer.
Stamp duty
on stock cer-
tificate to
bearer.
Colonial Stocli.
40 & 41 Vict. c. 59.
An Act to amend the Law with respect to the Transfer of Stock
formincj part of the Public Debt of any Colony, and the
Stanij} Duty on such Transfer. [14th August, 1877.]
7. The registrar, if so authorized by the government of a
colony issuing stock to which this act applies, shall on appli-
cation and payment of the fees and stamp duty, if any, charge-
able in respect of the certificate, grant to a stockholder a
certificate (in this act called a stock certificate to bearer) which
shall entitle the bearer to the stock therein described, and
shall be transferable by delivery.
There shall be attached to such certificate coupons entitling
the bearer of or person named in the coupons to the dividends
on the stock for a limited period.
An}^ stock in respect of which a stock certificate to bearer
has been so issued shall, so long as such certificate is out-
standing, cease to be dealt with through the medium of the
register.
A coupon so issued shall be deemed to be a cheque on a
banker within the meaning of any law or enactment for the
time being in force relating to cheques other than any enact-
ment relating to stamp duties.
8. Where a composition has not been paid in respect of the
stamp duty chargeable on the transfer of any stock to which
this act applies, a stock certificate to bearer issued in respect
of that stock shall be charged with a stamp duty of two
shillings and sixpence for every full sum of one hundred
pounds, and also for every fraction less than one hundred
pounds, or over and above one hundred pounds or a multiple
of (mo hundred pounds, of the nominal amount of stock
described in such certificate.
40 & 41 YiGT. c. 59. G59
9. On tlie expiration of the period for whieli tlie coupons Renewal of
fittaclied to a stock certiiieate to bearer liave been issued under coupons or
this act, the certificate may be exchanged for another certifi- certificate,
cate with couj^ons for a further period : Provided, that the
certificate issued in exchange, if the stamp duty has not been
compounded, shall be duly stamped, but in such case the
Commissioners of Inland Revenue shall, on production to
them of both certificates duly stamped, and subject to such
regulations as they may from time to time make, grant
allowance for the stamp on the former certificate.
10. On delivery to the registrar of a stock certificate to Conversion
bearer issued under this act, and of all unpaid coupons mto nommal
belonging thereto, the registrar shall enter the bearer in the iii°cert*ificate
register as proprietor of the stock described in the certificate, to bearer,
and thereupon that stock shall become transferable and the
dividends thereon payable as if no stock certificate to bearer
had been issued in respect of that stock.
11. If the bearer of a stock certificate to bearer issued Conversion of
xxnder this act insert therein the name, address, and quality of stock certifi-
CJIlG to DGS.I'Ol"*
some person, such certificate shall cease to be transferable, j^^^q nominal
and the person so named, or some person deriving title from certificate.
him by devolution in law, shall alone be recognized by the
registrar as entitled to the stock described in the certificate,
and shall be entitled to be entered in the register as pro-
l^rietor of that stock in like manner as if he were the bearer
of a stock certificate to bearer, but if deriving his title by
devolution in law he shall produce such evidence of his title
as the registrar may reasonably require.
12. A trustee shall not apply for or hold a stock certificate Trustee not
to bearer issued under this act unless expressly authorized to to ^W^Y ^p^'
do so by the terms of his trust. But this provision shall not ^!^°e\o®'"*^^^^"
impose on the registrar an obligation to inc[uire whether a Nearer,
person applying for a stock certificate to bearer is or is not a
trustee, or subject the registrar to any liability in the event
of his issuing a stock certificate to bearer to a trustee, or in-
validate any stock certificate to bearer issued.
13. If any stock certificate to bearer issued under this act Loss of stock
is lost, mislaid, or destroyed, the registrar shall, on such certificate to
indemnity being given as he may reasonably require, and on ^^^^^'
payment of the expense of the issue, issue a fresh stock certi-
ficate to bearer in the place of the certificate so lost, mislaid,
or destroyed. g, , .
14. Stock described in a stock certificate to bearer issued tificate to
under this act shall, save as relates to the mode of transfer bearer to
and payment of dividends, be subject to the same incidents in bave inci-
all respects as if it had continued to be transferable in the *\^"*^ °* °*^^f
. , '- stock, except
register. as to transfer,
u u 2 - ''''■■
660
APPENDIX OF STATUTES.
Forgery of
transfers of
stock and of
stock certifi-
cates, and
personation
of owners of
stock, &c.
33 & 34 Vict.
c. 58.
Stock to
which act
applies to be
personal
estate.
21. For tlie purposes of the act of tlie session of tlie
twenty-fourtli and twenty -fifth years of the reign of her pre-
sent Majesty, chapter ninety-eight, intituled " An Act to con-
solidate and amend the statute law of England relating to
indictahlo offences by forgery," colonial stock to which this
act applies shall be deemed to be capital stock of a body
corporate.
The Forgery Act, 1870, shall apjDly to a stock certificate
and a coupon issued in pursuance of this act, and to colonial
stock to which this act a^ox^lies, in like manner as if the same
were a stock certificate, coupon, or stock mentioned in that
act.
22. Colonial stock to which this act applies shall be personal
estate, and shall not be liable to any foreign attachment by
the custom of London or otherwise.
Short title.
Commence-
ment.
Application
of act.
Interpreta-
tion of terms
Bills of Sale Act, 1878.
41 & 42 Vict. c. 31.
An Act to consolidate and amend the Laio for prcventinff Frauds
upon Creditors hii secret Bills of Sale of Personal Chattels.
r22nd July, 1878.]
AVhereas it is expedient to consolidate and amend the law
relating to bills of sale of personal chattels :
Be it enacted by the Queen's most excellent -majesty, by
and with the advice and consent of the lords spiritual and
temporal, and commons, in this present parliament assembled,
and by the authority of the same, as foUows :
1. This act may be cited for all purposes as the Bills of
Sale Act, 1878.
2. Tliis act shall come into operation on the first day_ of
January one thousand eight hundred and seventy-nine, which
day is in this act referred to as tlie commencement of this act.
3. This act shall apply to every bill of sale executed on or
after the first day of January one thousand eight himdred and
seventy-nine (whether the same be absolute, or subject or not
subject to any trust) whereby the holder or grantee has
power, either with or without notice, and either immediately
or at any future time, to seize or take possession of_ any
personal chattels comprised in or made subject to such bill of
sale.
4. In this act the following words and expressions shall
have the meanings in this section assigned to them respec-
tively, unless there be something in the subject or context
repugnant to such construction ; (tliat is to say,)
The expression "bill of sale" sliall include bills of sale,
41 &42 YicT. c. 31. 661
assignments, transfers, declarations of trust without trans-
fer, inventories of goods with receipt thereto attached,
or receipts for purchase-mone3-s of goods, and other
assurances of personal chattels, and also powers of
attorney, authorities, or licenses to take possession of
personal chattels as security for any debt, and also any
agreement, whether intended or not to be followed by
the execution of any other instrument, by which a right
in equity to any personal chattels, or to any charge or
security thereon, shall be conferred, but shall not include
the following documents ; that is to say, assignments for
the benefit of the creditors of the person making or
giving the same, marriage settlements, transfers or as-
signments of any ship or vessel or any share thereof,
transfers of goods in the ordinary course of business of
any trade or calling, bills of sale of goods in foreign
parts or at sea, bills of lading, India warrants, ware-
house-keepers' certificates, Avarrants or orders for the
delivery of goods, or any other documents used in the
ordinary course of business as proof of the possession or
control of goods or authorizing or purporting to authorize,
either by indorsement or by delivery, the possessor of
such document to transfer or receive goods thereby repre-
sented :
The expression "personal chattels" shall mean goods,
furniture, and other articles capable of complete transfer
by delivery, and (when separately assigned or charged)
fixtures and gi-owing crops, but shall not include chattel
interests in real estate, nor fixtures (except trade ma-
chinery as hereinafter defined), when assigned together
with a freehold or leasehold interest in any land or
building to which they are affixed, nor growing crops
when assigned together with any interest in the land on
which they grow, nor shares or interests in the stock,
funds, or securities of any government, or in the capital
or property of incorporated or joint stock companies, nor
choses in action, nor any stock or produce upon any farm
or lands which by virtue of any covenant or agreement
or of the custom of the country ought not to be removed
from any farm where the same are at the time of making
or giving of such bill of sale :
Personal chattels shall be deemed to be in the "apparent
possession" of the person making or giving a bill of sale,
so long as thev remain or are in or upon any house, mill,
warehouse, building, works, yard, land, or other premises
occupied by him, or arc used and enjoyed by liim in any
place whatsoever, notwithstanding that formal possession
thereof may have been taken by or given to any other
person :
662
APPENDIX OF STATUTES.
Application
of act to
trade ma-
chinery.
Certain in-
struments
giving
powers of
distress to be
subject to
this act.
''Prescribed" means prescribed by rules made under the
provisions of this act.
5. From and after the commencement of this act trade
machinery shall, for the purposes of this act, be deemed to be
personal chattels, and any mode of disposition of trade ma-
chinery by the owner thereof which would be a bill of sale as
to any other personal chattels shall be deemed to be a bill of
sale within the meaning of this act.
For the purposes of this act —
** Trade machinery " means the machinery used in or
attached to any factory or workshop ;
1st. Exclusive of the fixed motive-powers, such as
the water-wheels and steam engines, and the
steam-boilers, donkey engines, and other fixed
appurtenances of the said motive-powei-s ; and,
2nd. Exclusive of the fixed power machinery, such
as the sliafts, wheels, drums, and their fixed
appurtenances, which transmit the action of the
motive-powers to the other machinery, fixed and
loose ; and,
3rd. Exclusive of the pipes for steam, gas, and water
in the factory or workshop.
The machinery or effects excluded by this
section from the definition of trade machinery
shall not be deemed to be personal chattels
within the meaning of this act.
" Factory or workshop " means an}^ premises on which
any manual labour is exercised by way of trade, or for
purposes of gain, in or incidental to the following pur-
poses or any of them ; that is to say,
(«.) In or incidental to the making any article or part
of an article ; or
(Zi.) In or incidental to the altering, repairing, orna-
menting, finishing, of any article ; or
(c.) In or incidental to the adapting for sale any
article.
6. Every attornment, instnmient, or agreement not being a
mining lease, whereby a power of distress is given or agreed
to be given by any person to any other person by way of
security for any present, future, or contingent debt or advance,
and whereby any rent is reserved or made payable as a mode
of providing for the payment of interest on such debt or ad-
vance, or otlierwise for the purpose of such security only, shall
be deemed to be a bill of sale, within the meaning of this
act, of any personal chattels which may be seized or taken
under such power of distress.
Provided, that nothing in this section shall extend to any
mortgage of any estate or interest in any land, tenement, or
hereditament which the mortgagee, being in possession, shall
41 & 42 Vict. c. 31. 663
have demised to the mortgagor as his teuaut at a fair and
reasonable rent.
7. No fixtures or growing crops shall be deemed, under this Pixtures or
act, to be separately assigned or charged by reason only that growing
they are assigned by separate Avords, or that power is given ?^°^^ °°* ,*''
to sever them from the land or building to which they are separately
affixed, or from the land on which they grow, without other- assi"-ned
wise taking possession of or dealing Avith such land or build- when the
ing, or land, if by the same instrument any freehold or lease- ^^^^ passes
hold interest in the land or building- to which such fixtures are py /^"® ^^^2°
XT n • xi 1 1 1-11 -1 msti-iiment.
anixed, or m tne land on wnicn sucn crops grow, is also con-
veyed or assigned to the same persons or person.
The same rule of construction shall bo applied to all deeds
or instruments, including fixtures or growing crops, executed
before the commencement of this act and then subsisting and
in force, in all questions arising under any bankruptcy, liqui-
dation, assignment for the benefit of creditors, or execution of
any process of any court, which shall take place or be issued
after the commencement of this act.
8. Every bill of sale to whicli this act applies shall be duly Avoidance of
attested and shall be registered under this act, within seven unregistered
days after the making or giving thereof, and shall set forth "^ _ . ®^^® -"^
tue consideration tor wnicfi such, bill oi sale was given, other-
wise such bill of sale, as against all trustees or assignees of
the estate of the person whose chattels, or any of them, are
comprised in such bill of sale under the law relating to
bankruptcy or liquidation, or under any assignment for the
benefit of the creditors of such person, and also as against all
sheriffs officers and other persons seizing any chattels com-
prised in such bill of sale, in the execution of any jirocess of
any court authorizing the seizure of the chattels of the j^erson
by whom or of whose chattels such bill has been made, and
also as against every person on whose behalf such process
shall have been issued, shall be deemed fraudulent and void
so far as regards the propert}^ in or right to the possession of
any chattels comprised in such bill of sale which, at or after
the time of filing the petition for bankruptcy or liquidation, or
of the execution of such assignment, or of executing such
process (as the case may be), and after the expiration of such
seven days are in the possession or apparent possession of the
person making such bill of sale (or of any person against
whom the process has issued under or in the execution of
which such bill has been made or given, as the case may be).
9. Where a subsequent bill of sale is executed within or on Avoidance of
the expiration of seven days after the execution of a prior certain dupli-
unregistered bill of sale, and comprises all or any part of the ^^j^ ^ ® ^
personal chattels comprised in such prior bill of sale, then, if
such subsequent bill of sale is civen as a sccuritv for the same
664: APPENDIX OF STATUTES.
debt as is SGCurecI by the prior bill of sale, or for any part of
sueb. debt, it shall, to the extent to which it is a security for
the same debt or part thereof, and so far as respects the per-
sonal chattels or part thereof comprised in the prior bill, be
absolutely void, unless it is proved to the satisfaction of the
court having cognizance of the case that the subsequent bill
of sale was bona fide given for the purpose of correcting some
material error in the prior bill of sale, and not for the purpose
of evading this act.
Mode of re- 10. A bill of sale shall be attested and registered under
gistering' bills tj^fg ^ct in the following manner :
° ^^ ^' (1.) The execution of every bill of sale shall be attested by
a solicitor of the supreme court, and the attestation
shall state that before the execution of the bill of sale
the effect thereof has been explained to the grantor
by the attesting solicitor :
(2.) Such bill, with every schedule or inventory thereto
annexed or therein referred to, and also a true copy
of such bill and of every such schedule or inventory,
and of every attestation of the execution of such bill
of sale, together with an affidavit of the time of such
bill of sale being made or given, and of its due exe-
cution and attestation, and a description of the resi-
dence and occupation of the person making or giving
the same (or in case the same is made or given by
any person under or in the execution of any process,
then a description of the residence and occupation of
the person against whom such process issued), and of
every attesting witness to such bill of sale, shall be
presented to and the said copy and affidavit shall be
filed with the registrar within seven clear days after
the making or giving of such bill of sale, in like
manner as a warrant of attorney in any personal
action given by a trader is now by laAV required to
be filed :
(3.) If the bill of sale is made or given subject to any de-
feasance or condition, or declaration of trust not
contained in the body thereof, such defeasance, con-
dition, or declaration shall be deemed to be part of
the bill, and shall be written on the same paper or
parchment therewith before the registration, and
shall be truly set forth in the copy filed under this
act therewith and as part thereof, otherwise the
registration shall be void.
In case two or more bills of sale are given, com2:)rising in
whole or in part any of the same chattels, they shall have
priority in the order of the date of their registration respec-
tively as regards such chattels.
41 & 42 YicT. c. 31. 665
A transfer or assigumeut of a registered bill of sale need
not be registered.
11. The registration of a bill of sale, whether executed Renewal of
before or after tlie commencement of this act, must be re- registration,
newed once at least every five years, and if a period of five
years elapses from the registration or renewed registration of
a bill of sale without a renewal or further renewal (as the case
may be), the registration shall become void.
The renewal of a registration shall be effected by filing
with the registrar an affidavit stating the date of the bill of
sale and of the last registration thereof, and the names, resi-
dences, and occupations of the parties thereto as stated there-
in, and that the bill of sale is still a subsisting security.
Every such affidavit may be in the form set forth in the
schedule (A.) to this act annexed.
A renewal of registration shall not become necessary by
reason only of a transfer or assignment of a bill of sale.
12. The registrar shall keep a book (in this act called "the Form of
register ") for the purposes of this act, and shall, upon the register,
filing of any bill of sale or copy under this act, enter therein
in the form set forth in the second schedule (B.) to this act
annexed, or in any other prescribed form, the name, resi-
dence, and occupation of the person by whom the bill was
made or given (or in case the same was made or given by any
person under or in the execution of process, then the name,
residence, and occupation of the person against whom such
process was issued, and also the name of the person or per-
sons to whom or in whose favour the bill was given), and the
other particulars shown in the said schedule or to be pre-
scribed under this act, and shall number all such bills regis-
tered in each year consecutively, according to the respective
dates of their registration.
Upon the registration of any affidavit of renewal the like
entry shall be made, with the addition of the date and number
of the last previous entry relating to the same bill, and the
bill of sale or copy originally filed shall be thereupon marked
with the nimiber affixed to such affidavit of renewal.
The registrar shall also keep an index of the names of the
grantors of registered bills of sale with reference to entries in
the register of the bills of sale given by each such grantor.
Such index shall be arranged in divisions corresponding
with the letters of the alphabet, so that all grantors whose
surnames begin with the same letter (and no others) shall be
comprised in one division, but the arrangement within each
such division need not be strictly alphabetical.
13. The masters of the Supreme Court of Judicatiue The registrar,
attached to the Queen's Bench Division of the High Court of
Justice, or such other officers as may for the time being be
666
APPENDIX OF STATUTES.
36 & 37 Vict.
c. 66.
38 & 39 Vict.
c. 77.
Rectification
of refcister.
Entry of
satisfaction.
Copies may-
be taken, &c.
Affidavits.
Fees.
assigned for this purpose under the provisions of the Supreme
Court of Judicature Acts, 1873 and 1875, shall be the registrar
for the purposes of this act, and any one of the said masters
may perform all or any of the duties of the registrar.
14. Any judge of the High Court of Justice on being satis-
fied that the omission to register a bill of sale or an affidavit
of renewal thereof within the time prescribed by this act, or
the omission or misstatement of the name, residence, or
occupation of any person, was accidental or due to inadvert-
ence, may in his discretion order such omission or misstate-
ment to be rectified by the insertion in the register of the true
name, residence, or occupation, or by extending the time for
such registration on such terms and conditions (if any) as to
security, notice by advertisement or otherwise, or as to any
other matter, as he thinks fit to direct.
15. Subject to and in accordance with any rules to be made
under and for the purposes of this act, the registrar may order
a memorandum of satisfaction to be written upon any regis-
tered copy of a bill of sale, upon the prescribed evidence
being given that the debt (if any) for which such bill of sale
was made or given has been satisfied or discharged.
16. Any person shall be entitled to have an office copy or
extract of any registered bill of sale, and affidavit of execution
filed therewith, or copy thereof, and of any affidavit filed
therewith, if any, or registered affidavit of renewal, upon
paying for the same at the like rate as for office copies of
judgments of the High Court of Justice, and any copy of a
registered bill of sale, and affidavit purporting to be an office
copy thereof, shall in all Courts and before all arbitrators or
other persons, bo admitted as prima facie evidence thereof,
and of the fact and date of registration as shown thereon.
Any person shall bo entitled at all reasonable times to search
the register and every registered bill of sale, upon payment of
one shilling for every copy of a bill of sale inspected ; such
payment shall be made by a judicature stamp.
17. Every affidavit required by or for the purposes of this
act may be sworn before a master of any division of the High
Court of Justice, or before any commissioner empowered to
take affidavits in the Supreme Court of Judicature.
Whoever wilfully makes or uses any false affidavit for tho
purposes of this act shall be deemed guilty of wilful and
corrupt perjury.
18. There shall be paid and received in common law stamps
the following fees, viz. :
On filing a bill of sale 2s.
On filing the affidavit of execution of a bill of sale 2s.
On tlie affidavit used for tho purpose of re-regis-
tering a bill of sale (to include the fee for filing) os.
41 & 42 Vict. c. 31. 667
19. Section twenty-six of the Supreme Court of Judicature CoUeGtion of
Act, 1875, and any enactments for the time being- in force fees under
amending- or substituted for that section, shall apply to fees ^8 & 39 Vict,
under this act, and an order under that section may, if need • ' • •
be, be made in relation to such fees accordingly.
20. Chattels comprised in a bill of sale which has been and Order and
continues to be duly registered under this act shall not be disposition,
deemed to be in the possession, order, or disposition of the
grantor of the bill of sale within the meaning- of the Bank- 32 & 33 Vict,
ruptcy Act, 1869. c. 71.
21. Eules for the purposes of this act may be made and Rules,
altered from time to time by the like persons and in the like ^^ ^ ^^ y.^^
manner in which rules and regulations may be made under ^ qq
and for the purposes of the Supreme Court of Judicature Acts, 38 & 39 Vict.
1873 and 1875. _ c. 77.
22. AVhen the time for registering a bill of sale expires on Time for re-
a Sunday, or other day on which the registrar's office is closed, gistration.
the registration shall be valid if made on the next following
day on which the office is open.
23. From and after the commencement of this act, the Bills Repeal of
of Sale Act, 1854, and the Bills of Sale Act, 1866, shaU bo acts.
repealed: Provided that (except as is herein expressly men- 17 & 18 Vict,
tioned with respect to construction and with respect to renewal ^g'^^'gQ y-^^
of registration) nothing in this act shall affect any bill of sale ~^ ^o.
executed before the commencement of this act, and as regards
bills of sale so executed the acts hereby repealed shall con-
tinue in force.
Any renewal after the commencement of this act of the
registration of a bill of sale executed before the commence-
ment of this act, and registered under the acts hereby repealed,
shall be made under this act in the same manner as the re-
newal of a registration made under this act.
24. This act shall not extend to Scotland or to Ireland. Extent of
act.
SCHEDULES.
Schedule (A). Section 11.
I [u4. I?.] of do swear that a bill of sale, bearing date
the day of 18 [insert the date of the hiW], and made
between \_insert the names and descriptions of the parties in the original
bill of sale'], and which said bill of sale [or, and a copy of which
said bill of sale, as the case may 6e] was registered on the day
of 18 linsert date of registration'], is still a subsisting security.
Sworn, (Oc.
668
Section 12.
ArPENDlX OF STATUTES.
Schedule (B).
Satis-
faction
entered.
No.
By whom given (or against
■whom process issued).
Name.
Resi-
dence.
Occu-
pation.
To
■whom
given.
Nature
of
Instru-
ment.
Date.
Date of
registra-
tion.
Date of
registra-
tion of
affidavit
of
renewal.
Short title.
Repeal of
39 & 40 Vict.
c. 48.
Mode of proof
of entries in
bankers'
books.
Proof that
book is a
banker's
books.
Verification
of copy.
Baitlrrs' Books Evidence Act, 1879.
42 Vict. c. 11.'
An Act to amend the Law of Evidence ivith respect to Bajikers'
Books. [23rd May, 1879.]
Be it enacted by the Queen's most excellent majesty, by and
with the advice and consent of the lords spiritual and tem-
poral, and commons, in this present parliament assembled,
and by the authority of the same, as follows :
1. This act may be cited as the Bankers' Books Evidence
Act, 1879.
2. The Bankers' Books Evidence Act, 1876, shall be repealed
as from the passing of this act, but such rejoeal shall not affect
anything which has been done or happened before such repeal
takes effect.
3. Subject to the provisions of this act, a copy of any entry
in a banker's book shall in all legal proceedings be received
as prima facie evidence of such entry, and of the matters,
transactions, and accounts therein recorded.
4. A copy of an entry in a banker's book shall not be re-
ceived in evidence under this act unless it be first proved that
the book was at the time of the making of the entry one of the
ordinary books of the bank, and that the entry was made in
the usual and ordinary course of business, and that the book
is in the custody or control of the bank.
Such proof may be given by a partner or officer of the bank,
and may be given orally or by an affidavit sworn before any
commissioner or person authorized to take affidavits.
5. A copy of an entry in a banker's book shall not be re-
ceived in evidence under this act unless it be further proved
that the copy has been examined with the original entry and
is correct.
Such proof shall be given by some person who has examined
42YicT. c. 11. GG9
tlie copy with the original entry, and may be given either
orally or by an affidavit sworn before any commissioner or
person authorized to take affidavits.
6. A banker or officer of a bank shall not, in an}' legal Case in which
proceeding to which the bank is not a party, be compellable banker, &c.
to produce any banker's book the contents of which can be "°|T*^f{^x
proved under this act, or to appear as a witness to prove the produce book
matters, transactions, and accounts therein recorded, unless by &c.
order of a judge made for special cause.
7. On the application of any jiarty to a legal proceeding a Court or
court or judge may order that such party be at liberty to in- judge may
spectand take copies of any entries in a banker's book for any order inspec-
of the purposes of such proceedings. An order under this '
section may be made either with or without summoning the
bank or any other party, and shall be served on the bank
three clear days before the same is to be obeyed, unless the
com't or judge otherwise directs.
8. The costs of any application to a court or judge under or Costs,
for the 23urposes of this act, and the costs of anything done
or to be done under an order of a court or judge made under
or for the purposes of this act shall be in the discretion of
the court or judge, who may order the same or any part
thereof to be paid to any party by the bank, where the same
have been occasioned by any default or delay on the part of
the bank. Any such order against a bank may be enforced
as if the bank was a i:)arty to the proceeding.
9. In this act the expressions " bank" and "banker" mean Interpreta-
any person, persons, partnership, or company carrying on the tio'i of
business of bankers and having duly made a return to the !!{:*^°u' »>
Commissioners of Inland Eevenue, and also any savings bank ^ud "bank-
certified under the acts relating to savings banks, and also any ers' books."
post office savings bank.
The fact of any such bank having didy made a return to the
Commissioners of Inland lievenue may be proved in any legal
proceeding by production of a copy of its return verified by
the affidavit of a partner or officer of the bank, or by the pro-
duction of a copy of a newspaper purporting to contain a copy
of such return published by the Commissioners of Inland
lievenue ; the fact that any such savings bank is certified
under the acts relating to savings banks may be proved by
an office or examined copy of its certificate ; the fact that
any such bank is a post office savings bank may be proved
by a certificate purporting to be under the hand of her
Majestv's Postmaster-General or one of the secretaries of the
Post Office.
Expressions in this act relating to "bankers' books" in-
clude ledgers, day books, cash books, account books, and all
other books used in the ordinary business of the bank.
C70
APPENDIX OF STATUTES.
Interpreta-
tion of "legal
proceeding,"
' ' court, ' '
"judge."
Computation
of time.
10. In this act —
The expression " legal proceeding" means any civil or
criminal proceeding or inc[uiry in which evidence is
or may be given, and includes an arbitration ;
The expression "the court" means the court, judge,
arbitrator, persons, or person before whom a legal
proceeding is held or taken ;
The expression "a judge" means with respect to
England a judge of the High Court of Justice, and
with respect to Scotland a lord ordinary of the Outer
House of the Court of Session, and with respect to
Ireland a judge of the High Court of Justice in
Ireland ;
The judge of a county court may with respect to any action
in such court exercise the powers of a judge under this act.
11. Suuda}', Christmas Day, Good Friday, and any bank
holiday shall be excluded from the computation of time under
this act.
Short title.
Act not to
apply to Bank
of England.
Act to be con-
strued with
25 & 2G Vict.
c. 89,
30 & 31 Vict.
c. 131, and
40 &41 Vict.
c. 26.
Registration
anew of com-
pany.
25 & 26 Vict.
c. 89.
30 & 31 Vict.
c. 131.
40 & 41 Vict.
c. 20.
Companies Act, 1879.
42 & 43 YiCT, c. 7G.
An Act to amend the Laiv icith respect to the LkibiUty of
Members of Bunldng and other Joint Stock Companies ;
and for other purposes. [15th August, 1879.]
Be it enacted by the Queen's most excellent majesty, by and
with the advice and consent of the lords spiritual and tem-
23oral, and commons, in this present parliament assembled,
and by the authority of the same, as follows :
1. This act may be cited as the Companies Act, 1879.
2. This act shall not apply to the Bank of England.
3. This act shall, so far as is consistent with the tenor
thereof, be construed as one with the Companies Acts, 18G2,
1867', and 1877, and those acts together with this act may be
referred to as the Companies Acts, 18G2 to 1879.
4. Subject as in this act mentioned, any company registered
before or after the passing of this act as an unlimited com-
pany may register under the Companies Acts, 18G2 to 1879, as
a limited company, or any company already registered as a
limited company may re-register under the provisions of this
act.
The registration of an unlimited company as a limited com-
pany in pursuance of this act shall not affect or prejudice any
debts, liabilities, obligations, or contracts incurred or entered
into by, to, with, or on behalf of such company prior to regis-
tration, and such debts, liabilities, contracts, and obligations
42 & 43 Vict. c. 70. . 671
may be enforced in manner provided by Part Til. of tlio 42 k 43 Vict.
Companies Act, 1862, in the case of a company registering in c. 76.
pursuance of tliat part. 25 & 26 Vict.
5. An imlimited company may, by tlie resolution passed by ^- ^^•
the members Avben assenting to registration as a limited com- Reserve
pany under the Companies Acts, 1862 to 1879, and for the capital of
purpose of such registration or otherwise, increase the nominal how provided
amount of its capital by increasing the nominal amoimt of .-,. ._ .-,, „.
each of its shares. ~ 89 "
Provided always, that no part of such increased capital 30 & 31 Vict,
shall be capable of being called up, except in the event of and c. 131.
for the purposes of the company being wound up. ^^ ^ '^^ "Vict.
And, in cases where no such increase of nominal capital % ^/^3 y- f
may be resolved upon, an unlimited company may, by such cr76.
resolution as aforesaid, provide that a portion of its uncalled
capital shall not be capable of being called up, except in the
event of and for the purposes of the company being wound up.
A limited company may by a special resolution declare that
any portion of its capital which has not been already called up
shall not be capable of being called up, except in the event
of and for the purpose of the company being wound up ; and
thereupon such portion of capital shall not be capable of being
called up, except in the event of and for the purposes of the
company being wound up.
6. Section one hundred and eighty-two of the Companies 25 & 26 Vict.
Act, 1862, is hereby repealed, and in place thereof it is c. 89, s. 182,
enacted as follows : — A bank of issue registered as a limited j".*^!?*^'^. ' ^°^
company, either before or after the passing of this act, shall tauk^of issue
not be entitled to limited liability in respect of its notes ; and unlimited in
the members thereof shall continue liable in respect of its respect of
notes in the same manner as if it had been registered as an ^otes.
unlimited company ; but in ease the general assets of the
company are, in the event of the company being wound up,
insuiflcient to satisfy the claims of both the noteholders and
the general creditors, then the members, after satisf jdng the
remaining demands of the note-holders, shall be liable to
contribute towards payment of the debts of the general cre-
ditors a sum equal to the amount received by the note-holders
out of the general assets of the company.
Por the purposes of this section the expression "the general
assets of the company " means the funds available for pay-
ment of the general creditor as well as the note-holder.
It shall be lawful for any bank of issue registered as a
limited company to make a statement on its notes to the effect
that the Hmited liability does not extend to its notes, and that
the members of the company continue liable in respect of its
notes in the same manner as if it had been registered as an
unlimited company.
672
APPENDIX OF STATUTES.
Audit of
accounts of
banking
comj)anies.
Signature of
balance sbcet.
Application of
25 & 26 Vict.
c. 89,
30 & 31 Vict.
c. 131, and
40 &41 Vict.
c. 26.
7. (1.) Once at the least ill every year the accounts of every
banking company registered after the passing of this act as a
limited company shall be examined by an auditor or auditors,
who shall be elected annually by the company in general
m.eeting.
(2.) A director or officer of the company shall not be capable
of being elected auditor of such company.
(3.) An auditor on ciuitting office shall bo re-eligible.
(4.) If any casual vacancy occurs in the office of any auditor
the surviving auditor or auditors (if any) may act, but if there
is no surviving auditor, the directors shall forthivith call an
extraordinary general meeting for the purpose of sux^plying
the vacancy or vacancies in the auditorship.
(.3.) Every auditor shall have a list delivered to him of all
books kept by the company, and shall at all reasonable times
have access to the books and accounts of the company ; and
any auditor may, in relation to such books and accounts,
examine the directors or any other officer of the company :
provided that if a banking company has branch banks be-
yond the limits of Europe, it shall be sufficient if the auditor
is allowed access to such copies of and extracts from the
books and accounts of any such branch as may have been
transmitted to the head office of the banking company in the
United Kingdom.
(6.) The auditor or auditors shall make a report to the
members on the accounts examined by him or them, and on
every balance sheet laid before the company in general meet-
ing during his or their tenure of office ; and in every such
report shall state whether, in his or their opinion, the balance
sheet referred to in the report is a full and fair balance sheet
properly drawn up, so as to exhibit a true and correct view
of the state of the company's affairs, as shown by the books
of the company ; and such report shall be read before the
company in general meeting.
(7.) The remuneration of the auditor or auditors shall be
fixed by the general meeting appointing such auditor or
auditors, and shall be paid by the company.
8. Every balance sheet submitted to the annual or other
meeting of the members of every banking company registered
after the passing of this act as a limited company shall be
signed by the auditor or auditors, and by the secretary or
manager" (if any), and by the directors of the company, or
thi-ee of such directors at the least.
9. On the registration, in pursuance of tliis act, of a com-
pany wliich has been already registered, the registrar shall
make provision for closing the former registration of the
company, and may dispense with the delivery to him of
copies of any dociimcnts with copies of which he was fur-
43VicT. c. 11. 373
nishecl on the occasion of the original registration of the
company; but, save as aforesaid, the registration of such a ,,"^ *^ "
company shall take place in the same manner and have the ', " ' ^
same effect as if it were the first registration of that company ~'^ ^'^ ~ ^° "
under the Companies Acts, 1862 to 1879, and as if the provi- 30 .fc'si Vict,
slons of the acts under which the company -was previously c. 131,
registered and regulated had been contained in different acts 40 & 41 Vict.
of parliament from those under -which the company is regis- ^l^^i^'/o y- ^
tered as a limited company. c^'G.
10. A company authorised to register under this act may p . ., ^ »
register thereunder and avail itself of the privileges conferred ^^j. available
by this act, notwithstanding any provisions contained in any notwith-
act of parliament, royal charter, deed of settlement, contract standing con-
of copartnery, cost book, regulations, letters patent, or other stitution of
instrument constituting or regulating the company. company.
India Stock {Powers of Attorney) Ad, 1880.
43 Vict. c. H.
An Act to make Poivers of Attorney and Requests for Trans-
niission of Dividend Warrants hy Post relatiny to India
Five per centum Stock applicable to India Four per centuin
Stock. [19th March, 1880.]
1. This act may be cited as India Stock (Powers of Attorney) Short title.
Act, 1880.
2. Every power of attorney in force at the time of the passing Powers of
of this act for the sale and transfer of any India five per cent, attorney for
stock shall, unless it be legally revoked or become void, remain saleandtrans-
in force for the purpose of enabling the attorney or attorneys ff^Vr^ ent.
therein named or referred to to receive and give receipts for gtock to apply
any principal sum of such India five per cent, stock, and to to India four
sell and transfer any India four per cent, stock, that may be per cent,
accepted in exchange for such five per cent, stock, and to stock,
receive the consideration money and give receipts for the
same.
3. Every power of attorney in force at the time of the Powers of
passing of this act for the receipt of dividends on any India attorney for
five per cent, stock shall, unless it be legally revoked or JiJIdendf on
become void, remain in force for the purpose of enabling the j^^^^^ ^^g p^j.
attorney or attorneys therein named or referred to to receive cent, stock to
the dividends to accrue on India four per cent, stock, and also apply to India
to receive the said pajmient of one pound ten shillings per fo^uj^^per cent,
cent, on India five per cent, stock which will become payable ^^^^ '•
on the fiftli day of July one thousand eight Imndred and
eighty.
o. X X
674
Eequests for
post dividend
warrants in
respect of
India five per
cent, stock, to
apply to India
four per cent,
stock.
APPENDIX OF STATUTES (sCOTLAND).
4. Every request for the transmission of dividend warrants
by post relating to India five per cent, stock in force at tlie
time of the passing of this act, or which may hereafter be
made, in pursuance of the act of the 34th and 35th Victoria,
chapter 29, shall, unless it be legally revoked or become void,
extend and apply to India four per cent, stock as if the stock
mentioned in such request were therein described as India
four -pcv cent, stock.
43 & 44 Vict. c. 20.
An Act to grant and alter certain Duties of Inland Revenue and
to amend the Laiv in relation to certain other Duties.
57. It shall not after the passing of this act be obligatory
on the commissioners to publish in any newspaper any
return made to them by any banking company which is duly
registered under the provisions of the several acts specified in
the third schedule, or any of them.
II. Eelating to Scotland exclusively.
Preamble.
From and
after loth
May, 17G6, no
notes to be
Bank Notes iMyable on Demand.
5 Geo. 3, c. 49 (a.d. 1765).
An Act to prevent the Inconveniences arising from the present
Method of issuing Notes and Bills by the Banks, Banking
Companies and Bankers, in that part of Great Britain
called Scotland {a).
Wheeeas a practice has prevailed in that part of Great
Britain called Scotland of issuing notes commonly called
bank notes, for sums of money payable to the bearer on
demand, or, in the option of the issuer or granter, j)ayable at
the end of six months with a sum equal to the legal interest
from the demand to that time : and whereas notes, with such
option as aforesaid, have been and are circulated in that part
of the United Kingdom to a great extent, and do pass from
hand to hand as specie, whereby great inconveniences have
arisen: for remedy whereof be it enacted, &c., that from and
after the 15th day of May, 1766, it shall not be lawful for
any person or persons whatsoever, bodies politic or corporate,
() Reprinted from the Revised Edition of the Statutes, 1871.
7 Geo. 4, c. 67. 675
to issue or give, or cause to be issued or given, within that issued in
part of Great Britain called Scotland, any note, ticket, token, Scotland and
or other writing for money, of the nature of a bank note, circulated as
circulated or to bo circulated as specie, but such as shall be l^^j^^^ ^-^^^^i be
payable on demand, in lawful money of Great Britain, and payable on
■udthout reserving any power or option of delaying payment demand ;
thereof for any time or term whatsoever ; and that from and and notes
after the said loth day of May, 1776, all notes, tickets, issued and
tokens, or other writings for money, of the nature of a bank circulated
note, issued previous to the said day, and circulated as specie yioifsly to^ttie
in that part of the United Kingdom, shall and they are said day shall
hereby declared and adjudged to be payable on demand in be payable on
lawful money aforesaid, any option, condition, or other clause demand, not-
therein contained'to the contrary notwithstanding. Tn o iti'c^af
2. Provided always, that nothing contained in this act shall clause to the
prevent any person or persons, bodies politic or corporate, contrary,
from issuing post bills, payable seven days after sight, in the Post bills pay-
same manner as they are at present issued by the Bank of able at seven
England. days' sight
3. That all and every person or persons whatsoever, bodies excepted ;
politic or corporate, and the legal administrators of such ^"^^j^^'^^j^,^
person or persons, bodies politic or corporate, who shall after trary°hereto
the said loth day of May, 1766, issue or cause to bo issued forfeit 500^.,
any note, ticket, token, or other writing for money, of the
nature of a bank note, circulated or to be circulated as specie,
contrary to the dii-ections of this act before mentioned, and to
the true meaning and intent thereof, shall for every such
offence forfeit and pay to the person or persons who shall
inform and prosecute for the same, 500/. sterling, with full with full costs
costs of suit, to be sued for and recovered by way of com- °* ^^^*'-
plaint before the Court of Session, upon 15 days' notice to
the person or persons, bodies politic or corporate, complained
of ; which complaint the said Court of Session is hereby
authorized and required siunmarily to determine without
abiding the course of any roll («).
Banking Cojjartnerships Regulation Act, 1826.
7 Geo. 4, c. 67.
An Act to regulate the Mode in ivhich certain Societies or Co-
partnerships for Banking in Scotland mag sue and be sued.
[20th May, 1826.]
Whereas the practice has prevailed in Scotland of instituting
societies possessing joint stocks, the shares of which are
{a) The subsequent imrepealed sections, viz., 4, 5 and 6, relating to
enforcing payment of these notes or orders by summary execution and
method of protesting on non-payment, arc not printed.
xx2
676
Banking co-
partnerships
iu Scotland
may sue and
be sued in the
name of their
manatrer, &c.
Such societies
shall yearly
deliver, at the
stamp office in
Edinburgh,
account, con-
taining the
name of the
firm, &c.
APPENDIX OF^STATUTES (SCOTLANI)).
either conditionally or unconditionall}' transferable, for tliQ
purpose of carrying on the business of banking ; and it is ex-
pedient that every such society or copartnership should _ be
enabled to sue and be sued in the name of its manager, cashier,
or other principal officer ; be it therefore enacted, «&c., that it
shall and may be lawful for every such joint stock society or
copartnership, already estabhshed or that may hereafter be
established in Scotland for the purposes of banking, to sue and
be sued in the name of the manager, cashier, or other prin-
cipal officer of such society or copartnership, provided that
such joint stock society or copartnership shall observe the
regidations prescribed by this act.
2. That every such joint stock society or copartnership
already formed shall, between the 25th day of May, and the
25th day of July in this and each succeeding year, and every
such joint stock society or copartnership hereafter to be
formed, shall, before such joint stock society or copartnership
shall begin to carry on business, and thereafter in each suc-
ceeding year, between the said 25th day of May and the 25th
day of July, cause an account or return to be made out
according to the form contained in the schedule marked A.
to this act annexed {b), wherein shall be set forth the true
(b) SOHEDXJLE (A.).
Ketiten or account to be entered at the Stamp Office in Edinburgh,
in pursuance of an act passed in the seventh year of the reign of
King George the Eoui-th, intituled [Acre insert the title of this act],
viz.
Eirm or name of the banking society or copartnership, viz. [set forth the
firm or name]. .
Names and places of abode of all the partners concerned or engaged in
svich society or copartnership, videlicet [set forth all the names and places
of abode].
Names and places of the bank or banks established by such society or co-
partnership, videlicet [set forth all the names and places].
Name and description of the officer of the said banking society or copart-
nership in whose name such society or copartnership shall sue and bo
sued, videlicet [set forth the name and description].
Names of the several towns and places where the biUs or notes of the
said banking society or copartnership are to be issued by the said
society or copartnership, or their agent or agents, videlicet [set forth
the names of all the toivns and places].
A. B. of manager, or other officer [describing the ojfice], of the
above society or copartnership, maketh oath and saith, that the
above doth contain the name, style and firm of the above society
or copartnership, and the names and places of the abode of the
several members thereof, and of the banks established by the said
society or copartnership, and the name, title and description of the
officer of the said society or copartnership in whose name such
society or copartnership shall sue and be sued, and the names of
the towns and places where the notes of the said society or copart-
nership are to be issued, as tlie same respectively appear in the
7Geo. 4, c. 67. 677
names, titlo or firm of sucli intended or existing society or
copartnership, and also the names and places of abode of all
the members of such society, or of all the partners concerned
or engaged in such copartnershiji, as the same respectively
shall appear on the books of such society or copartnership,
and the name or firm of every bank or banks established or
to be established by such society or copartnership, and also
the name and place of abode of the manager, cashier, or other
principal officer, in the name of ^-hom such society or co-
partnership shall sue and be sued, as hereinafter provided,
and also the name of every town and place where any of the
bills or notes of such society or copartnership shall be issued
by any such society or copartnership, or by their agent or
agents ; and every such account or return shall be delivered
to the head collector of stamp duties at the stamp office in
Edinburgh, who shall cause the same to be filed and kept in
the stamp office there, and an entry and registry thereof to be
made in a book or books to be there kept for that purjiose,
and which book or books any person or persons shall from
time to time have liberty to search and inspect, on payment
of the sum of Is. for every search.
3. That such account or return shall be made out by the Accounts tobe
officer named as aforesaid, and shall be verified by the oath ^^f^^^ ""^
of such officer taken before any justice of the peace, and °^°^
which oath any justice of the peace is hereby authorized and
empowered to administer, and that such account or return
shall, between the 25th day of May and the 25th day of July
in every year, be in like manner delivered by such officer as
aforesaid to the said collector, to be filed and kept in the
manner and for the purposes as hereinbefore mentioned.
4. That a copy of any such account or retirrn, so filed and Certified
kept and registered at the stamp office, as by this act is copies of such
directed, and which copy shall be certified to be a true copy, ^fi^Sice of
under the hand of the said collector, or of the comptroller of j-j^g appoint-
the stamp duties at Edinburgh, shall in all proceedings, civil mcnt of the
or criminal, and in all cases whatsoever, bo received in public ofacers,
evidence as proof of the appointment and authority of the ^°-
officer named in such account or return, and also of the
fact that all persons named therein as members of such society
or copartnership were members thereof at the date of such
account or return.
5. That the said collector or comptroller for the time being Commis-
. sioners of
books of the said society or copartnership, and to the best of the
information, knowledge and belief of this deponent.
Sworn before me the day of at
in the county of
C. D. justice of the peace in and
for the said county.
678
APPENDIX or STATUTES (sCOTLANd).
stamps to give
certified
copies of
affidavits.
Account of
officers or
members in
the course of
any year to
bo made.
sTiall, and lie is hereby required, upon application made to
liim by any person or persons requiring,' a copy certified ac-
cording to this act, of any such account c return as aforesaid,
in order that the same may be produced in evidence, or for
any other purpose; to deliver to the person or persons so
apj)lying for the same such certified copy, he, she, or they
paying for the same the sum of ten shillings and no more.
6. Provided also, and be it further enacted, that the man-
ager or other officer of every such society or copartnership
shall, and he is hereby required from time to time, as often
as occasion shall render it necessary, make out upon oath, in
manner hereinbefore directed, and cause to be delivered to
the said collector as aforesaid, a further account or return
according to the form contained in the schedule marked (B.)
to this act annexed («), of the name of any person who shall
have been nominated or appointed a new or additional officer
of such society or copartnership, in whose name the same
shall sue and be sued, and also of the name or names of any
person or persons who shall have ceased to be members of
such society or copartnership, and also of the name or names
of any person or persons who shall have become a member or
members of such society or copartnership, either in addition
(a) SCHEDITLE (B.).
Eetxjen or account to be entered at the Stamp Office in Edinburgh,
on behalf of l_)iainc the society or eopartnersJdp], in pursuance of an
act passed in the seventh year of the reign of King George the
Fourth, intituled [insert the title of this aet'\, videhcet,
Name of any new or additional officer of the said society or copartnership
in whose name the same shall sue and be sued, videlicet,
A. B. in the room of C. D. deceased or removed [as the case may be].
Names of any and every person who may have ceased to be a member of
such society or copartnership, videlecit \_set forth every name'].
Names of any and every person who may have become a new member of
such society or copartnership \_set forth every name].
Names of any additional towns or places where bills or notes are to be
issued, and where the same are to be made payable.
A. B. of manager [or other officer'] of the above-named society
or copartnership, maketh oath and saith, that the above doth con-
tain the name and place of abode of any person who hath become
or been appointed an officer of the above society or coj^artnership,
in whose name the same may sue and be sued, and also the name
and place of abode of any and every person who hath ceased to be
a member of the said society or coj^artnership, and of any and
every person who hath become a member of the said copartnership,
since the registry of the said society or copartnership on the
day of last, as the same respectively appear on the books of
the said society or cojiartnership, and to the best of the informa-
tion, knowledge and belief of this deponent.
Sworn before me, the day of at
in the county of
C. D. justice of the peace in and
for the said county.
7 Geo. 4, c. 67. 679
to or in the place or stead of any former member or members
thereof, and of the name or names of any new or additional
town or towns, place or places, where such bills or notes are
or are intended to be issued, and where the same are to be
made payable ; and such further accounts or returns shall
from time to time be filed and kept, and entered and registered
at the stamp office in Edinburgh, in like manner as is herein-
before required with respect to the original or annual account
or return hereinbefore directed to be made.
7. That all actions and suits, and also all petitions to found Copartner-
any sequestration in Scotland, or commission of bankruptcy sHips shall sue
in England, against any person or persons who may be at any ^^ the^name
time indebted to any such copartnership carrying on business ^f t^ejj,
under the provisions of this act, and all proceedings at law or officer.
in equity under any sequestration or commission of bank-
ruptcy, and all other proceedings at law or in equity to be
commenced or instituted for or on behalf of any such copart-
nership, against any person or persons, bodies politic or cor-
porate, or others, whether members of such copartnership or
otherwise, for recovering any debts or enforcing any claims
or demands due to such copartnership, or for any other matter
relating to the concerns of such copartnership, shall and
lawfully may, from and after the passing of this act, be com-
menced or instituted and prosecuted in the name of the officer
named as aforesaid for the time being of such copartnership,
as the nominal pursuer, plaintiff, or petitioner, for and on
behalf of such copartnership ; and that all actions or suits,
and proceedings at law or in equity, to be commenced or
instituted by any person or persons, bodies politic or _ cor-
porate, or others, whether members of such copartnership or
otherwise, against such copartnership, shall and lawfully may
be commenced, instituted, and prosecuted against the officer
named as aforesaid for the time being of such copartnership,
as the nominal defender or defendant for and on behalf of
such copartnership; and that all indictments, informations,
and prosecutions by or an behalf of such copartnership, for
any stealing or embezzlement of any money, goods, effects,
bills, notes, securities, or other property of or belonging to
such copartnership, or for any fraud, forgery, crime, or offence
committed against or with intent to injure or defraud such
copartnership, may be had, preferred, and carried on in the
name of the officer named as aforesaid, for the time being of
such copartnership ; and that in all indictments and informa-
tions to be had or preferred by or on behalf of such copart-
nership, against any person or persons whomsoever, it shall
be lawful and sufficient to state the money, goods, effects,
bills, notes, securities, or other property of such copartnership
to be the money, goods, effects, bills, notes, securities, or
GSO APPENDIX OF STATUTES (sCOTLAND).
other property of the officer named as aforesaid, for the time
being, of such copartnership ; and that any forgery, fraud,
crime, or other offence committed against or with intent to
injure or defraud any such copartnership, shall and lawfully
may in such indictment or indictments, notwithstanding as
aforesaid, be laid or stated to have been committed against or
with intent to injure or defraud the officer named as aforesaid,
for the time being, of such copartnership ; and any offender
or offenders may thereupon be lawfully convicted for any
such forgery, fraud, crime, or offence ; and that in all other
allegations, indictments, informations or other proceedings of
any kind whatsoever, in which it otherwise might or would
have been necessary to state the names of the persons com-
posing such copartnership, it shall and may be lawful and
sufficient to state the name of the officer named as aforesaid,
for the time being, of such copartnership ; and the death,
resignation, removal, or any act of such officer shall not abate
or prejudice any such action, suit, indictment, information,
prosecution, or other proceeding commenced against, or by or
on behalf of such copartnership, but the same may be con-
tinued, prosecuted, and carried on in the name of any other
manager, cashier, or other principal officer of such copartner-
ship for the time being.
Not morothan 8. That no person or persons, or body or bodies politic or
one action for corporate, having or claiming to have any demand upon or
the recovery against any such society or copartnership, shall bring more
raand. ' than one action or suit, in case the merits shall have been tried
in such action or suit, in respect of such demand ; and the pro-
ceedings in any action or suit by or against the officer named
as aforesaid for the time being of any such copartnership, may
be j)leaded in bar of any other action or actions, suit or suits,
for the same demand, by or against such copartnership.
Decrees of a 9. That all and every decree or decrees, order or orders,
court of interlocutor or interlocutors, made or pronounced in any suit
^^u^^^L'^^^x^^ or proceeding in any court of law or equity against the officer
take effect named as aforesaid of any such coj)artnership carrying on
against the business under the provisions of this act, shall have the like
copartner- effect and operation upon and against the property and funds
^'"P- of such coj)artnership, and upon and against the persons and
property of every or any member or members thereof, as if
every or any such members of such coi^artncrship were parties
before the court to and in any such suit or proceeding ; and
such order, interlocutor, and decree shall be enforced against
every or any member of such copartnership, in like manner
as if every such member of such copartnership was a party
before such court to and in such suit or proceeding.
Judgments 10. That all and every judgment and judgments, decree or
against officer decrees, in any action, suit or proceedings in law or equity
7 Geo. 4, c. 67. 681
against tlie officer named as aforesaid of any such copartner- against the
ship, shall have the like effect and operation upon and against copartner-
the property of such eopai'tnership, and upon and against the ^^^'P-
property of every such member thereof as aforesaid, as if such
judgment or judgments had been recovered or obtained
against such copartnership ; and that the bankruptcy, insol-
vency, or stopping payment of such officer for the time being •
of such copartnership, in his individual character or capacity,
shall not be nor be construed to be the bankruptcy, insol-
vency, or stopping payment of such copartnership ; and that
such copartnership and every member thereof, and the capital
stock and effects of such copartnership, and the effects of
every member of such copartnership, shall in all cases, not-
withstanding the bankruptcy, insolvency, or stopping pajanent
of any such officer, be attached and attachable, and be in all
respects liable to the lawful claims and demands of the cre-
ditor and creditors of such copartnership, or of any member or
members thereof, as if no such bankruptcy, insolvency, or
stopping payment of such officer had happened or taken
place.
11. Provided always, that such officer in whose name any Officer, &c. in
such suit or action shall have been commenced, prosecuted, or fi^h cases
defended, and every person or persons against whom execu- iiidemmiiea.
tion upon any judgment obtained or entered up as aforesaid
in any such action shall be issued as aforesaid, shall always
be reimbursed and fully indemnified for all loss, damages,
costs, and charges which such officer or person may have
incurred by reason of such execution, out of the funds of such
copartnership, or in failure thereof, from the funds of the
other members of such copartnership, as in the ordinary cases
of copartnership.
12. [Not to affect questions depending at the time of pass-
ing this act] (a).
13. Provided always, that no such society or copartnership Limiting the
shall be obliged to take out more than four licences for the number of
issuing of any promissory notes for money paj'able to the |'°|^°ces to be
bearer on demand, allowed bj^ law to be re-issued, in all, for branches °^
any number of towns or places in Scotland ; and in case any
such society or copartnership shall issue such promissory notes
as aforesaid, by themselves or their agents, at more than four
different towns or places in Scotland, then after taking out
three distinct licences for three of such towns or places, such
society or copartnership shall be entitled to have all the rest
of such towns or places included in a fourth licence.
{a) Repealed by the Statute Law Reviaion Act, 1873, 3G & 37 Vict.
c. 91,
682
APPENDIX OF STATUTES (sCOTLANd).
Penalty on
copartnership
neglecting to
send returns,
and penalties
for making
false returns.
Penalties,
liow to bo re-
covered.
14. Tliat if any such society or copartnership, carrying on
the business of bankers under the authority of this act, shall
issue any bills or notes, or to borrow or owe or take up any
money on their bills or notes, without having caused such
account or return as aforesaid to be made out and delivered
in the manner and form directed by this act, or shall neglect
or omit to cause such account or return to be renewed yearly
and every year between the days or times hereinbefore ap-
pointed for that purpose, such society or copartnership so
offending shall, for each and every week they shall so neglect
to make such account and return forfeit the sum of 500/. ;
and if any officer of such society or copartnership shall make
out or sign any false account or return, or any account or
return which shall not truly set forth all the several particu-
lars by this act required to be contained or inserted in such
account or return, the society or copartnership to which such
officer so offending shall belong, shall for every such offence
forfeit the sum of 500/., and the said officer so offending shall
also for every such offence forfeit the sum of 100/.; and if
any such officer making out or signing any such account or
return as aforesaid, shall knowingly and wilfully- make a
false oath of or concerning any of the matters to be therein
specified and set forth, every such officer so off ending,^ and
being thereof lawfully convicted, shall be subject and liable
to such pains and penalties as by any law now in force persons
convicted of wilful and corrupt perjury are subject and liable
to.
15. That all pecuniary penalties and forfeitures imposed by
this act shall and may be sued for and recovered in his
Majesty's Court of Exchequer at Edinburgh, in the same
manner as penalties incurred under any act or acts relating to
stamp duties may be sued for and recovered in such coiu't.
7 & 8 Vict,
c. 32, s. 10.
The Bank Notes Issue Regulation Aet.
8 & 9 Vict. c. 38.
An Act to regulate the Issue of Bank Notes in Scotland.
[21st July, 1845.]
"Whereas by an act made and passed in the 8th year of the
reign of her Majesty, intituled " An Act to regulate the issue
of bank notes, and for giving to the Governor and Company
of the Bank of England certain privileges for a limited
period," it was enacted that from and after the passing of
that act no person, other than a banker, who on the Gth day
8 & 9 Vict. c. 38. 683
of May, 1844, was lawfully issuing Lis own bank notes, sliould
make or issue bank notes in any part of the United Kingdom ;
and whereas it is expedient to regidate the issue of bank notes
by such bankers as are now by law authorized to issue the
same in Scotland; be it therefore enacted, &c., that every Bankers
banker claiming to be entitled to issue bank notes in Scotland claumng to
shall, within one month next after the passing of this act, issu^bank ^
give notice in writing to the commissioners of stamps and notes to o'ive
taxes, at their head office in London, of such claim, and of notice to com-
the place and name and firm at and under which such banker mis«ioners of
has issued such notes in Scotland during the year next pre- ^^^'^P''^ ^^^
ceding the 1st day of May, 1845, and thereupon the said com-
missioners shall ascertain if such banker was on the 6th day ^.'^"^™'^"
of May, 1844, and from thence up to the 1st day of May, certify exist-
1845, carrying on the business of a banker and lawfully issu- ing banks of
ing his own bank notes in Scotland, and if it shall so appear i^sue and
then the said commissioners shall proceed to ascertain the |"^itation of
average amount of the bank notes of such banker which were ^''^^^®'
in circulation during the said period of one year preceding the
1st day of May, 1845, according to the retui'ns made by such
banker in pursuance of the act passed in the 4th and 5th years
of the reign of her present Majesty, intituled "An Act to 4 & 5 Vict.
make further provision relative to the returns to be made by °- ^^•
banks of the amount of their notes in circulation ;" and the
said commissioners, or any two of them, shall certify under
their hands to such banker the average amount when so as-
certained as aforesaid, omitting the fractions of a pound, if
any ; and it shall be lawful for every such banker to continue
to issue his own bank notes after the 6th day of December,
1845, to the extent of the amount so certified, and of the
amount of gold and silver coin held by such banker at the
head office or principal place of issue of such banker, in the
proportion and manner hereinafter mentioned, but not to any
further extent ; and from and after the 6th day of December,
1845, it shall not be lawful for any banker to make or issue
bank notes in Scotland, save and except only such bankers as
shall have obtained such certificate from the commissioners of
stamps and taxes.
2. Provided always, that if it shall be made to appear to Provision for
the commissioners of stamps and taxes that any two or more united banks,
banks have by written contract or agreement (which contract
or agreement shall be produced to the said commissioners)
become united within the year next preceding such 1st day of
May, 1845, it shall be lawful for the said commissioners to
ascertain the average amount of the notes of each such bank
in the manner hereinbefore directed, and to certify a sum equal
to the average amount of the notes of the two or more banks
so united, as the amount which the united bank shall there-
G84
APPENDIX OF STATUTES (sCOTLANd).
Duplicate of
certificate to
be published
in the Gazette.
Gazette to be
evidence.
In case banks
become
united, com-
missioners to
certify the
amount of
bank notes
■which each
bank was
authorized
to issue.
Issue of notes
for fractional
parts of a
pound pro-
hibited.
Limitation of
bank notes in
circulation.
after be authorized to Issue, subject to the regulations of this
act.
3. That the commissioners of stamps and taxes shall, at the
time of certifj'ing to any banker such particulars as they are
hereinbefore required to certify, also publish a duplicate of
their certificate thereof in the next succeeding London Gazette
in which the same may be conveniently inserted; and the
Gazette in which such publication shall be made shall be con-
clusive evidence in all courts whatsoever of the amount of
bank notes which the banker named in such certificate or
duplicate is by law authorized to issue and to have in circula-
tion as aforesaid, exclusive of an amount equal to the monthly
average amount of the gold and silver coin held by such banker
as herein provided.
4. That in case it shall be made to appear to the commis-
sioners of stamps and taxes, at any time hereafter, that any
two or more banks have by written contract or agreement
(which contract or agreement shall be produced to the said
commissioners) become united subsequently to the passing of
this act, it shall be lawful to the said commissioners, upon
the application of such united bank, to certify in manner
hereinbefore mentioned the aggregate of the amount of bank
notes which such separate bank were previously authorized
to issue under the separate certificates previously delivered to
them, and so from time to time ; and every such certificate
shall be published in manner hereinbefore directed, and from
and after such publication the amount therein stated shall be
and be deemed to be the limit of the amount of bank notes
which such united bank may have in circulation, exclusive of
an amount equal to the monthly average amount of the gold
and silver coin held by such bank, as herein provided.
6. That all bank notes to be issued or re-issued in Scotland
shall be expressed to be for payment of a sum in pounds
sterling, without any fractional parts of a pound ; and if any
banker in Scotland shall, from and after the 6th day of
December, 1845, make, sign, issue or re-issue any bank note
for the fractional part of a pound sterling, or for any sum
together with the fractional part of a pound sterling, every
such banker so making, signing, issuing, or re-issuing any
such note as aforesaid shall for each note so made, signed,
issued, or re-issued forfeit or pay the sum of 20^.
6. That from and after the 6th day of December, 1845, it
shall not be lawful for any banker in Scotland to have in
circulation, upon the average of a period of four weeks, to be
ascertained as hereinafter mentioned, a greater amount of
notes than an amount composed of the sum certified by the
commissioners of stamps and taxes as aforesaid and the
monthly average amount of gold and silver coin held by such
8 & U Vict. c. 38. G85
banker at the head office or principal place of issue of such
banker dui-ing the same period of four weeks, to be ascer-
tained in manner hereinafter mentioned.
7. That every banker who after the 6th day of December, Issuing banks
1845, shall issue bank notes in Scotland shall, on some one day *° render
in every week after the 13th day of December, 1845 (such day ^'^"^^'^ '*•
to be fixed by the commissioners of stamps and taxes), trans-
mit to the said commissioners a just and true account of the
amount of bank notes of such banker in circulation at the close
of the business on the next preceding Saturday, distinguish-
ing the notes of 5/. and upwards, and the notes below bl., and
also an account of the total amount of gold and silver coin held
by such banker at the head office or principal place of issue
in Scotland of such banker at the close of business on each
day of the week entbng on the same Saturday, and also an
account of the total amount of gold and silver coin in Scotland
held by such banker at the close of business on that day ; and
on completing the first period of four weeks, and so on
completing each successive period of four weeks, every such
banker shall annex to such account the average amount of
bank notes of such banker in circulation during the said four
weeks, distinguishing the bank notes of bl. and upwards and
the notes below 5^., and the average amount of gold and
silver coin respectively held by such banker at the head office
or principal place of issue in Scotland of such banker during
the said four weeks, and also the amount of bank notes which
such banker is, by the certificate published as aforesaid in the
London Grazette, authorized to issue under the provisions of
this act ; and every such account shall specify the head office
or princijial places of issue in Scotland of such banker, and
shall be verified by the signature of such banker or his chief
cashier, or in case of a company or partnershij) by the signa-
ture of the chief cashier or other officer duly authorized by
the directors of such company or partnership, and shall be
made in the form to this act annexed marked (A.) {a)) ; and
if such banker shall neglect or refuse to render any such
account in the form and at the time required by this act, or
shall at any time render a false account, such banker shall
forfeit the sum of 100/. for every such offence.
8. That all bank notes shall be deemed to be in circulation Wliat shall be
from the time the same shall have been issued by any banker, deemed to be
or any servant or agent of such banker, until the same shall ^a^ notes in
have been actually retm'ned to such banker, or some servant ^^^ ation.
or agent of such banker.
9. That from the returns so made by each banker to the Commis-
commissioners of stamps and taxes the said commissioners sioners of
stamps and
[a) Sec schedule, post, p. 686.
686
APPENDIX OF STATUTES (sCOTLANd).
i> fl 0) o g
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8 & 9 Vict. c. 38. 687
shall, at the end of the first period of four ^veelis after the taxes to make
said 6th day of December, 1845, and so at the end of each a montlily
successive period of four weeks, make out a general return in ^^ ^"^•
the form to this act annexed marked (B.) (a) of the monthly
average amount of bank notes in circulation of each banker in
Scotland during the last preceding four weeks, and of the
average amount of all the gold and silver coin held by such
banker, and certifying under the hand of any officer of the
said commissioners duly authorized for that purpose, in the
case of each such banker, whether such banker has held the
amount of coin required by law during the period to which
the said return shall apply, and shall publish the same in the
next succeeding London Gazette in which the same can be
conveniently inserted.
10. That for the purpose of ascertaining the monthly average Mode of _
amount of bank notes of each banker in circulation, the aggre- J^^^'J^'^^g^^f
gate of the amount of bank notes of each such banker in circu- ^^^^^^^ ^f
lation at the close of the business on Saturday of each week ^ank notes of
during the first complete period of four weeks next after the each banker
6th day of December, 1845, shall be divided by the number in circulation,
of weeks, and the average so ascertained shall be deemed ^^^^1° Jye"""'
to be the average of bank notes of each such bank in circula- ^^.^^ f"^^,
tion during such period of four weeks, and so in each successive weeks after
period of four weeks ; and the monthly average amount of gold 3ist Decem-
and silver coin respectively held as aforesaid by such banker ber, 184o.
shall be ascertained in like manner from the amount of gold
and silver coin held by such banker at the head ofiice or prin-
cipal place of issue in Scotland of such banker at the close
of business on Saturday in each week during the same period ;
and the monthly average amount of bank notes of each such
banker in circulation dm-ing any such period of fom- weeks is
not to exceed a sum made up by adding the amount certified
by the commissioners of stamps and taxes as aforesaid and
the monthly average amount of gold and silver com held by
such banker as aforesaid during the same period.
11. That in taking account of the coin held by any such In taking tlio
banker as aforesaid, with respect to which bank notes to a account of
further extent than the sum certified as aforesaid by the ^aSkcrs, silver
commissioners of stamps and taxes may, under the provisions ^oin not to
of this act, be made and issued, no amount of silver coin exceed the
exceeding one fourth part of the gold coin held by such proportion of
banker as aforesaid shaU be taken into account, nor shall any °^j/'''^*^^ ""*
banker be authorized to make and issue bank notes in =
Scotland, on any amount of silver coin held by such banker
exceeding the proportion of one fourth part of the gold coin
held by such banker as aforesaid.
(d) See schedule, atite, p. C8G.
688
APPENDIX OF STATUTES (sCOTLANd).
Commis-
sioners of
stamps and
taxes em-
powered to
cause the
books of
bankers con-
taining ac-
counts of their
l)ank notes in
circulation,
and of gold
coin, to be in-
spected.
Penalty for
refusing to
allow such
inspection.
All bankers to
return their
names once a
year to the
btamp office.
12. And whereas in order to ensure the rendering of true
and faithful accounts of the amount of hank notes in circula-
tion, and the amount of gold and silver coin held by each
banker, as directed by this act, it is necessary that the
commissioners of stamps and taxes should be empowered to
cause the books of bankers issuing such notes, and the gold
and silver coin held by such bankers as aforesaid, to bo
inspected as hereinafter mentioned: be it therefore enacted,
that all and every the book and books of any banker who
shall issue bank notes under the provisions of this act, in
which shall be kejjt, contained or entered any account, minute
or memorandum of or relating to the bank notes issued or to
be issued by such banker, or of or relating to the amount of
such notes in circulation from time to time, or of or relating
to the gold and silver coin held by such banker from time to
time, or any account, minute, or memorandum, the sight or
inspection whereof may tend to secure the rendering of true
accounts of the average amount of such notes in circulation
and gold and silver coin held as directed by this act, or to test
the truth of any such account, shall be open for the inspection
and examination at all seasonable times of any officer of
stamp duties authorized in that behalf by writing signed by
the commissioners of stamps and taxes, or any two of them ;
and every such officer shall be at liberty to take copies of or
extracts from any such book or account as aforesaid, and to
inspect and ascertain the amount of any gold or silver coin
held by such banker; and if any banker or other person
keeping any such book, or having the custody or possession
thereof or power to produce the same, shall, upon demand
made by any such officer showing (if required) his authority
in that behalf, refuse to produce any such book to such
officer for his inspection and examination, or to permit him to
inspect and examine the same, or to take copies thereof or
extracts therefrom, or of or from any such account, minute or
memorandum as aforesaid, kept, contained or entered therein,
or if any banker or other person having the custody or
possession of any coin belonging to such banker shall refuse
to permit or prevent the inspection of such gold and silver
coin as aforesaid, every such banker or other person so
offending shall for every such offence forfeit the sum of
100^.: provided always, that the said commissioners shall not
exercise the powers aforesaid without the consent of the
Commissioners of her Majesty's Treasury.
13. That every banker in Scotland who is now carrying on
or shall hereafter carry on business as such, other than the
Bank of Scotland, the Ixoyal Bank of Scotland, and the
British Linen Company, shall, on tlie 1st day of January in
each year, or within 15 days thereafter, make a return to the
8 & 9 Vict. c. 38. G89
commissioners of stamps and taxes, at their head office in
London, of his name, residence and occupation, or, in the
case of a company or partnership, of the name, residence and
occupation of every person composing or being a member of
such company or partnership, and also the name of the firm
under which such banker, company or partnership carry on
the business of banking, and of every place where such
business is carried on ; and if any such banker, company or
partnership shall omit or refuse to make such return within
fifteen days after the said 1st day of January, or shall wilfully
make other than a true return of the persons as herein
required, every banker, company or partnership so offending
shall forfeit or pay the sum of 50^. ; and the said com-
missioners of stamps and taxes shall on or before the 1st day
of March in every j^ear publish in some newspaper circulating
within each town or county resj)ectively in which the head
office or principal place of issue of any such banker be
situated a copy of the return so made by every banker,
company or partnership carrying on the business of bankers
within such town or county respectively, as the case may be.
14. That if the monthly average circulation of bank notes Penalty on
of any banker, taken in the manner herein directed, shall at banks issuing
any time exceed the amount which such banker is authorized "^ excels.
to issue and to have in circulation under the provisions of
this act, such banker shall in everj^ such case forfeit a sum
equal to the amount by which the average monthly circula-
tion, taken as aforesaid, shall have exceeded the amount
which such banker was authorized to issue and to have in
circulation as aforesaid.
15. And whereas by 3 & 4 Will. 4, c. 98, s. 6, it was enacted, Bank of Eng-
that from and after the 1st day of August, 1834, unless and land notes not
until parliament should otherwise direct, a tender of a note a legal tender
or notes of the Governor and Company of the Bank of
England, expressed to be payable to bearer on demand,
should be a legal tender to the amount expressed in such
note or notes, and should be taken to be valid as a tender to
such amount for all sums above 5/. on all occasions on which
any tender of money may be legally made, so long as the
Bank of England should continue to pay on demand their
said notes in legal coin : provided always, that no such note
or notes should be deemed a legal tender of payment by the
Governor and Company of the Bank of England, or any
branch bank of the said governor and company : and whereas
doubts have arisen as to the extent of the said enactment, for
removal whereof be it enacted and declared, that nothing in
the said last recited act contained shall extend or be construed
to extend to make the tender of a note or notes of the
Governor and Company of the Bank of England a legal
G. Y Y
690
APPENDIX OF STATUTES (sCOTLAND).
Proviso.
Notes for less
than '20.S. not
negotiaLle iu
Scotland {a) .
Notes of 2Qs.
or above, and
kss than oL,
to be drawn
iu certain
form {a) .
tender in Scotland: provided always, that nothing in this act
contained shall be construed to prohibit the circulation in
Scotland of the notes of the Governor and Company of the
Bank of England as heretofore.
16. That all promissory or other notes, bills of exchange, or
drafts, or undertakings in writing, being negotiable or trans-
ferable, for the payment of any sum or sums of money, or any
orders, notes, or undertakings in writing, being negotiable or
transferable, for the delivery of any goods, specifying their
value in money less than the sum of 205. in the whole, hereto-
fore made or issued, or which shall hereafter be made or
issued in Scotland, shall, from and after the 1st day of
January, 1846, be and the same are hereby declared to be
absolutely void and of no effect, any law, statute, usage, or
custom to the contrary thereof in anywise notwithstanding;
and that if any person or persons shall, after the 1st day of
January, 1846, by any art, device, or means whatsoever,
publish or utter in Scotland any such notes, bills, drafts, or
engagements as aforesaid for a less sum than 20*., or on which
less than the sum of 20*. shall be due, and which shall be
in anywise negotiable or transferable, or shall negotiate or
transfer the same in Scotland, every such person shall forfeit
and pay for every such offence any sum not exceeding 201.
nor less than 51., at the discretion of the justice of the peace
who shall hear and determine such offence («).
17. That all promissory or other notes, bills of exchange, or
drafts, or undertakings in writing, being negotiable or trans-
ferable, for the payment of 20s., or any sum of money above
that sum and less than 51., or on which 20*., or above that
sum and less than 5^., shall remain undischarged, and which
shall be issued within Scotland at any time after the 1st day
of January, 1846, shall specify the names and places of abode
of the persons respectively to whom or to whose order the
same shall be made j)ayable, and shall bear date before or at
the time of drawing or issuing thereof, and not on any day
subsequent thereto, and shall be made payable within the
space of 21 days next after the day of the date thereof, and
shall not be transferable or negotiable after the time hereby
limited for payment thereof, and that every indorsement to be
made thereon shall be made before the expiration of that
time, and to bear date at or not before the time of making
thereof, and shall specify the name and place of abode of the
person or persons to whom or to whose order the money con-
tained in every such note, bill, draft, or undertaking is to be
paid ; and that the signing of every such note, bill, draft, or
(«) The restrictions on issuing these notes are repealed or removed by
26 & 27 Vict. c. 10."), and 3G & 37 Vict. c. 7o, iintil the 28th July, 1874.
8 & 9 YicT. c. 38. 091
undertaking, and also of every such, indorsement, shall be
attested by one subscribing Tvitness at tlie least ; and which
said notes, bills of exchange, or drafts, or undertakings in
writing, may be made or drawn in words to the purport or
effect as set out in the schedules to this act annexed marked
(C.) (b) and (D.) (c) ; and that all promissory or other notes,
bills of exchange, or drafts, or undertakings in writing, being
negotiable or transferable, for the payment of 20s., or any
sum of money above that sum and less than 51., or on which
20s., or above that sum and less than 5^., shall remain undis-
charged, and which shall be issued in Scotland at any time
after the said 1st day of January, 184G, in any other manner
than as aforesaid, and also every indorsement on any such
note, bill, draft, or other undertaking to be negotiated under
this act, other than as aforesaid, shall and the same are hereby
declared to be absolutely void, any law, statute, usage, or
custom to the contrary thereof in anywise notwithstanding :
provided always, that nothing in this clause contained shall
be construed to extend to any such bank notes as shall be
lawfully issued by any banker in Scotland authorized by this
act to continue the issue of bank notes.
18. That if any body politic or corporate or any person or Penalty for
persons shall, from and after the said 1st day of January, persons other
i^ , . . • • o ii 1 • than bankers
1846, make, sign, issue, or re-issue m Scotland any promissory Y^erchj autho-
note payable on demand to the bearer thereof for any sum of rized, issuing
money less than the sum of 51., except the bank notes of such notes payable
bankers as are hereby authorized to continue to issue bank on demand for
notes as aforesaid, then and in either of such cases every such ^^^^ *^^^ ^'•
body politic or corporate or person or persons so making,
signing, issuing, or re-issuing any such promissory note as
(i) SCHEDTJLE (C.)
[Flace'] idaijl [_month'] [l/ear}.
Twenty-one days after date I promise to pay to A. B. of {pkee'], or
his order, the sum of for value received by
Witness, E. F. . C. D.
And the endorsement, toties quoties.
\_I)aij'] {jnontlt] [yt-a;-].
Pay the contents to G. H. of \_place'\, or his order.
Witness, J. K. A. B.
((') Schedule (D.)
\_I'lace] [day] [inonth:] [year'].
Twenty-one days after date pay to A. B. of [p/('ff], or his order, the
sum of value received, as advised by
To E. F. of Iplace']. E. D.
Witness, G. H.
And the endorsement, toties quoties.
[Dffy] [month'] [year].
Pay the contents to J. K. of [place], or his order.
Witness, L. M. A. B.
Y y2
692
Penalty for
persons, other
than bankers
hereby autho-
rized, titter in g-
or negotiating
notes, bills of
exchange,
&c., transfer-
able, for pay-
ment of 20a\
or less than
bl.
Not to pro-
hibit checks
on bankers.
Mode of
recovering
penalties.
APPENDIX OF STATUTES (sCOTLAND).
aforesaid, except as aforesaid, shall for every sucli note so
made, signed, issued or re-issued forfeit the sum of 20^.
19. That if any body politic or corporate or person or per-
sons shall, from and after the passing of this act, pubhsh,
utter, or negotiate in Scotland any promissory or other note
(not being the bank note of a banker hereby authorized to
continue to issue bank notes), or any bill of exchange, draft,
or undertaking in writing, being negotiable or transferable,
for the pajonent of 20*., or above that sum and less than bl.,
or on which 20s., or above that sum and less than bl., shall
remain undischarged, made, drawn, or indorsed in any other
manner than as is hereinbefore directed, every such body
politic or corporate or person or persons so publishing, utter-
in"-, or negotiating any such promissory or other note (not
being such bank note as aforesaid), bill of exchange, draft,
or undertaking in writing as aforesaid, shall forfeit and pay
the sum of 20^.
20. Provided always, that nothing herein contained shall
extend to prohibit any draft or order drawn by any person on
his banker, or on any person acting as such banker, for the
payment of money held by such banker or person to the use
of the person by whom such draft or order shall be drawn.
21. That all pecuniary penalties under this act may be sued
or prosecuted for and recovered for the use of her Majesty, in
the name of her Majesty's advocate general or solicitor general
in Scotland, or of the solicitor of stamps and taxes in Scotland,
or of any person authorized to sue or prosecute for the same,
by writing under the hands of the commissioners of stamps
and taxes, or in the name of any ofhcer of stamp duties, by
action of debt, bill, plaint, or information in the Court of
Exchequer in Scotland, or, in respect of any penalty not ex-
ceeding 20^., by information or complaint before one or more
justice or justices of the peace in Scotland, in such and the
same manner as any other penalties imposed by any of the
laws now in force relating to the duties under the manage-
ment of the commissioners of stamps ; and it shall be lawful
in all cases for the commissioners of stamps and taxes, either
before or after any proceedings commenced for recovery of
any such penalty, to mitigate or compound any such penalty
as the said commissioners shall think fit, and to stay any such
proceedings after the same shall have been commenced, and
whether judgment may have been obtained for such penalty
or not, on pa_>anent of part only of any such penalty, with or
without costs, or on payment only of the costs incurred in
such proceedings, or of any part thereof, or on such other
terms as sucli commissioners shall judge reasonable: provided
always, that in no such proceeding aforesaid shall any essoign,
protection, wager of law, nor more than one imparlance be
16 & 17 Vict. c. (j'S. 693
allowed ; and all pecuniary penalties imposed by or incurred
under this act, by whom or in whoso name soever the same
shall be sued or prosecuted for or recovered, shall go and be
applied to the use of her Majesty, and shall be deemed to be
and shall be accounted for as part of her Majesty's revenue
arising from stamp duties, any thing in any act contained, or
any law or usage, to the contrary in anywise notwithstanding:
provided always, that it shall be lawful for the commissioners
of stamps and taxes, at their discretion, to give all or any
part of such penalties as rewards to any person or persons
who shall have detected the offenders, or given information
which may have led to their prosecution and conviction.
22. That the term "bank notes" used in this act shall Interpre-
extend and apply to all bills or notes for the payment of t'^tion of act.
money to the bearer on demand, other than bills and notes of
the Governor and Company of the Bank of England; and
that the term " banker" shall extend and apply to all corpo-
rations, societies, partnerships, and persons, and every indi-
vidual person carrying on the business of banking, whether
by the issue of bank notes or otherwise ; and that the word
" person" used in this act shall include corporations ; and that
the word " coin" shall mean the coin of this realm ; and that
the singular number in this act shall include the plural, and
the plural number the singidar, except where there is any
thing in the context repugnant to such construction ; and that
the masculine gender in this act shall include the feminine,
except where there is anything in the context repugnant to
such construction.
Composition for Stamp Duties 2)((!/nhle on Notes and Bills.
16 & 17 Vict. c. 63(a).
An Act to repeal certain Stamp Duties, and to grant others in
lieu thereof ; to give relief tvith respect to the Stamp Dttties
071 Neiosjyapers and Supplements thereto ; to repeal the Latu
071 Adrerfise7ne7its, and otherioise to a7ne7ul the Laivs re-
lating to Stamp Duties. [4th August, 1853.]
7. And whereas, under and by virtue of certain acts of par- Power to trea-
liament now in force, the Governor and Company of the Bank suiy to com-
of Scotland, and the Eoyal Bank of Scotland, and the British V^^"^^ ^^ith
Linen Company in Scotland, are respectively authorized and Sc°tr^\^
empowered to make and issue and re -issue their promissory the stamp
notes payable to bearer on demand on unstamped paper, duties on
their pro-
missory notes.
{a) 33 & 34 Vict. c. 99, s. 2, repeals the whole of this act except the
above section 7.
APPENDIX OF STATUTES (.SCOTLAND).
giving security, and keeping and producing true accounts of
all the notes so issued by them respectively, and accounting
for and paj-ing the stamp duties payable in respect of such
notes : and whereas it is expedient to authorize and empower
the commissioners of her Majesty's treasury to compound
with the said banks, as well as all bankers in Scotland, for
the stamp duties on their promissory notes payable to bearer
on demand as well as for stamps payable on their bills of
exchange: it shall be lawful for the commissioners of her
Majesty's treasury for the time being, or any three of them,
and they are hereby authorized and empowered to compound
and agree with the said Governor and Company of the Bank
of Scotland, the Eoyal Bank of Scotland, and the British
Linen Company in Scotland, and all or any other bankers in
Scotland, or elsewhere, respectively, for a composition in lieu
of the stamp duties payable on the promissory notes of the
said banks and bankers respectively payable to the bearer on
demand, as well as for stamps payable on their bills of ex-
change ; and such composition shall be made on ^uch terms
and conditions, and with such security for the payment of the
same, and for keeping, producing, and rendering of such
accounts, as the said last-mentioned commissioners may deem
to be proper in that behalf ; and upon such composition being
entered into by such banks and bankers respectively, it shall
be lawful for them to issue and re-issue all notes and to draw
all such bills for which such composition shall have been made
upon unstamped paper, anything in any act contained to the
contrary notwithstanding.
Lien or Right of Retention over Shares in Joint Stock Banks,
and signing Bills and Notes.
17 & 18 Vict. c. 73.
An Act to amend the Acts for the Regulation of Joint Stock
Banks in Scotland. [31st July, 1854.]
"Whereas an act passed in the 8th year of the reign of her
7&8Vict. present Majesty, intituled "An Act to regidate joint stock
c. 113. banks in England :" and whereas the said act was extended
to Scotland and Ireland by an act passed in the 9th and 10th
9 & 10 Vict, years in the reign of her Majesty, intitided " An Act to regu-
c. 75. late joint stock banks in Scotland and Ireland: " and whereas
it is expedient that the recited acts should be amended in
certain of the provisions thereof, in so far as the same apply
to Scotland : be it enacted, &c., as follows :
11) Vict. c. 3. 095
1. No clause directed by the said acts to be inserted in the Right of re-
deed of partnership of any joint stock banking- company in tention or lien
Scotland to be executed previous to such company being in- p^rJ'ifers not°
corporated under the recited acts shall take away or impair ^.^ ^^^ affected,
the right of retention or lien which, in virtue of the common
law of Scotland, such company has or may be entitled to
exercise over the shares of its partners, for or in respect of
any debt or liability incurred or obligation undertaken by
them to the company.
2. Provided, that as often as the company may, in virtue of The company
their right of lien or retention acquire any shares in the coni- *« ^f^iJ-g^ii^^
pany's stock, they shall be bound to sell the same within six yj'i^Ji^e of
months after the same shall have been so acquired, and in right of lien,
such manner as is by the said first-recited act provided for the
sale of forfeited shares : and the company shall bo bound to
account to the party or parties interested in such shares, or to
their creditors, or heirs, or executors, for the balance of the
price or prices which may have been realized by su.ch sale,
after paying the debt due to the company, and the expenses
incurred by them in securing their debt and selling the
shares.
3. In such deed of partnership there shall be inserted pro- Provision to
visions reg'ulating the manner in which bills of exchange or he inadc as to
^ , ° p ,^ 1 1 ii„ siKnins? bills
promissory notes of the company may be made, accepted or ^^^ ^^ °.„^_
indorsed, and it shall not be necessary that such bills of
exchange or promissory notes be signed in the manner pre-
scribed by the fii-st-recited act.
Joint StocJi Banks Incorporafio)i hy Letters Patoit.
19 YicT. c. 3.
An Act to extend the Period for ivhich her Majesty may yrant
Letters Patent of hicorporation to Joint Stock Banks in
Scotland existing before the Act of 1846.
[7th March, 1846.]
Wherpas, under the provisions of the act of the 9th and
10th years of her present Majesty, chapter 75 (whereby the
act of the 7th and 8th years of her Majesty, chapter 113, was
extended to joint stock banks in Scotland), her Majesty, with
the advice of her privy council, is empowered to grant letters
patent of incorporation to any company of more than six
persons who were carrying on the business of bankers in
Scotland on or before the 9th day of August, 1845, upon the
terms and in manner in the said acts mentioned or referred
to, but only for a term of years not exceeding 20 years : and
C96
APPENDIX OF STATUTES (iRELAKd).
Extending
period for
which her
Majesty may-
grant letters
patent of in-
corjDoration to
certain joint
stock banks
in Scotland.
whereas it is expedient that her Majesty should be em-
powered in certain cases to grant such letters patent of
incorporation for a longer period : now be it enacted, &:c., as
follows :
1. That notwithstanding anything in the said acts con-
tained, it shall be lawful for her Majesty to grant letters
patent of incorporation under the said acts to any company
of more than six ^lersons in Scotland who were carrying on
the business of bankers before the said 9th day of August, 1845,
either for a term of years or in perpetuity, but so that the
same shall be liable to be dealt with by or under tlie pro-
visions of any future acts of parliament in every respect as if
this act had not been passed.
III. Relating to Ireland exclusively.
Composition
for stamps on
notes of Bank
of Ireland.
Cancellation of wiuseil Bank Notes.
55 Geo. 3, c. 100.
An Act to inovide for the Collection and Management of Stamp
Duties payable on Bills of Exchange, Promissory Notes,
Receipts, and Game Certificates, in Ireland (a).
[22nd June, 1815.]
19. And be it further enacted, that all bank notes and bank
post bills, which shall be issued by the Governor and Com-
pany of the Bank of Ireland, shall be exempt from the stamp
duties which may from time to time be charged thereon
respectively (unless otherwise expressly provided in the act or
acts charging the same), from every 25th day of March for
one whole year next following ; provided the governor and
company of the said bank shall on the said 25th day of March
respectively have paid into his Majesty's treasury in Ireland,
such sum of money as shall have been from time to time
agreed upon by and between the said governor and company,
and the lord high treasurer of Ireland, or the commissioners
for executing the office of lord high treasurer of Ireland, as
a compensation for and to be in lieu of and in full satisfaction
for all stamp duties payable wpou aU notes and bills to bo
(a) By the TuhiDd Eovenue Repeal Act, 1870, (33 & 34 Vict. c. 99), the
whole of the act is repealed except sections I'J and 20, which are hero
printed. By one of the repealed sections, sect. 3, bankers issuing notes
were bound to register the name of the firm and of the partners in the
bank at the stamp office in Dublin.
1 & 2 Geo. 4, c. 72. GO:
issued by tlie said bank during tbe year next ensuing
respectively, and that any such composition heretofore made
shall be in force according to the terms thereof, as if this act
had not passed.
20. And be it further enacted, that although any bank or Cancelling
banker's note or notes shall be signed or otherwise executed "ot^^ ami
by any banker or bankers duly registered in manner herein- j.°°jgtJ^^ti
before mentioned, or by his or thoir servant or servants, yet if bankers,
the same shall remain in a book and be part of the leaves, or
any one leaf thereof, and not cut or separated therefrom, then
and in every such case if such note or notes remaining in
such book shall be brought to the stamp office in Dublin, it
shall and may be lawful to and for the said commissioners of
stamps, or any of them, or any officer by them duly autho-
rized, and they are hereby required to cancel the stamps
thereon respectively, and to mark or stamp any vellum, parch-
ment, or paper which shall be brought to the said office by
the person or persons so bringing such note or notes with
any marks or stamps which he or they may require, on such
person or persons paying the difference or price (if any)
between the stamps so cancelled, and the stamps or marks so
required to be marked or stamped on the vellum, parchment,
or paper so brought to the said stamp office.
T/ic Banh of Ireland Restriction Act.
1 & 2 Geo. 4, c. 72.
An Act to establish an Agreement icitli the Governor and
Company of the Banh of Ireland for advancing the Sum
o/" 500,000^. Irish Currency; and to empoiver the said
Governor and Company to enlarge the Capital Stock or
Fund of the said Bank to 3,000,000^. (a).
[2nd July, 1821.]
6. And be it further enacted, that from and after the Persons in
passing of this act, it shall and may be lawful for any number P'^^^^^'l^P'''
of persons in Ireland, united or to be united in societies or n^iipg^fo^
partnerships, and residing and having their establishments or Dublin may
houses of business at any place not less than 50 miles distant borrow any
from Dublin, to borrow, owe, or take up any sum or sums of sum of money
money on their bills or notes payable on demand, and to ^Qtes^^'a^.^ble
{a) By the Statute Law Revision Act, 1873, (36 & 37 Vict. c. 91),
sections 1, 2 and 8 are repealed ; the remaining sections, 3, 4 and 5,
relating to the capital of the Bank of Ireland, and the receipt of its notes
in payment of the public debt, are not printed.
698
APPENDIX OF STATUTES (iRELANd).
on clcmand,
without being
liable to
penalty.
21 & 22 Geo.
3 (I.).
No other
privilege
to be granted
to partner-
ships.
make and issue such notes or bills accordingly, payable on
demand, at any place in Ireland exceeding the distance of 50
miles from Dublin, all the individuals composing such societies
or copartnerships being liable and responsible for the due
payment of such bills and notes ; and such persons shall not
be subject or liable to any penalty for the making or issuing
such bills or notes ; anything in an act made in the parliament
of Ireland, holden in the 21st and 22nd years of the reign
of his late Majesty King George the Third, intituled "An
Act for establishing a bank by the name of the Grovernor and
Company of the Bank of Ireland," to the contrary notwith-
standing.
7. Provided always, that no further or other power, privi-
lege, or authority shall, previous to the said 1st day of
January, 1838, nor until after payment to the said governor
and company of all sum and sums of money which now are or
hereafter shall or may become due to them from government,
be granted to any copartnership or society of persons what-
soever, contrary to the laws now in force for establishing and
regulating the bank of Ireland, save and except the power of
enabling such societies and copartnerships as aforesaid, re-
siding and carrying on their business not less than 50 miles
from Dublin, to sue and be sued in the name of a public
officer, should parliament hereafter think fit to grant such
a power.
1 & 2 Geo. 4,
c. 72.
Societies of
persons more
than six in
number may
be bankers in
Ireland at
places 50
miles from
The Bankinrj Cojmrtnerships Regulation Act.
6 Geo. 4, c. 42.
An Act for the better Rec/ulcition of Copartnerships of certain
Bankers in Ireland {a). [10th June, 1825.]
2. And whereas an act was passed in the session of parlia-
ment holden in the 1st and 2nd years of his present Majesty's
reign, intituled "An Act to establish an agreement with the
Governor and Company of the Bank of Ireland, for advancing
the sum of 500,000/. Irish currency ; and to empower the said
governor and company to increase the capital stock or fund of
the said bank to three millions," and it is expedient that the
said last-recited act should be altered and amended, be it
further enacted, that from and after the passing of this act, it
shall and may be lawful for any number of persons, xmited or
to be united in any society or co2)artucrship in Ireland, con-
sisting of more than six in number, and not having the
(rt) The Statute Law Revision Act, 1873, (3G & 37 Vict. c. 91), repeals
sects. 1, 4 and 8.
6 Geo. 4, c. 42. 699
establishments or houses of business of such society or co- Dublin, aud
partnership at any place or places less than 50 miles distant issue bills and
from Dublin, to carry on the trade and business of bankers, ^°*j^^^g^^-^g^o.
in like manner as copartnerships of bankers, consisting of not responsible. °
more than six in number, may lawfully do ; and to borrow,
owe, or take up any sum or sums of money on their bills
or notes, payable on demand, or at any time after date, or
after sight, and to make and issue such notes or bills accord-
ingly at any place in Ireland, exceeding the distance of 50
mUes from Dublin, all the individuals composing such societies
or copartnerships being liable and responsible for the due pay-
ment of all such bills and notes, in manner hereinafter
provided ; anything contained in an act made in the parlia- Notwith-
ment of Ireland, in the 21st and 22nd years of the reign of -Jf l,ro- "^^^JJ'J^ ^°*®^
missory notes under the provisions of this act^ it shall be ^^ J^g^. ^j^
lawful for the commissioners of stamps, or their officers, to demand, and
cancel and allow as spoiled the stamp upon such certificate, to grant
and in lieu thereof to grant to such banker or bankers a licence licences imder
under the authority of this act ; and every such licence shall, ^^^^ f^erTof .
during its continuance in force, also authorize the re-issumg
of all promissory notes payable to the bearer on demand,
which such banker or bankers may have previously issued
on paper duly stamped, until the 24th day of March inclusive
712
APPENDIX OF STATUTES (iRELAXd).
Bankers
licensed
under this act
to issue all
their promis-
sory notes of
payment of
money to the
bearer on
demand on
unstamped
paper.
Bankers
issuing un-
stamped notes
to give se-
curity by bond
for the due
performance
of the con-
ditions herein
contained.
then next following', proYided sucli notes may so long be
lawfully re-issued.
6. Provided always, that if any banker or bankers who shall
take out a licence under the authority of this act, shall issue
under the authority either of this or any other act, any un-
stamped promissory notes for payment of money to the bearer
on demand, such banker or bankers shall, so long as he or
the}' shall continue licensed as aforesaid, make and issue on
unstamped paper all his or their promissory notes for pajmient
of money to the bearer on demand, of whatever amount or
value (not exceeding the sum of 100^.) such notes may be ;
and it shall not be lawful for such banker or bankers, during
the period aforesaid, to issue, for the first time, any such pro-
missory note as aforesaid on stamped paper.
7. That before any licence shall be granted to any person or
persons to issue any unstamped promissory notes imder the
authority of this act, such person or persons shall give security
by bond to his Majesty, his heirs and successors, with a con-
dition that if such person or persons do and shall from time
to time enter or cause to be entered, in a book or books to be
kept for that purpose, an account of all such unstamped pro-
missory notes as he or they shall so as aforesaid issue, specify-
ing the amount or value thereof respectively, and the several
dates of the issuing thereof, and in like manner also a similar
account of all such promissory notes as, having been issued as
aforesaid, shall have been cancelled, and the dates of the can-
celling thereof ; and do and shall from time to time, when
thereunto recjuested, produce and show such accounts to and
permit the same to be examined and inspected by the said
commissioners of stamps, or any officer of stamps appointed
under the hands and seals of the said commissioners for that
p)urpose ; and also do and shall deliver to the said commis-
sioners of stamps half-yearly (that is to say), within 14 days
after the 1st day of January and the 1st day of July in every
year, a just and true account in writing, verified upon the
oaths or afiirmations (which any justice of the peace is hereby
empowered to administer), to the best of the knowledge and
belief of such person or persons, and of his or their cashier,
accountant or chief clerk, or of such of them as the said com-
missioners shall require, of the amount or value of all im-
stamped promissory notes issued under the provisions of this
act in circulation, Avithiu the meaning of this act, on a given
day, that is to say, on Saturday in every week, for the space
of ]ialf-a-year prior to the half-yearly day immediately pre-
ceding the delivery of such account, together with the average
amount or value of such promissory notes so in circulation
according to such account ; and also do and shall pay or cause
to he 2>uid to the receiver yeneral of slamp duties in Ireland, or
9 Geo. 4, c. 80. 713
to some other jjerson duly authorized hij the commissioners of
stamps to receive the same, as a composition for the duties tvhich
u-ould otherwise have been payable for such promissory notes
issued or in circulation during such half year, the sum of Is. 6d.
for every 100/., and also for the fractional part oflOOl. of the
said averaye amount or value of such notes in circidation, ac-
cording to the true intent and meaning of this act ; and on due
performance thereof such bond shall be void, but otherwise the
same shall be and remain in full force and virtue (a).
8. That every unstamped promissory note issued under the For -what
provisions of this act shall, for the purpose of pajTaent of P^"?^ ^g°*^^
duty, be deemed to be in circulation from the day of the issu- ^pg^^^^
ing to the day of the cancelling thereof, both clays inclusive, circulation,
excepting nevertheless the period during -svhich such note
shall be in the hands of the banker or bankers who first
issued the same, or by whom the same shall be expressed to
be payable, or, in case of copartnerships of more than six
persons, which shall be in the hands of the public officers of
such copartnership.
9. That in every bond to be given pursuant to the directions Eegulations
of this act, the person or persons intending to issue any such F^^-'^P,^^^"^ *^®
unstamped promissory notes as aforesaid, or such and so many ^?^^^ °^
of the said persons as the commissioners of stamps, or their ^y^n^^i to this
proper officer in that behalf, shall require, shall be the act.
obligors ; and every such bond shall be taken in the sum of
100/., or in such larger sums as the said commissioners of
stamps, or such officer as aforesaid, may judge to be the
probable amount of the composition or duties that will be
payable from such person or persons under or by virtue of
this act during the period of one year ; and it shall be lawful
for the said commissioners, or such officer as aforesaid, to fix
the time or times of payment of the said composition or duties,
and to specify the same in the condition to every such bond ;
and every such bond may be recj^uired to be renewed from
time to time, at the discretion of the said commissioners, or of
such officer as aforesaid, and as often as the same shall be
forfeited, or the parties to the same, or any of them, shall die,
become bankrupt or insolvent, or reside in parts beyond the
seas.
10. That if any alteration shall be made in any copartner- Fresh bonds
ship of persons who shall have given any such security by to be given on
bond as by this act is directed, whether such alteration shall ^"^^^4^°°!
be caused by the death or retirement of one or more of the g^ips.
partners of the firm, or by the accession of any additional or
new partner or partners, a fresh bond shall, within one
calendar month after any such alteration, be given by the re-
(«) By a & 6 Vict. c. 82, s. 1, this composition duty is repealed.
714
APPENDIX OF STATUTES (iRELAND).
Penalty on
bankers re-
fusing to
renew their
bonds.
This act not
to exempt
from penalties
any persons
issuing un-
stamped notes
not in ac-
cordance
herewith.
Penalties how
and by whom
to be re-
covered.
Not to affect
the privileges
of the Bank
of Ireland.
maining partner or partners, or tlie persons composing the
new copartnersHi), as the case may be, which bond shall be
taken as a security for the duties which may be due and
owing, or may become due and owing in respect of the un-
stamped promissory notes which shall have been issued by
the persons composing the old copartnership, and which shall
be in circulation at the time of such alteration, as well as for
duties which shall or may be or become due or owing in
respect of the imstamped promissory notes issued or to be
issued by the persons composing the new copartnership ; pro-
vided that no such fresh bond shall be rendered necessary by
any such alteration as aforesaid in any copartnership of per-
sons exceeding six in number, but that the bonds to be given
by such last-mentioned copartnerships shall be taken as se-
curities for all the duties they may incur so long as they shall
exist, or the persons composing the same or any of them shall
carry on business in copartnership together, or with any
other person or persons, notwithstanding any alteration in
such copartnership ; saving always the power of the said
commissioners of stamps to rec^uire a new bond in any case
where they shall deem it necessary for better securing the
payment of the said duties.
11. That if any person or persons, who shall have given
security by bond to his Majesty in the manner hereinbefore
directed, shall refuse or neglect, for the space of one calendar
month, to renew such bond when forfeited, and as often as
the same is by this act required to be renewed, such person
or persons so offending shall for every such offence forfeit and
pay the sum of 100^.
12. Provided always, that nothing in this act contained shall
extend or be construed to extend to exempt or relieve, from
the forfeitures or penalties imposed by any act or acts now in
force upon persons issuing promissory notes not duly stamped
as the law requires, any person or persons who, under any
colour or pretence whatsoever, shall issue any unstamped pro-
missory note, unless such person or persons shall bo duly
licensed to issue such promissory note under the provisions of
this act, and such note shall be drawn and issued in strict
accordance with the regulations and restrictions herein con-
tained.
13. That all pecuniary forfeitures and penalties which may
be incurred under any of the provisions of this act, shall bo
recovered for use of his Majesty, his heirs and successors, in
any of his Majesty's courts of record, by action of debt, bill,
plaint, or information, in the name of his Majesty's attorney
or solicitor-general in Ireland.
14. Provided always, that nothing in this act contained
shall extend or be construed to extend to prejudice, alter, or
9 GrEo. 4, c. 80. 715
affect any of the rights, po^vers, or privileges of the Governor
and Company of the Bank of Ireland.
15. [Commissioners of stamps to cancel re-issuable pro-
missory note stamps rendered unnecessary by the act, and to
repay the amount, if application made within six calendar
months after passing of the act ; section exhausted or expired.]
16. And whereas by an act passed in the 6th year of the 6Geo. 4, c. 42.
reign of his present Majestj^, intituled " An Act for the better No society or
regulation of copartnerships of certain bankers in Ireland," copartnership
any certificate granted by the commissioners of stamps in g|j°|^^|f^'^
Ireland, to any society or copartnership of bankers in Ireland obliged to
exceeding six in number, of the registry of the firm and name take out
of such society, is liable to the stamp duty payable by law on more than
certificates to be taken out yearly by any banker or bankers in J^J^g^^^J^
Ireland, that is to say, a stamp duty of 30^. : and whereas it ^^^^^^ ^ °^^
is provided by the said recited act, that a separate and distinct
certificate, with a separate and distinct stamp, shall be granted
for and in respect of every town or place where any such bills
or notes as in the said act are mentioned shall be issued^ by
any such society or copartnership : and whereas it is expedient
that no such society or copartnership should be recjuired to
take out more than four certificates in any one year, although
it should issue such bills or notes as aforesaid at more than
four towns or places in Ireland ; be it therefore further
enacted, that no society or copartnership of bankers in Ireland
exceeding six in number, and carrying on the trade or busi-
ness of bankers under the authority of the said recited act,
shall be obliged to take out more than four certificates in any
one year of the entry and registry of the firm or name of such
society or copartnership ; and in case any such society or co-
partnership shall issue such bills or notes as _ aforesaid, by
themselves or their agents, at more than fonr dift'erent towns
or i)laces in Ireland, then after taking out three distinct cer-
tificates for three of such towns or places, such society or co-
partnership shall be entitled to have all the remainder of such
towns or places included in a fourth certificate ; anything in
the said act of the sixth year of the reign of his present
Majestv to the contrary notwithstanding.
17. That every certificate which hath been or shall at any Certificates to
time hereafter be taken out by any such last-mentioned continue in
society or copartnership as aforesaid, shall continue in force, JjJ^^^jJ**'^^^"
for the issuing of such bills and notes as aforesaid at the J^e^h r^gisSy.
town or place or the several towns or places therein named,
until the 2.5th day of March next following the date of such
certificate, notwithstanding any fresh entry or registry of the
name or firm of such society or copartnership ; and that if any
fresh entry or registry shall be made from any cause whatever,
after any such society or copartnership shall have taken out
716
APPENDIX OF STATUTES (iRELANd).
four sucli distinct certificates as aforesaid, sucli society or co-
partnersliip shall not be required to take out any further cer-
tificate, in respect of any town or place not included in any of
such fom' certificates, until the 24th day of March next
following such fresh entry or registry.
No banker in
Ireland to
issue notes
which shall
not express to
be payable at
the place
where issued.
Notes issued
contrary
hereto shall
be valid
against the
party issuinpr;
who shall also
be liable iu
double the
amount.
Bank Notes payable n-Jicre iissiied.
9 Geo. 4, c. 81.
An Act for making Promissory Notes 2oayablc, issued by Banks,
Banking Companies, or Bankers, in Ireland, at the Places
ivhere they are issued. [2oth July, 1828.]
Whereas divers banks, banking companies, and bankers, in
Ireland, have made and issued promissory notes, without
making the same payable in coin of the realm at the several
places respectively where such notes have been issued or re-
issued : and whereas it is expedient that in future all such
promissory notes, and all bank post bills issued by such banks,
banking companies, or bankers, shoidd be made payable at
the places where the same shall be issued or re-issued ; be it
therefore enacted, &c., that from and after the 1st day of
Ajpril, 1829, no bank, banking company, or banker, in Ireland,
shall, by themselves, or by any agent or agents, partner or
partners, or other person or persons whomsoever on their or
his behalf, or on their or his account, make, issue, or re-issue,
in any place in Ireland where such bank, banking company,
or banker shall have any house or establishment for business,
or any authorized resident agent or agents, any promissory
note or bank post bill of any denomination whatsoever, being
or purporting to be the note or notes, bank post bill or bank
post bills of the bank, banking company, or banker, making,
issuing, or re-issuing the same, Avhich shall not be payable at
the places respectively where the same shall be made, issued,
or re-issued by or on behalf of such bank, banking company,
or banker ; and in every such note the place where the same
shall have been issued or re-issued shall be expressly men-
tioned : lu-ovided nevertheless, that if any such promissory
note or bank post bill shall be issued or re-issued contrary to
the provisions of this act, the same shall nevertheless not only
be valid against the bank, banking company, or banker
issuing or re-issuing the same by any of the wa3-s or means
aforesaid, but such bank, banking company, or banker, shall
be liable and bound to pay, in the lawful coin of the realm,
double the amount of the sum specified in each such note or
bank post bill (to bo sued for and recovered by the holder
11 Geo. 4 & 1 Will. 4, c. 32. 717
thereof in any of his Majesty's coui'ts for tlie recovery of
debts in Ireland, by action of debt, bill, plaint, or infor-
mation), either at the place -where the same shall have been
issued or re-issued by or on behalf of such bank, banking
company, or banker, or at any other place where such bank,
banking company, or banker shall have any house or esta-
blishment for business, notwithstanding such note or bank
post bill shall not be expressed to be so payable, or shall be
or expressed to be otherwise jiayable : provided always, that Not to prevent
nothing herein contained shall extend to prevent any such "ot «'>^'-\ P- 726.
728
APPENDIX OF STATUTES (iRELANu).
Oatlis to be
taken by
directors, &c.
of the Bank
of Irclaud.
Bankers
claiming to be
entitled to
issue bank
notes to give
notice to com-
missioners of
stamps and
taxes.
Commission-
ers to certify
c.xi.stiDgbauks
of issue and
limitation of
issue.
4 & 5 Vict.
c. uO.
Governor and Company of the Bank of England as here-
tofore.
7. That from and after the passing of this act it shall not be
necessary for any governor, deputy governor, or director of the
said bank, before acting in the said several offices or trusts,
to make and subscribe the declaration pursuant to the act of
parliament passed in the kingdom of Ireland, intituled "An
Act to prevent the further growth of poper}'," nor to take any-
other oaths than the oath of allegiance, the oath of qualifica-
tion by possession of stock and the oath of fidelity to the cor-
poration prescribed in and by the charter of incorporation of
the governor and company of the said bank, and that it shall
not be necessary for any member of the said corporation, before
voting in any general court, to make and subscribe the afore-
said declaration, nor to take any other oaths than the oaths of
allegiance, the oath of qualification by the possession of stock,
and the oath of fidelity to the said corporation provided in the
said charter of incorporation : provided always, that in case
any of the persons called Quakers shall at any time be chosen
governor, deputy governor, or director, or shall be or become
a member of the said corporation, it shall be sufficient for such
person or persons to make his or their solemn affirmation, to
the purport and effect of the oaths prescribed by the said charter
and by this act to be taken by governors, deputy governors,
directors, or members respectively of the said corporation.
8. That every banker claiming to be entitled to issue bank
notes in Ireland shall, within one month next after the passing
of this act, give notice in writing to the commissioners of
stamps and taxes, at their head office in London, of such
claim, and of the place and name and firm at and under which
such banker has issued such notes in Ireland during the year
next preceding the 1st day of May, 1845, and thereupon the
said commissioners shall ascertain if such banker was on the
6th day of May, 1844, and from thence up to the 1st day of
May, 1845, carrj-iug on the business of a banker, and lawfully
issuing his own bank notes in Ireland, and if it shall so appear,
then the said commissioners shall proceed to ascertain the
average amount of the bank notes of such banker which were
in circulation during the said period of one j'ear preceding the
1st day of May, 1845, according to the returns made by such
banker in piu'suance of the act passed in the 4th and 5th years
of the reign of her present Majesty, intituled "An Act to
make further provisions relative to the returns to be made by
banks of the amount of their notes in circulation," and the said
commissioners, or any two of them, shall certify under their
hands to such banker the average amount, when so ascer-
tained as aforesaid, omitting the fractions of a pound, if any;
and it shall be laAvf ul for every such banker to continue to
8 & 9 Vict. c. 37. 729
issue liis own bank notes after the 6th day of December,
1845, to the extent of the amount so certified, and of the
amount of the gokl and silver coin held by such banker, in
the proportion and manner hereinafter mentioned, but not to
any further extent ; and from and after the 6th day of Prohibiting
December, 1845, it shall not be lawfid for any banker to issue by un-
make or issue bank notes in Ireland, save and except only ccrtmed
such bankers as shall have obtained such certificate from the
commissioners of stamps and taxes.
9. Provided always, that if it shall bo made to appear to Trovision for
the commissioners of stamps and taxes that any two or more united banks,
banks have, by written contract or agreement (which con-
tract or agreement shall be produced to the said commis-
sioners), become united withiu the year next preceding such
1st day of May, 1845, it shall be lawful for the said commis-
sioners to ascertain the average amount of the notes of each
such bank in the manner hereinbefore directed, and to certify
a sum ecpial to the average amount of the notes of the two or
more banks so united as the amount which the united bank
shall thereafter be authorized to issue, subject to the regvda-
tions of this act.
10. That the commissioners of stamps and taxes shall, at Duplicate of
the time of certifying to any banker such particulars as they certificate to
are hereinbefore required to certify, also piiblish a duplicate ^^ published
of their certificate thereof in the next succeeding Dublin Q^zette
Gazette in which the same may be conveniently inserted ; and p ++ + r
the gazette in which such publication shall be made shall be gyi^ence
conclusive evidence in all courts whatsoever of the amount of
bank notes which the banker named in such certificate or
duplicate is by law authorized to issue and to have in circula-
tion as aforesaid, exclusive of an amount equal to the monthly
average amount of the gold and silver coin held by such
banker as herein provided.
11. That in case it sliall be made to appear to the commis- In case banks
sioners of stamps and taxes at any time hereafter that any become
two or more banks have, by -written contract or agreement "°it'^'i> ^om-
(which contract or agreement shall be produced to the said ^rtifv^the '^
commissioners), become united subsequently to the passing amount of
of this act, it shall be lawful to the said commissioners, upon bank notes
the application of such luiited bank, to certify, in manner "^^'luch each
hereinbefore mentioned, the aggregate of the amount of bank °, ^^^^, ,
notes which such separate banks were previously authorized issue,
to issue under the separate certificates previously delivered to
them, and so from time to time ; and every such certificate
shall be published in manner hereinbefore directed ; and from
and after such publication the amount therein stated shall be
and be deemed to be the limit of the amount of bank notes
which such united bank may have in circulation, exclusive of
730
APPENDIX OF STATUTES (iRELANd).
Banks
entitled to
the privilege
of issuing
notes may
relinquish the
same:
but not
resiune
the issue.
Limitation of
bank notes in
circulation.
Issue of notes
for frac'tional
parts of a
pound i)ro-
hibited.
Issuing banks
to render
accounts
weekly.
an amount equal to tlie montlily average amount of the gold
and silver coin held b}' such banker as herein provided.
12. That it shall be lawful for any banker in Ireland who
under the provisions of this act is entitled to issue bank notes
to contract and agree with the Grovernor and Company of the
Bank of Ireland, by an agreement in writing, for the relin-
quishment of the privilege of issuing such notes in favour of
the said governor and company, and in each such case a copy
of such agreement shall be transmitted to the commissioners
of stamps and taxes ; and the said commissioners shall there-
upon certify, in manner hereinbefore mentioned, the aggre-
gate of the amount of bank notes which the Bank of Ireland
and the banker with whom such agreement shall have been
made were previously authorized to issue under the sepa-
rate certificates j)reviously delivered to them ; and every
such certificate shall be published in manner hereinbefore
directed ; and from and after such publication the amount
therein stated shall be the limit of the amount of bank notes
which the Governor and Company of the Bank of Ireland
may have in circulation, exclusive of an amount equal to the
amount of the gold and silver coin held by the Bank of Ireland
as hertnn provided.
13. That it shall not be lawful for any banker who shall
have so agreed to relinquish the privilege of issuing bank
notes at any time thereafter to issue any such notes.
14. That from and after the 6th day of December, 1845, it
shall not be lawful for any banker in Ireland to have in cir-
culation, upon the average of a period of four weeks, to be
ascertained as hereinafter mentioned, a greater amount of
notes than an amount composed of the sums certified by the
commissioners of stamps and taxes as aforesaid, and the
monthly average amount of gold and silver coin held by such
banker during the same period of four weeks, to be ascer-
tained in manner hereinafter mentioned.
15. That all bank notes to be issued or re-issued in Ireland
after the Gth day of December, 1845, shall be expressed to
be for payment of a sum in pounds sterling, without any
fractional parts of a pound ; and if any banker in Ireland
shall from and after that day make, sign, issue, or re-issue
any bank note for the fractional part of a pound sterling,
or for any sum together with the fractional part of a pound
sterling, every such banker so making, signing, issiung, or
re-issuing, any such note as aforesaid shall for each note so
made, signed, issued, or re-issued forfeit or pay the sum of
201.
16. Tliat every banker Avho after the 6th day of December,
1845, shall issue bank notes in Ireland shall, on some one day
in every week after the 13th day of December, 1845 (such day
8 & 9 Vict. c. 37. 731
to be fixed by tlie couimissiouers of stamps aud taxes),
transmit to the said commissioners a just and true account
of the amount of bank notes of such banker in circulation
at the close of the business on the next preceding- Saturday,
distinguishing the notes of ol. and upwards, and the notes
below bl., and also an account of the total amount of gold
and silver coin held by such banker at each of the head offices
or principal places of issue in Ireland of such banker at the
close of business on each day of the week ending on that
Saturday, and also an account of the total amount of gold
and silver coin in Ireland held by such banker at the close
of business on that day ; and on completing the first period
of four weeks, and so on completing each successive period
of four weeks, every such banker shall annex to such
account the average amount of bank notes of such banker
in circulation diu-ing the said four weeks, distinguishing the
bank notes of 5^. and upwards, and the notes below bl., and
the average amount of gold and silver coin respectively held
by such banker at each of the head offices or principal places
of issue in Ireland of such banker during the said four weeks,
and also the amovmt of bank notes which such such banker is,
by the certificate published as aforesaid, authorized to issue
under the provisions of this act; and every such account shall
be verified by the signature of such banker or his chief
cashier, or in the case of a company or partnership by the
signature of the chief cashier or other officer duly authorized
by the directors of such company' or partnership, and shall be
made in the form to this act annexed marked (A.) («) : and if
any such banker shall neglect or refuse to render any such
account in the form and at the time required by this act, or
shall at any time render a false account, such banker shall
forfeit the sum of 100/. for every such offence.
17. That all bank notes shall be deemed to be in circulation What shall be
from the time the same shall have been issued by any banker, ^eemcd to be
or any servant or agent of such banker, until the same shall circulatioii ^^
have been actually returned to such banker, or some servant or
agent of such banker.
18. That from the returns so made by each banker to the Commission-
commissioners of stamps and taxes the said commissioners ^^^ of stamps
shall, at the end of the first period of four weeks after the monthlv
said 6th day of December, 1845, and so at the end of each return.
successive period of four weeks, make out a general return in
the form to this act annexed marked (B.) {b) of the monthly
average amount of bank notes in circulation of each banker
in Ireland during the last preceding four weeks, and of the
(«) See note (a), post, p. 732.
{h) Sec note {h), post, p. 733.
733 APPENDIX OF STATUTES (iRELAND).
average amount of all tho gold and silver coin held by such
banker during the same period, and certifying, under the
band of any officer of the said commissioners duly authorized
for that purpose in the case of each such banker, whether
siich banker has held the amount of coin required by law
during the period to which the said return shall apply, and
shall publish the same in the next succeeding Dublin Gazette
in which the same can be conveniently inserted.
[a] SCHED-ULE (A.)
Name and title set forth in licence
Name of the firm
Head offices or principal places of issue
Amount of notes in circulation on \ £5 and ujjwards .... £
Saturday, the day of . ) Under £5 £
Total £
Bank.
Firm.
Place.
Amount of gold and silver coin held at the head office or principal place
of issue at the close of business on —
Head Office
at
Head Office
at
Head Office
at
Head Office
at
Gold
Silver
Gold
SUver
Gold
Silver
Gold
Silver
Monday the
Tuesday the
"Wednesday the
Thursday the
Friday the
Saturday the
Total amount of coin held at the close of business on Saturday, the
day of 18 .
Gold £
Silver _£
Total £
\_To be inserted in the aecount at the end of each period of four u-ccksA
Amoimt of notes authorized by certificate £
Average amount of notes in circulation \ £5 and upwards £
dui'ing the four weeks ending as above j Under £5 .... £
Average amoimt of coin held during the said ) Gold .... £
four weeks j Silver .... £
Total £
I being the [banker, chief cashier, director or partner,
an the case may he\ do hereby certify, that the above is a true account of
the notes in circulation, and of the coin held by the said bank, as required
under the act 8 & 9 Vict. c.
Signed
Dated this day of 18 .
8 & 9 Vict. c. 37.
733
19. That for the purpose of ascertaining the monthly
average amount of bank notes of each banker in circulation,
the aggregate of the amount of bank notes of each such
banker in circulation at the close of the business on the
Saturday in each week during the first complete period of
four -weeks next after the 6th day of December, 1845, shall be
divided by the number of weeks, and the average so ascer-
tained shall be deemed to be the average of bank notes of
each such banker in circulation during such period of four
weeks, and so in each successive period of four weeks ; and
the monthly average amount of gold and silver coin respec-
tively held as aforesaid by such banker shall be ascertained in
like manner from the amount of gold and silver coin held by
such banker at the head offices or principal places of issue of
such banker in Ireland, as after mentioned, at the close
of business on such day in each week ; and the monthly
average amount of bank notes of each such banker in circula-
tion during any such period of four weeks is not to exceed a
sum made up by adding the amount certified by the com-
missioners of stamps and taxes as aforesaid and the monthly
average amount of gold and silver coin held by such banker
as aforesaid during the same period.
20. That in taking account of the coin held by any banker
in Ireland with respect to which bank notes to a further
extent than the sum certified as aforesaid by the commis-
sioners of stamps and taxes may, under the provisions of this
act, be made and issued, there shall be included only the gold
Mode of as-
cei'tainiug" the
average
amount of
bank notes of
each banker
in circulation,
and gold coin,
during the
first four
weeks after
the 6th day of
December,
18i5.
Wliat shall
be taken in
the account of
coin held by
any banker.
(b) Schedule (B.)
Name and
Title,
as set
forth in
the
Licence.
Name
of tlie
rii'm.
Head
Office, or
principal
Place of
Issue.
Circula-
tion au-
thorized
by Cei-ti-
flcate.
Average Circulation
during Four Weeks
ending the
Average Amormt of
Coin held during'
Four Weeks ending-
1^"
3
is .
3
^
5
w
I hereby certify, that each of the bankers named in the above return
who have in circulation an amount of notes beyond that authorized iu
theii- certificate [with the exception of A. B. or C. D., as the case may be,"]
have held an amount of gold and silver coin not less than that which they
are required to hold during the period to which this retuni relates.
(Signed) Officer of Stamp Duties.
Dated this day of 18 .
734
APPENDIX OF STATUTES (iRELAND).
Silver coin
not to exceed
the proportion
of one quarter
of ffold.
Commission-
ers of stamps
and taxes em-
powered to
cause the
books of
bankers, con-
taining ac-
counts of
their bank
notes in cir-
culation, and
of gold coin,
to be in-
spected.
Penalty for
refusing to
allow such
inspection.
and silver coin lield by such, banker at the several head offices
or principal places of issue in Ireland of such banker, such head
offices or principal places of issue not exceeding four in number,
of "which not more than two shall be situated in the same pro-
vince ; and every banker shall give notice in writing to the
said commissioners, on or before the 6th day of December
next, of such head offices or principal places of issue at which
the account of gold and silver coin held by him is to be taken
as aforesaid ; and no amount of silver coin exceeding one
fourth part of the gold coin held by such banker as aforesaid
shall be taken into account, nor shall any banker be authorized
to make and issue bank notes in Ireland on any amount of
silver coin held by such banker exceeding the proportion of one
fourth iiart of the gold coin held by such banker as aforesaid.
21. And whereas in order to ensure the rendering of true
and faithful accounts of the amount of bank notes in circula-
tion, and the amount of gold and silver coin held by each
banker, as directed by this act, it is necessary that the com-
missioners of stamps and taxes should be empowered to cause
the books of bankers issuing such notes, and the amount of
gold and silver coin held by such bankers as aforesaid, to be
inspected as hereinafter mentioned ; be it therefore enacted,
that all and every the book and books of any banker who
shall issue bank notes under the provisions of this act, in
which shall be kept, contained, or entered any accoixnt,
minute, or memorandum of or relating to the bank notes
issued or to be issued by such bank, of or relating to the
amount of such notes in eii'culation from time to time, or of or
relating to the gold or silver coin held by such banker from
time to time, or any account, minute, or memorandum the
sight or inspection whereof may tend to secure the rendering
of true accounts of the average amount of such notes in cir-
culation and gold or silver coin held as directed by this act,
or to test the truth of any such account, shall be open for the
inspection and examination at all seasonable times of any
officer of stamp duties authorized in that behalf by writing
signed by the commissioners of stamps and taxes, or any two
of them ; and every such officer shall be at liberty to take
copies of or extracts from any such book or account as afore-
said, and to inspect and ascertain the amount of any gold or
silver coin held by such banker ; and if any banker or other
person keeping any such book, or having the custody or j^os-
session thereof or power to produce the same, shall, upon
demand made by any such officer showing (if required) his
authority in that behalf, refuse to produce any such book to
such officer for his inspection and exaiiiination, or to permit
him to inspect and examine the same, or to take copies
thereof or extracts thorofroni, or of or fi-om any sucli accoimt.
8 & 9 Vict. c. 37. 735
minute or memorandum as aforesaid, kept, contained, or
entered therein, or if any banker or other person having the
custody or possession of any coin belonging to such banker
shall refuse to permit or prevent the inspection of such gold
and silver coin as aforesaid, every such banker or other person
so offending shall for every such offence forfeit the sum of
100^. : provided always, that the said commissioners shall not
exercise the powers aforesaid without the consent of the
commissioners of her Majesty's treasury.
22. That every banker in Ireland, other than the Bank of All bankers
Ireland, who is now carrying on or shall hereafter carry on to return their
l)usiness as such, shall, on the first day of January in each ^^™cs once a
year, or within 15 days thereafter, make a return to the com- \^^^-^,-, q^^^q
missioners of stamps and taxes, at their office in Dublin, of '
his name, residence, and occupation, or, in the case of a
company or partnership, of the name, residence, and occupa-
tion of every person composing or being a member of such
company or partnership, and also the name of the firm under
which such banker, company, or partnership carrying on the
business of banking, and of every place where such business
is carried on ; and if any such banker shall omit or refuse to
make such return within 15 days after the said 1st day of
January, or shall wilfully make other than a true return of
the persons as herein required, every banker so offending
shall forfeit or pay the sum of 50^. ; and the said commis-
sioners of stamps and taxes shall on or before the 1st day of
March in every year publish in the Dublin Gazette a copy of
the return so made by every banker.
23. That if the flionthly average circulation of bank notes Penalty on
of any banker, taken in the manner herein directed, shall at banks issuing
any time exceed the amount which such banker is authorized i^ excess.
to issue and to have in circulation under the provisions of this
act, such banker shall in every such case forfeit a sum equal
to the amount by which the average monthly circulation,
taken as aforesaid, shall have exceeded the amount which
such banker was authorized to issue and to have in circula-
tion as aforesaid.
24. That all promissory or other notes, bills of exchange, Notes for less
or drafts, or undertakings in writing, being negotiable or than 20s. not
transferable, for the payment of any sum or sums of money, negotiable in
or any orders, notes, or undertakings in writing, being nego- ■'■^^^^'i^'
tiable or transferable, for the delivery of any goods, sjiecifying
their value in money less than the sum of 20s. in the whole,
heretofore made or issued, or which shall hereafter be made
or issued in Ireland, shall, from and after the 1st day of
January, 1846, be and the same are hereby declared to be
absolutely void and of no efl'eet, any law, statute, usage, or
custom to the conti'ar}^ thereof in anywise notwitlistanding ;
736
APPENDIX OF STATUTES (IRELAND.)
Notes for 20s.
and above,
and le.ss than
M., to Le
drawn in
certain
foi-m ((•).
find that if any person or persons sliall, after the 1st day of
January, 184G, by any art, device, or means whatsoever,
publish or utter in Ireland any such notes, bills, drafts, or
engagements as aforesaid, for a less sum than 20s., or on
■which less than a sum of 20s. shall be due, and which shall
be in anywise negotiable or transferable, or shall negotiate
or transfer the same in Ireland, every such person shall
forfeit and pay for every such offence any sum not exceeding
20/. nor less than 5/., at the discretion of the justice of the
peace who shall hear and determine such offence.
25. That all promissory or other notes, bills of exchange,
or drafts, or undertakings in writing, being negotiable or
transferable, for the payment of 20s., or any sum of money
above that sum and less than 5/.. or on which 20s., or above
that sum and less than 5Z., shall remain undischarged, and
which shall be issued within Ireland at any time after the 1st
day of Januaiy, 1846, shall specify the names and places of
abode of the persons respectively to whom or to whose order
the same shall be made payable, and shall bear date before
or at the time of drawing or issuing thereof, and not on any
day subsequent thereto, and shall be made payable within the
space of 21 days next after the date thereof, and shall not be
transferable or negotiable after the time hereby limited for
pajmient thereof, and that every indorsement to be made
thereon shall be made before the expiration of that time, and
to bear date at or not before the time of mating thereof, and
shall specify the name and place of abode of the person or
persons to whom or to whose order the money contained in
every such note, bill, draft, or undertaking is to be paid ; and
that the signing of every such note, bill, draft, or imdertaking,
and also of every such indorsement, shall be attested by one
subscribing witness at the least ; and which said notes, bills
of exchange, or drafts, or undertakings in writing, may be
made or drawn in words to the purport or effect as set out in
the .schedules to this act annexed marked (D.) («) and(E.) (h)\
and that all promissory or other notes, bills of exchange,
or drafts, or undertakings in writing being negotiable or
transferable, for the payment of 20s., or any sum of money
(ff) Schedule (D.).
[^Place] [_day'\ {jnontW] [yeny'\
Twonty-one days after date I promise to pay to A. B. of [_placc], or his
order, the sum of for value received by
Witness, E. F. C. D.
A)ul the Indurscmcnt, toties quoties.
[Drt//] \jiwn(h'\ [//mr]
Piiv the contents to Cr. II. of \_i)h(ce], or his order.
Witness, J. K. A. B.
(Jj) See note (i), post, p. 737.
{<') See note {c), post, p. 737,
8 & 9 YiCT. c. 37. 737
above that sum and less than 5/., or in which 205., or above
that sum and less than 5/., shall remain undischarged, and
which shall be issued in Ireland at any time after the said 1st
day of January, 1846, in any other manner than as aforesaid,
and also every indorsement on any sucli note, bill, draft, or
other undertaking to be negotiated under this act, other than
as aforesaid, shall and the same are hereby declared to be
absolutely void, any law, statute, usage, or custom to the con-
trary thereof in anywise notwithstanding ; provided that
nothing in this clause contained shall be construed to extend
to any such bank notes as shall be lawfully issued by any
banker in Ireland authorized by this act to continue the issue
of bank notes (c).
26. That if any body politic or cor2:)orate or any person or Penalty for
persons shall, from and after the said 1st day of January, persons other
1846, make, sign, issue, or re-issue in Ireland any promissory tlian 'bankers
note payable on demand to the bearer thereof for any sum of ^^^^^ ^jTidno- "
money less than the sum of 51., except the bank notes of such notes payable
bankers as are hereby authorized to continue to issue bank on demand for
notes as aforesaid, then and in either of such cases every such ^^^^ *^^^ ^^'®
body politic or corporate or person or persons so making, P°"° '^^
signing, issuing, or re-issuing any such promissory note as
aforesaid, except as aforesaid, shall for every such note so
made, signed, issued, or re-issued forfeit the sum of 20/.
27. That if any body politic or corporate or person or Penalty for
persons shall, from and after the passing of this act, publish, persons other
utter, or negotiate in Ireland any promissory or other note than bankers
(not being the bank note of a banker hereby authorized to ^.^^ed utterino-
continue to issue bank notes), or any bill of exchange, draft, or or negotiating
undertaking in writing, being negotiable or transferable, for notes, bills of
the payment of 20s., or above that sum and less than 51., or exchange,
on which 20s., or above that sum and less than 51., shall f °;', j^^^**'.
remain undischarged, made, drawn, or indorsed in any other payment of
manner than as is hereinbefore directed, every such body 20s., or less
politic or corj)orate or person or persons so publishing, utter- than five
ing, or negotiating any such promissory or other note (not poinds.
{b) Schedule (E.).
[^Flace] [_da!/'] [^month'] [ye^'']
Twenty-one days after date pay to A. B. of \_ place"], or his order, the
sum of value received, as advised by
To E. F. of [place]. C. D.
Witness, G. H.
And the indorsement, toties quoties.
[Z'fl'.y] \_month] [y^«>']
Pay the contents to J. K. of [_ place], or his order.
"Witness, L. M. ^ A. B.
(c) By 27 & 28 Vict. c. 20, the restrictions on the issue of these notes
were removed originally for three years, and now continued by 36 & 37
Vict. c. 75, to the 13th May, 1874.
G. 3 B •
APPENDIX OF STATUTES (iRELAND).
Not to pro-
liibit cheques
on bankers.
being such bank note as aforesaid, bill of exchange, draft, or
undertaking in writing as aforesaid, shall forfeit and pay the
snm of 201.
28. Provided always, that nothing herein contained shall
extend to prohibit any draft or order drawn by any person on
his banker, or on any person acting as such banker, for the
payment of money held by such banker or person to the use
of the person by whom such draft or order shall be
drawn.
29. That all pecuniary penalties under this act maybe sued
or prosecuted for and recovered for the use of her Majesty, in
the name of her Majesty's attorney-general or solicitor-general
in Ireland, or of the solicitor of stamps in Ireland, or of any
person authorized to sue or prosecute for the same, by writing
under the hands of the commissioners of stamps and taxes, or
in the name of any officer of stamp duties, by action of debt,
bill, plaint, or information in the Court of Exchequer in
Dublin, or by civil bill in the court of the recorder, chairman,
or assistant barrister within whose local jurisdiction any offence
shall have been committed, in respect of any such penalty, or,
in respect of any penalty not exceeding 201., by information
or complaint before one or more justice or justices of the peace
in Ireland, in such and the same manner as any other penal-
ties imposed by any of the laws now in force relating to the
duties under the management of the commissioners of stamps ;
and it shall be lawful in all cases for the commissioners of
stamps and taxes, either before or after any proceedings
commenced for recovery of any such penalty, to mitigate or
compound any such penalty as the said commissioners shall
think fit, and to stay any such proceedings after the same
shall have been commenced, and whether judgment may have
been obtained for such penalty or not, on pajnnent of part
only of any such penalty, with or without costs, or on payment
only of the costs incurred in such proceedings, or of any part
thereof, or on such other terms as such commissioners shall
judge reasonable : provided always, that in no such proceed-
ing as aforesaid shaU any essoign, protection, wager of law,
nor more than one imparlance be allowed ; and all pecuniary
penalties imposed by or incurred under this act, by whom or
in whose name soever the same shall be sued or prosecuted
for or recovered, shall go and be applied to the use of her
INIajesty, and shall be deemed to be and shall bo accounted
for as part of her Majesty's revenue arising from stamp
duties, any thing in any act contained, or any law or usage,
to the contrary in anywise notwithstanding : provided always,
that it shall be lawful for the commissioners of stamps and taxes,
at their discretion, to give all or any part of such penalties
as rewards to any person or persons who shall have detected the
8 & 9 Vict. c. 37. 739
offenders, or given information xohich may have led to their
prosecution and conviction (a).
30. That after the passing of this act every company or co- Companies to
partnership of more than six persons estahHshed. before the sue and be
passing of this act, for the purpose of carrying on the "trade or ^^^^^ ^^^^^^
business of bankers within the distance of 50 miles from ^^^^^'^ oi t'l^n-
Dublin, shall have the same powers and privileges of suing
and being sued, and of presenting petitions to found se-
questrations or fiats in bankruptcy, in the name of any one
of the public officers of such company or copartnership, as the
nominal plaintiff, petitioner, or defendant, on behalf of such
company or copartnership, as are provided with respect to
companies carrying on the said trade or business at any place
in Ireland exceeding the distance of 50 miles from Dublin,
under the provisions of an act passed in the 6th year of
the reign of Kang Greorge the Foiu-th, intituled " An Act for G Geo. 4,c. 42.
the better regulation of copartnerships of certain bankers in
Ireland ;" and all judgments, decrees, and orders made and
obtained in any action, suit, or other proceeding brought,
instituted, or carried on by or against any such company or
copartnership carrying on business within the distance of 50
miles from Dublin, in the name of their public officer, shall
have the same effect and operation, and may be enforced in
like manner in all respects, as is provided in and by the last-
mentioned act with respect to the judgments, decrees, and
orders therein mentioned ; provided that every such company
or copartnership as last aforesaid shall make out and deliver
from time to time to the commissioners of stamps and taxes
the several accounts or returns required by the last-mentioned
act ; and all the provisions of the last-mentioned act as to such
accoimts or returns shall be taken to apply to the accounts or
returns so made out and delivered by the said last-mentioned
companies, as if they had been originally included in the pro-
visions of the last-mentioned act.
32. That the term '' bank note " used in this act shall Inteipre-
extend and apply to all biUs or notes for the payment of tation of act.
money to the bearer on demand; and that the term "banker"
shall, when the Bank of Ireland be not specially excej)ted,
extend and apply to the Gfovernor and Company of the Bank
of Ireland, and to all other corporations, societies, partner-
ships, and persons, and every individual person carrying on
the business of banking, whether by the issue of bank notes
or otherwise ; and that the word " coin " shall be construed to
mean the coin of this realm; and that the word " j)erson "
used in this act shall include corporations ; and that the
singular number used in this act shall include the plural
{a) This repealed by 38 k 39 Vict. c. 6G.
3 b2
^40
APPENDIX OF STATUTES (iRELAND).
number, and the plural number the singular, except where
there is anything in the context repugnant to such construc-
tion ; and that the masculine gender in this act shall include
the feminine, except where there is anything in the context
repugnant to such construction.
Stamp duties
in Ireland,
5 & G Vict,
c. 82, and
continued by
8 & 9 Vict.
0. 2, 11 & 12
Vict. c. 9,
14 & 15 Vict.
0. 18, and
15 & IGVict.
0. 21, made
peqjetual.
Acts con-
tinued in
force.
Stamp Duties in force for a limited Period made
Perpetual.
16 & 17 Vict. c. 59, s. 20.
An Act . ... to make perpetual certain Stamp Duties
in Ireland («). [4th August, 1853.]
20. And whereas by an act passed in the session of par-
liament held in the 5th and 6th years of her Majesty's reign,
chapter 82, certain rates and duties, denominated stamp
duties, were granted and made payable in Ireland for a
limited term ; and by four several acts passed respectively
in the 8th, 11th, 14th and 15th years of her Majesty's
reign, the same rates and duties were continued for four
other several and successive terms, the last of which will
expire on the 10th day of October, 1853; and it is expedient
to make the said rates and duties perpetual.
All the several sums of money and duties, and composition
for duties granted and made payable in Ireland by the said
act of the 5th and 6th years of her Majesty, chapter 82, and
not repealed by any subsequent act, and also all duties now
payable in lieu or instead of any of the said duties which
may have been so repealed, shall be and the same are hereby
continued and made perpetual, and shall be charged, raised,
levied, collected, and paid unto and for the use of her
Majesty, her heirs and successors for ever. The said act of
the 5th and 6th years of her Majesty, and all and every other
act or acts now in force in relation to the duties and com-
position for duties which are continued by this act, shall
severally be continued and remain in full force in all respects
in relation to the said duties and composition for duties
hereby continued and granted, and all and every the powers
and authorities, rules, regulations, directions, penalties, for-
feitures, clauses, matters and things contained in the said
acts or any of them, and in force as aforesaid, shall severally
and respectively be duly observed, practised, applied and put
(a) The Inland Ecvenuo llepeal Act, 1870, 33 & 34 Vict. c. 99, s. 2,
excepts sect. 20 from its operation, so far as it continues or perpetuates
jiny enactment, wliich is thereby repealed.
27 & 28 Vict. c. 8G. 741
in execution in relation to the said duties, and compositions
for duties hereby continued and granted, for the charging,
raising, levpng, paying, accounting for, and securing of the
said duties and composition for duties, and all arrears thereof ;
and for preventing, detecting and punishing of all frauds,
forgeries, and other offences relating thereto, as fully and
effectually to all intents and purposes as if the same powers,
authorities, rvdes, regulations, directions, penalties, forfeitures,
clauses, matters and things were particularly repeated and
re-enacted in the body of this act with reference to the said
duties and composition for duties hereby granted.
Compositions for Stamp Duty on Bank Post Bills of 61. and
iqnvards.
27 & 28 YiOT. c. 86.
An Act to permit for a limited Period Compositions for Stamp
Duty on Bank Post Bills of 51. and upivards in Ireland.
[29th July, 1864.]
Whereas by an act passed in the 16th and 17th years of 16 & 17 Vict.
her Majesty's reign, chapter 63, the commissioners of her ^- ^•^•
Majesty's treasury are authorized and empowered to com-
pound and agree with all or any bankers in Scotland or
elsewhere for a composition in lieu of the stamp duties
payable on the bills of exchange of such bankers: and
whereas it is expedient to permit bankers in Ireland for a
limited period to compound for the stamp duties payable on
their bank post bills as well as on their bills of exchange : be
it enacted, &c. as follows:
1. It shall be lawful for the commissioners of her Majesrty's Power to
treasury and they are hereby authorized and empowered to treasury to
compound and agree with any banker in Ireland for a com- ^^bankers
position in lieu of the stamp duties payable on the bank post j^ Ireland
bills to be made or drawn by such banker at any time duriny for the stamp
the period of three years from the passiny of this act (a), for duty on bank
any sum of money amounting to 51. or upwards, and such ^g^*Q^o|
composition shall be made on the like tei-ms and conditions ^'j^j.^^ years.
and with such security as the said commissioners are by the
said act empowered to require in the case of compounding for
the stamp duties on bills of exchange; and upon such com-
position being entered into by such banker it shall be lawful
for him duriny the period aforesaid («), to make, draw, and
(a) These words repealed by Statute Law Revision Act, 1875.
742
APPENDIX OF STATUTES (iRELAND).
issue all such bank post bills, for wMcli composition stall
have been made, on unstamped paper, anything in any act
contained to the contrary notwithstanding.
27 & 28 Vict.
c. 86.
PoTvers of
27 & 28 Vict,
c. 8G, made
perpetual.
Short title.
Compositions for Stani]) Duty on Bank Post Bills of 61. and
upwards.
30 & 31 YicT. c. 89.
An Act to render perpetual an Act passed in the Session /widen
in the 27th and 2Sth Years of her i^resent Majesty, intitided
^^ An Act to permit for a limited Period Compositions for
Stamp Duty on Bank Post Bills of 51. and rqnvards in
Ireland:' [12th August, 18G7.]
Whereas by an act passed in the session holden in the 27th
and 28th years of the reign of her present Majesty, chapter
86, intituled " An Act to permit for a limited period com-
positions for stamp duty on bank post bills of hi. and upwards
in Ireland," the commissioners of her Majesty's treasury are
empowered to compound and agree, in manner therein men-
tioned, with any banker in Ireland for a composition in lieu
of the stamp duties payable on the bank post bills to be made
or drawn by such banker at any time during the period of
three years from the passing of the said act for any sum of
money amounting to 5^. and upwards: and whereas it is
expedient to make perpetual the powers conferred by the said
act: be it enacted, iSrc, as follows:
1. The powers conferred by the said act of the session of
the 27th and 28th years of the reign of her i)resent Majesty
shall be perpetual, and the said act shall he construed as if
the- words " during the period of three years from the passing of
this act''^ had been omitted therefrom {h).
2. This act may be cited for aU purposes as " The Stamp
Duty Composition (Ireland) Act, 1867."
{h) These words repealed by Statute Law Revision Act, 1875.
INDEX.
ACCEPTANCE,
may be genei-al or qualified, 102 — 107.
what is a qualified, ib.
1 & 2 Geo. IV. c. 7, ib.
"payable at a bankers," 103.
when presentment must be proved, ib.
holder of draft may refuse to take a qualified, 102.
conditional, 105.
■whether acceptance is or is not question of law, ib.
per procuration, 300.
order to banker to obtain, 118.
order to banker to accept drafts against biUs of lading, ib.
ACCOIBIODATIOX BILL, 279.
notice of dishonour not required as against di'awer of, 536.
proof upon, 537.
ACCOL^T,
customer opening account with banker, 1.
opening by partners, 30, 260.
authority of one partner to open, and to transfer, ib.
coi-poration, 32.
trustees, 29.
infants, 26.
executors, ib.
agent, 27.
companies, 33.
keeping customer',?, 195. {See Pass Book.)
accounts at several branches, 199, 428. {See Beanch Banks.)
debiting account with costs of action, 198.
charging with interest, 199.
deposit, 3.
customer overdi-awing, 1.
disclosing state of, 6, 44.
trust accounts, 275 — 280. (-S^-eTEtrsTEES.)
Bank of England does not take notice of trusts, 317.
ACCOUNTABLE OR DEPOSIT RECEIPTS, 125.
what is an accountable receipt, ib.
what stamp required, ib.
liability of banker on change of firm, 127.
on bankruptcy of firm, 128.
double liability on, 129.
whether it is a negotiable instrument, 130.
may bo subject of a donatio mortis causa, ib.
Statute of Limitations applies to, ib.
forging, 131.
obtaining by false pretence, 133.
744 INDEX.
ACCOUNTANT-GENERAL, cheques of, 21.
ADMINISTRATOR. {See Executoe.)
ADVANCES. {See Deposit of Sectteities.)
by manager, 472.
guaranty to secure, 202. {See Guaeaijties.)
to directors, 274.
AGENT. {See Bankee, Relation of, and Coeeespondent ; Oedees
TO Bankees ; Joint Stock Companies.)
■when he can bind principal by drawing or indorsing cheques, 27.
when liable personally, ib.
indorsing or accepting bills " per proc," 300.
liability of agent indorsing bill, 301.
banker making himself agent, 5, 133.
notice to agent, 162.
London agent, 135.
frauds by, 184.
taking shares, liability of, 565.
ALTERATION,
avoids " cheque " if material, 14.
altering date is material, ib.
fraudulent, who must suffer, 1 7.
altering number on bank note. {See Addendum.)
APPROPRIATION OF PAYMENTS, 236.
general rule as to, ib.
in case of partnership, 236.
distinct account, 238.
legal and illegal items, 242.
as to baiTing Statute of Limitations, ib.
specific appropriation of payments, ib.
where banker becomes bankrupt, ib.
in cases of guaranty, 208.
ARTICLES OF ASSOCIATION. {See Limited Banking Companies.)
under Companies Act, 1862. .406.
what it must contain, ib.
and how stamped, ib.
how altered, ib.
ASSIGNEE OF BANKRUPT. {See Bankettptcy and Teustee in
Bankeuptcy.)
ASSIGNMENT,
of debt, 115.
of shares, 107.
of policies, 163.
ATTACHMENT OF FUNDS IN BANKER'S HANDS, 487.
under Judicature Act, ib.
debt must be absolute not conditional, ib.
foreign attachment in Mayor's Court, 488.
does not apjily to a corporation, ib.
nor to consols, 489.
INDEX.
745
ATTACHMENT OF FUNDS IN BANKER'S HANDS— co«.
effect of account opened in wife's name, 28.
and in their joint names, ib.
separate estate under Married Women's Act, 29.
and rights of the wife to invest and sue, ib.
wife can sue for dishonouring cheque, ib.
wife taking shares in company, and her and her husband's
liability, 437, 438, 504.
INDIAN BANKS, 425.
INDORSEMENT. {Sec Cheques ; Bills of ExcHAsaE ; Discoitnt.)
of cheques, 22.
conditional, of bill, 299.
restrictive, of bill, ib.
what amounts to, ib.
"per proc," 301.
liability of person indorsing as agent, ib.
INFANT,
cheques by, 26.
shareholder, liability of, 505.
INTEREST. [Sec Pass Book.)
on deposits, 4, n., 125.
on rests, 199.
on balances, ib.
comijoiind, ib.
IRISH BANKS, 326.
JOINT-STOCK BANKS, 375. {Sec Limited Banking Companies ;
Winding Up ; Shares.)
restrictions upon, 329, 375.
siunmary of the statutes relating to issue by, 376.
under 7 Geo. IV. c. 4G, ib.
return of names under 7 Geo, IV. c. 46, ib.
what the return proves, 377.
annual returns, 378.
contracts by copartnerships under 7 Goo. IV. c. 46. .380.
how such partnerships shoidd sue and be sued, ib.
setoff, 381.
effect of judgment, decrees and orders, ib.
registering judgments against members, 382.
statute still in force, 383.
INDEX. 763
JOINT STOCK BA:^KS—co>itini.
may be made to cover futui-e advances, ib.
when fixtiu'es pass, 169.
mortgagee of lease not bound to take legal assignment,
171.
remedy, is foreclosure, ib.
Statute of Limitations, ib.
as against whom mortgage will prevail, 173.
by comxjany, 175.
policies of insurance, 161.
shares, 163.
scrip certificate, 167.
biUs of exchange, &c., 177.
bills of lading, 179.
goods, 183.
ships, 185.
MUTUAL CREDIT AND SET OFF. {See Banketjptcy.)
NOTES, 340. {See Bake Notes.)
NOTICE,
of dishonor of cheques, 62.
bills and notes, 349, 536.
to branch banks, 429.
to company, thi-ough directors, 451.
service of, on manager, 464.
OFFICER. {See Public Officee.)
ORDERS TO BANKERS, 102.
orders to pay, 102.
bills of exchange, ib.
bills drawn payable at bankers, ib.
general or qualified acceptances, ib.
acceptances under 1 & 2 Geo. IV. c. 78, ib.
to whom payable, 107.
paying in forged bUl, banker not protected, ib.
banker recci\'ing sum to meet bill cannot apply to other
purposes, 108, 110.
when is bill paid, ib.
payment by cheques provisional or absolute, 109.
refusal of banker to pay, 110.
no action lies by holder, ib.
money specifically appropriated to take up bills, ib.
cancellation by mistake. 111.
refusal of holder to take a special acceptance, 112.
bills payable " in case of need," ib.
promissory notes, 113.
not within 1 '& 2 Geo. IV. c. 73, ib.
made payable at bankers, ib.
INDEX.
'67
ORDERS TO BXKKEBS—co»ii»Hed.
orders other tlian mere orders to pay, 113.
appropriation or assignment of funds in favour of third
person, 114.
■when such order can be revoked, il>.
cheque not an equitable assignment, 115.
how assigned in la-w, ib.
under Judicature Act, il>.
banker's liability to assignee, ib.
order to receive dividends, 116.
how stamped, ib.
order to hold money as stakeholder, 117.
contracts of wagering void under 8 &9 Vict. c. 109, s. 18, ib.
subscription for winner of lawful game excepted, ib.
order to obtain acceptance, 118.
order to accept drafts against bills of lading, ib.
order to transfer or place to credit of another, ib.
order to invest money, 119.
as to deposit of securities for safe keeping. {Sec Deposit of
Secxteities fok Safe Custody.)
general liability of bankers on such deposit, 120.
order as to trust fimds, 122.
following trust monies in banker's hands, 123.
application of Clai/to/i^s case, ib.
illegal orders of customers, ib.
PAETNERSHIPS AT COMMON LAW, 251.
liability of firm for partner's contracts, ib.
no implied authority to transfer banking account, ib.
drawing or indorsing bills, 252.
submission to arbitration, ib.
pledging property, ib.
liabilitj' of firm for pai-tner's wrongs, ib.
defence in actions by partner, 255.
joint and several liability of partners, ib.
in equity is joint and several, ib.
death of partner, 256.
no sur\-ivorship of goodwill, ib.
partnerships in other firms, ib.
change of firm and substitution of liability, 257.
incoming partners, 258.
partnership account with banker, 260.
PASS BOOKS, 195.
what it is, ib.
change of firm, 197.
when credit given in, binds the banker, ib.
feloniously making a false entry in, 198.
mode of keeping accounts in, ib.
accounts at several branches, 199. {Sec Beaxch BA^•KS.)
when interest and commission can be charged, i4.
deduction of income tax, 201.
PAYMENT,
appropriation of, 236. {See Appeopeiation.)
after notice of bankruptcy, 525. {Set Bankeuptcy.)
stopping payment of cheque for benefit of payee's creditors, ib.
768 INDEX.
'PAYMEiHT— continued.
of cheques, 36. [See Cheques.)
in forged notes, 38.
in country bank notes, 39.
in bills of exchange, 41.
in cash, 43.
part payment of cheque, ib.'
cheques as evidence of, 74.
of lost cheque, 89.
of lost note, 355.
by cheques, 109.
in Bank of England notes, 34 1, 342.
in country bank notes, ib.
PLATE. {See Deposit.)
deposit of, with banker, 191.
liability of banker, ib.
PLEDGE,
with banker, 183. {See Deposit.)
how far available for subsequent advances, ib.
when default made, banker may sell, ib.
pledgor not the i-eal owner, ib.
liability of banker, 184.
POLICIES OF INSURANCE, 161. {See Deposit.)
is a chose in action within Bankruptcy Act, ib.
notice need not be given as against the trustee of depositor of, 162.
notice should be sent for other purposes, ib.
assignment of policies, ib.
POST-DATING CHEQUES, 14.
POWER OF ATTORNEY,
to transfer stocks by, 313.
by forged power, 314.
forging, to receive dividends, 321.
PRESENTMENT,
of cheques, 49. {See Cheques.)
time for, ib.
as between payee and drawer, ib.
payee and drawee, 51,
transferee and payee, 52.
transferee and di-awer, ib.
place of, ib.
through Clearing House, 53.
by post, 57.
stale or overdue, ib.
when presentable for payment, 59.
dispensing with, 61.
of bms, 84, 85, 103. {See Bills.)
of notes, 345. {See Bank Notes.)
PROMISSORY NOTES, 328. {See Banks of Issue.)
of Bank of England, exempt from stamp duty, 329.
stamp duty on, 330.
lien on, 244, 248.
deposit of, 177.
payable at bankers, 113.
INDEX. 769
PUBLIC OFFICES, 375. {Sse Joixt Stock Bank?.)
duties of, 376, 474.
actions and suits by and against, 380, 47o.
judgments, decrees, and orders against, 3S1, 479.
how payment to bo realized, ib.
indemnity of, 480.
death, resignation or removal, 478.
criminal proceedings by and against, 48.
RECEIPTS, 125. [Ses Accouxtable oe Deposit Receipts.)
stamp on banker's, 125
RECEIVER.
pajdng into bank, 282.
REGISTER, 411. {See Joint Stock Banks ; Limited Banks.)
of members, 411.
what it must contain, if).
rectifying register, 412.
inspection of, 413.
of office, 409.
of mortgage, 415.
effect of neglect, 415.
who must do so, ib.
of judgments, 382.
REGISTRATION OF JOINT STOCK BANKS, 393, 395, 400, 422.
REMITTANCES, 372. {See Discount ; Relation of London and
Country Bankees ; Commission.)
loss of note remitted to creditor by debtor, 373.
when banlier liable for loss of, 133, 131.
remittances abroad, 374.
of bank post bills, 152.
sijecific ax^propriation of, 135.
REPUTED OWNERSHIP, 523. {Sec Bankruptcy.)
RETURNS. {See Joint Stock Banks ; Banks of Issue.)
of names under 7 Geo. IV. c. 46. ,376.
what return proves, 377.
annual, 378.
to stamp office, 382.
of notes in circulation, ib.
SAVINGS BANKS, 262.
definition of, ib.
how formed, ib.
deposits, rules to be observed, 263.
purchase of annuities in, 265.
deposit book, ib.
remedies of depositors, 266.
investments, 267.
weelily and annual accounts, ib.
officers in, must give security, 268.
loss by acts or misconduct of, ib.
trustees of, 270.
civil liability of, 271.
criminal liability, ib.
Military, Naval, and Post Office savings banks, ib.
SCOTCH BANKS, 422.
G. 3 D
770 INDEX.
SCRIP CERTIFICATE,
what it is, 1G7.
passes by delivery, ili.
must be stamped, ib.
deposit of, ib.
SECURITIES. {Sec Deposit op Securities.)
SET-OFF, 293, 539. {See Bankeuptcy.)
what debts can be, 510.
must be in same right, ib.
object of Sect. 39 of Bankruptcy Act, ib.
persons liable on bills, &c., to a bank buying up their notes after
stoj)page to, 354,
as to country bank notes, 352.
as to contributories' right of, 508.
against calls, 138.
SHARES AND SHAREHOLDERS, 431. {See Dibectoe3 ; Wind-
ixG-up ; Deposits; Lien; Joint Stock Banks.)
are personal propei-ty, ib.
equitable mortgage of, 161, 432.
scrip certificate, 167.
purchase or sale of shares, 432.
contract for sale not within 17th sect, of Statute of Frauds, 433.
stamp required for contract, ib.
purchase of, induced by fravid, ib., 410, 506.
transfer of, ib. 434.
consent of directors, 434, 456.
liability of transferee, 510.
shareholders, 435. {See Winding-up.)
who are, under Companies Act, ib.
and under 7 Geo. IV. c. 46, ib.
applicants and allottees, 503.
bankrupt's trustee, ib.
directors, 504.
infants, 505.
legatees, ib.
principal and agent, ib.
trustees, 506.
executors, 437, 504.
husband and wife, ib., 504.
liability of husband, ib.
Married Women's Property Act, 438.
spiritual persons, ib.
calls, 439.
when to be made, ib.
money due on, is specialty debt, 439.
charging shares, 441.
when it operates, 442.
how it may be made, ib.
banker's lien on. {See Lien.)
appropriating, by directors, 451.
purchase of, by comjDany, 455.
enhancing price of, dii'ectors, 459.
suiTeuder of, 400.
forfeiting, 461.
shareholders' liability on wiuding up. {See Winding up.)
criminal liability of sliarcholders, 481.
SHIP. {See Deposit to secure Advances.)
mortgage on, IS 5.
under Merchant Shipping Act, 1S51, ib.
INDEX.
SKIP— mitiiiiicd.
direct mortgage with registration, 185.
moi'tgage under certificate, 1S6.
equities may be enforced against mortgagees, 187.
ecjuitable mortgage of, valid without registration, ib.
SHORT BILLS, Uo. {Sc-e Deposit.)
STAMPS. {See Appendix.)
on receipts of banker, 125.
on cheques, 18.
cancelling, 19.
on order to receive dividend, 110.
on letter of credit, 100.
bank notes, 33-5.
adhesive, 18.
on order to pay a sum of money out of a debt, 115.
on bills. {See Appendix.)
STOCK. {See Bank of England.)
contract for the sale of, 309.
in public funds, 308.
transfer of, 310 — 315.
transfer by executor, 311.
by joint proprietors, 312.
mortgage of, 315.
investment of trust funds in Bank of England, 323.
bequests of, 326.
charging, 318.
STOPPAGE OF BANK, not act of bankruptcy, 517.
SURETY. {See Guaeanty.)
release of, 208.
by variation of agreement, ib.
time or indulgence given to principal, 209.
non-disclo.sure, 211.
creditors taking security, 213.
release of debtor, 215.
payment, 218.
TENDER. {See Bank Notes.)
in bank notes, 39.
of coin, 36.
TITLE DEEDS, 1G&. {See Deposit to secxtee Advances.)
TRANSFER OF STOCK, 310—315. {SeeSwcx.)
of shares, 434. {See Shakes.)
TRUST PROPERTY, lien as to, 246.
TRUSTEE IN BANKRUPTCY. (5ec Bankkuptct.)
cheques drawn by, 26.
as contributory, 503.
TRUSTEES,
depositing trust funds with banker, 275.
liability of, 270.
mixing trust fund with his o^vn, 278.
banker's liability for misapplication by, 281.
payment to, 279.
CO -trustee must join, ib.
liability for co-trustee, 280.
cheques of, 29.
when shareholders, 506.
771
772 INDEX.
TUVSTEES— continued.
"when liable as contributories, 506.
investing in bank stock, 323.
TRUSTEES OF PUBLIC BODIES, 273.
TEUSTS, Bank of England does not notice, 317. (See Trustee.)
UNCLAIMED DIVIDENDS, 322.
ITNLIMITED BANKING COMPANIES, 375, 397. {See Joint
Stock Banks.)
converting into limited liability, 397. {See Li>nTED Banks.)
WARRANT FOR DIVIDENDS,
sent by post, 321.
making out false, 322.
"WILL, what words in, pass an account at bankers, 2.
bank note, 342.
WINDING-UP AND DISSOLUTION,
of banking copartnerships, 490.
of limited banking companies, 491.
compulsory, 492.
petition for, 494.
restraining actions against company, ib.
forwarding order to registrar, 495.
voluntary, ib.
imder supervision of court., 497.
liquidators, ib.
prosecuting delinquent lic^uidators, 485.
winding-up of companies existing before 1862. .500.
contributories generally, 502.
applicants, 503.
allottees, ib.
bankrupt's trustee, ib.
directors, 504.
executors and administrators, ib.
females marrying, ib.
infants, 505.
legatees, ib.
principals and agents, id,
trustees, 506.
purchasers by means of misrepresentation, 506.
scripholders, ib.
list of contributories, ib.
past members, 507.
rectifying register on settling list,'__508,
proving debts, ib.
making calls, ib.
right of set off, ib.
nature of liability, 510.
extent of liability, ib.
enforcing calls, ib.
dissolution of companies on winding-up, 511.
other modes of winding up, 512.
of colonial banks, 513.
WITNESS, obligation of banker to give evidence, 4.
C. F. EOWOETH, PEINTEE, BEEAll'S BUILDINGS, ClIANCEEY LANE, E.G.
•wjpllfincnt
FOURTH EDITION OF GRANT'S TREATISE
LAW RELATmCi TO BANKERS
BANKING COMPANIES,
CONTAIXIXG THE
BILLS OF EXCHANGE AND BILLS OF SALE ACTS, 1882,
V/ITH NOTES.
BY
CLAUDE C. M. PLUMPTRE,
OF THE MIDDLE TEMPLE, BAKRISTER-AT-LAW, ESQ.
Middk Temple Common Law Scholar, Hilary Term, 1877,
Author of " A Summary of the Law of Simple Contracts."
LONDON:
BUTTERWORTHS, 7, FLEET STREET,
ICatD \0u6lis'^crs to tijc C^uccn's most excellent JWajcstn.
HODGES, FIGGIS & CO., GRAFTON STREET, DUBLIN.
CALCUTTA: THACKER, SPINIC & CO. MELBOURNE: GEORGE ROBERTSON.
MANCHESTER : JMEREDITH, RAY & LITTLER.
EDINBURGH : T. & T. CLAEK ; BELL & BRADFUTE.
1882.
LONDON :
PRINTED BY C. F. EOWOETH, BREAM'S BUTLDINOS, CHANCERY LANE.
( -73 )
BILLS OF EXCHANGE ACT. 1882.
4.5 & 46 YiCT. c. 01.
An Act to codify the law relating to Bills of Exchange, Cheques,
and Promissory Notes. [18tli August, 1882.]
Be it enacted by the Queen's most excellent Majesty, by and
■with the advice and consent of the Lords Spiritual and
Temporal, and Commons, in this present Parliament assembled,
and by the authority of the same, as follows :
PAET I.— PRELIillNAP.Y.
1. This act may be cited as the Bills of Exchange Act, Short title.
1882 («).
2. In this act, unless the context otherwise requires,— Interpreta-
" Accejjtance " means an acceptance completed by delivery tionof teims.
or notification (b).
" Action " includes counter claim and set off.
" Banker " includes a body of persons whether incorporated
or not who carry on the business of banhing.
" Bankrupt " includes any person whose estate is vested in
a trustee or assignee under the law for the time being
in force relating to bankruptcy.
"Bearer" means the person in possession of a bill or note
which is payable to bearer.
"Bill" means bill of exchange, and "note" means pro-
missory note (c).
"Delivery" means transfer of possession, actual or con-
structive, from one person to another {d).
"Holder" means the payee or indorsee of a bill or note
who is in possession of it, or the bearer thereof (e).
" Indorsement " means an indorsement completed by
delivery (/).
(rt) The law relating to the issue of bank notes is not affected by this
act (sect. 97). The act extends to Ireland and Scotland, and only to
bills, cheques, and notes.
(b) See sect. 21 as to what constitutes "delivery."
(c) For fui-ther definition of "bill," see .sect. 3 (1), and for "note,"
see sect. 83; for defiuition of "bill payable on demand," see sect. 10,
and for "cheques," sect. 73.
(d) As to what amounts to an effectual delivery, see sect. 21.
{e) For definition of " holder in due course," see sect. 29.
(/) As to the requisites of a valid indorsement, and as to the kinds of
indorsements, see sects. 32, 33, 34, 3o.
G. ^ I^
774
SUPPLEMENT.
" Issue " means the first delivery of a bill or note, complete
in form to a person wlio takes it as a holder.
" Person " includes a body of persons whether incorporated
ornot(/).
"Value" means valuable consideration (5^).
"Written" includes printed, and "writing" includes
print.
PAET II. — Bills of ExcnAxoE.
Form and Interpretation.
Bill of 3. (1.) A bill of exchange is an unconditional order in
exchange writing, addressed by one person (//) to another ii), signed by
defined. ^-j^g person giving it, requiring the person to whom it is
addressed to pay on demand or at a fixed or determinable
future time a sum certain in money to or to the order of a
specified person {!<), or to bearer.
(2.) An instrument which does not comply with these con-
ditions, or which orders any act to be done in addition to the
payment of money, is not a bill of exchange.
(3.) An order to pay out of a particular fund is not uncon-
ditional within the meaning of this section ; but an unqualified
order to pay, coupled with (a) an indication of a particular
fund out of which the drawee is to reimburse himself or a
particular account to be debited with the amount, or (b) a
statement of the transaction which gives rise to the bill, is
unconditional.
(4.) A bill is not invalid by reason —
(a.) That it is not dated (^) ;
(b.) That it does not specify the value given, or that
any value has been given therefor ;
(c.) That it does not specify the place where it is
drawn or the place where it is payable.
Inland and 4. (1.) An inland bill is a bill which is or on the face of it
foreign bills, purports to be (a) both drawn and payable within the British
Islands, or (b) drawn within the British Islands upon some
person resident therein. Any other bill is a foreign bill (?»).
For the purposes of this act "British Islands" mean any
(/) As to a corporation drawing, accepting, or indorsing bills, see
sect. 22.
{g) See further as to valuable consideration, sect. 27.
(A) Called the "drawer."
\i) Called the "drawee," and if he accepts, the "acceptor."
\k) Called the "payee."
{I) See further as to dating a bill, sects. 12, 13.
\m) Foreign bills arc frequently drawn in sets. See sect. 71. The pro-
visions in the Stamp Act relating to foreig-n bills are still in force. See
sect. 07 (3). Tlic Stamp Act is printed in the Appendix to Grant, p. G43.
45 & 46 VioT. c. Gl. 775
part of the United Kingdom of Great Britain and Ireland, the
i.slands of Man, Griierusey, Jersey, Alderney, and Sark, and
the islands adjacent to any of them being part of the dominions
of her Majesty.
(2.) Unless the contrary appear on the face of the bill the
holder may treat it as an inland bill(«).
5. (1.) A bill may be drawn payable to, or to the order of. Effect whero
the drawer; or it may be drawn payable to, or to the order (different
of, the drawee. bmtrcthe
(2.) Where in a bill drawer and drawee are the same ^^^^ person,
person, or where the drawee is a fictitious person or a person
not having capacity to contract, the holder may treat the
instrument, at his option, either as a bill of exchange or as a
promissory note.
6. (1.) The drawee must be named or otherwise indicated Address to
in a bill with reasonable certainty. drawee.
(2.) A bill may be addressed to two or more drawees
whether they are partners or not, but an order addressed to
two drawees in the alternative or to two or more drawees in
succession is not a bill of exchange.
7. (1.) AYhere a bill is not paj'able to bearer, the payee Certainty
must be named or otherwise indicated therein with reasonable required as
certainty. to payee.
(2.) A bill may be made payable to two or more payees
jointly, or it may be made payable in the alternative to one
of two, or one or some of several payees. A bill may also be
made payable to the holder of an ofiico for the time being (o).
(3.) Where the payee is a fictitious or non-existing person
the bill may be treated as payable to bearer.
8. (1.) AVhen a bill contains words prohibiting transfer, or What bills
indicating an intention that it should not be transferable (]}), are ncgo-
it is valid as between the j^arties thereto, but is not nego- ^'
tiable.
(2.) A negotiable bill may be payable either to order or to
bearer.
(3.) A bill is payable to bearer which is expressed to be so
payable, or on which the only or last indorsement is an in-
dorsement in blank.
(4.) A bill is payable to order which is expressed to be so
payable, or which is expressed to be poi/able to a particidar
person, and does not contain loords j^rohibitiny transfer or indi-
cating an intention that it shoidd 7iot be transferable (g).
(«) This is new.
(o) This provision as to an alternative payee and to the holder of an
office for the time being is new.
{j}) See sects. 35, 36.
{q) This is new. A bill payable to A. B. will henceforth Lc oquiv.alent
to a bill payable to " A. B. or order."
:j E 2
776
SUPPLEMENT.
(5.) Where a bill, either originally or by indorsement, is
exj)ressed to be i-)ayable to tlie order of a specified person,
and not to liim or his order, it is nevertheless payable to him
or his order at his option.
Sum payable. 9. (1.) The sum payable by a bill is a sum certain within
the meaning of this act, although it is required to be paid —
(a.) With interest,
(b.) By stated instalments.
(c.) By stated instalments, with a provision that upon
default in payment of any instalment the whole shall
become due.
(d.) According to an indicated rate of exchange or ac-
cording to a rate of exchange to be ascertained as directed
by the bill.
(2.) Where the sum payable is expressed in words and
also in figures, and there is a discrepancy between the two,
the sum denoted by the words is the amount payable {?•).
(3.) AVhere a bill is expressed to be payable with interest,
unless the instrument otherwise provides, interest runs from
the date of the bill, and if the bill is undated from the issue
thereof.
10. (1.) A bill is payable on demand —
(a.) AVhich is expressed to be payable on demand, or at
sight, or on presentation ; or
(b.) lu which no time for payment is expressed.
(2.) Where a bill is accepted or indorsed when it is overdue,
it shall, as regards the acceptor who so accepts, or any
indorser who so indorses it, be deemed a bill payable on
demand (s).
11. A bill is payable at a determinable future time within
the meaning of this act which is expressed to be payable —
(1.) At a fixed period after date or sight (i).
(2.) On or at a fixed period after the occurrence of a speci-
fied event tchich is certain to happen, though the time of
happening may be uncertain.
An instrument expressed to bo payable on a contingency is
not a bill, and the happening of the event does not cure the
defect.
12. AVhere a bill expressed to bo payable at a fixed period
after date is issued undated, or where tlie acceptance of a bill
payable at a fixed period after sight is undated, any holder
Bill payable
on demand.
Bill payable
at a future
time.
Omis.sion of
date in bill
payable after
date.
(r) Tliis is confirmatory of the common law. See Grant, jx 16.
(«) As to when a bill payable on demand is to be deemed to be over-
due, see sect. 3G (3) ; and as to the eqiutics attaching to an overdue
bill, lb. sub-sect. 2. As to presentment of such bills, see sect. 45 (2).
As to the effect of a bankcn- paying such bills with a forged indorsement
thereon, sec sect. CO. A cheque is defined l>y sect. 73 to be a bill payable
on demand.
{!) See sects. U (2). {?,), and C. (-i). •
4o .t 4() YicT. c. 61. 777
may insert tlioreiu the true date of issue or acceptance, and
the bill shall be payable accordingl}'.
Provided that (1) -where the holder in good faith and by
mistake inserts a wrong date, and (2) in every case where a
wrong date is inserted, if the TdIII subsequently comes into the
hands of a holder in due course the bill shall not be avoided
thereby, but shall operate and be payable as if the date so
inserted had been the true date («).
13. (1.) Where a bill or an acceptance or any indorsement Ante-dating
on a bill is dated, the date shall, unless the contrary be proved, ^^. V^st-
be deemed to be the true date of the drawing, acceptance, or ^ "^=*
indorsement, as the case may be.
(2.) A bill is not invalid by reason only that it is ante-dated
or post-dated, or that it bears date on a Sunday (v).
14. Where a bill is not payable on demand (.r) the day on Computation
which it falls due is determined as follows : o* *""® °^
(1.) Three days, called days of grace, are, in every case pay°^ent.
where the bill itself does not otherwise provide, added to
the time of payment as fixed by the bill, and the bill is
due and payable on the last day of grace : Provided that —
(a.) When the last day of grace falls on Sunday,
Christmas Day, Good Friday, or a day appointed by
royal proclamation as a public fast or thanksgiving
day, the bill is, except in the case hereinafter pro-
\Tided for, due and payable on the preceding business
day (y) ;
(b.) When the last day of grace is a bank holiday
(other than Christmas Day or Good Friday) under
the Bank Holidays Act, 1871, and acts amending or 34 & 35 Vict,
extending it, or when the last day of grace is a c. 17.
Sunday and the second day of grace is a bank
holiday, the bill is due and payable on the succeed-
ing business day.
(2.) Where a bill is payable at a fixed period after date,
after sight, or after" the happening of a specified event,
the time of payment is determined by excluding the day
from which the time is to begin to run and by including
the day of payment.
(3.) Where a biU is payable at a fixed period after sight ,^
the time begins to run from the date of the acceptance if
the bill be accepted, and from the date of noting or pro-
test if the bill be noted or protested for non-acceptance,
or for non-delivery.
(4.) The term "month " in a bill means calendar month.
(«) This section is new.
((■) As to the former law relating to post-dating cheques, see Grant,
p. 14.
{x) As to what bills are payable on demand, sec sect. 10.
(y) This is new. As to the expression " business day," sec sect. 92.
/ 1'
SUPPLEMENT.
Optioual
stipvilations
by drawer or
indorser.
Definition
aud requi-
sites of ac-
ceptance.
Case of need. 15. The drawer of a till and any indorser may Insert
therein the name of a person to whom the holder may resort
in case of need, that is to say, in case the hill is dishonoured
by non-acceptance or non-payment. Such person is called the
referee in case of need. It is in the option of the holder to
resort to the referee in case of need or not as he may think
fit (z).
16. The drawer of a bill, and any indorser, may insert
therein an express stipulation —
(1.) Negativing or limiting his own liability to the holder :
(2.) "Waiving as regards himself some or all of the holder's
duties.
17. (1.) The accex-)tance of a bill is the signification by the
drawee of his assent to the order of the drawer.
(2.) An acceptance is invalid unless it complies with the
following conditions, namely :
(a.) It must be written on the bill and be signed by the
drawee. The mere signature of the drawee without
additional words is sufficient.
(b.) It must not express that the drawee will perform his
promise by any other means than the payment of money.
Time for 18. A bill may be accepted —
acceptance. (1.) Before it has been signed by the drawer, or while
otherwise incomplete («).
(2.) When it is overdue, or after it has been dishonoured
by a previous refusal to accept, or dj non-payment {b).
(3.) "When a bill payable after sight is dishonoured by non-
acceptance, and the drawee subsequently accepts it, the
holder, in the absence of any different agreement, is
entitled to have the bill accepted as of the date of fu-st
presentment to the di'awee for acceptance (c).
General and 19. (1.) An acceptance is either (a) general, or (b) quali-
qualified fied {(/).
acceptances. ^2.) A general acceptance assents without qualification to
the order of the drawer. A qualified acceptance in express
terms varies the effect of the bill as drawn.
In particular an acceptance is qualified which is —
(a.) conditional, that is to say, which makes payment by
the acceptor dependent on the fulfilment of a condition
therein stated {e) :
(:) By sect. G7 the bill mnst be noted before presentment to the referee.
It woiild seem that notice of dishonour to the referee is not notice to the
indorser {In re Leeds Bankiiuj Co., Ex parte Fnonje, L. R., 1 Eq. I).
{a) See sect. 21.
{b) Sec sects. 10, 39 (4).
(e) This sub-section is new.
{d) Sec Grant, p. 102, where the subject of general aud qualified
acceptances is fully discussed. As to the right of the holder to refuse,
and the effect of such an acceptance, see sect. 44.
{e) Sec Grant, p. 10.5.
45 & 46 Vict. c. <3l. 779
(b.) partial, tliat is to say, an acceptance to pay part only
of the amount for which the bill is drawn :
(c.) local, that is to saj', an acceptance to pay only at a
particular specified place (/) :
An acceptance to pay at a particular place is a general
acceptance, unless it expressly states that the bill is to be
paid there only and not elsewhere if) :
(d.) qualified as to time ;
(e.) the acceptance of some one or more of the drawees, but
not of all.
20. (1.) AVhere a simple signature on a blank stamped Inchoate ia-
paper is delivered by the signer in order that it may be con- struments.
verted into a bill, it operates as a prima facie authorit}^ to fill
it up as a complete bill for any amount the stamp will cover,
using the signature for that of the cbawer, or the acceptor, or
an indorser ; and, in like manner, when a bill is wanting in
any material particular, the person in possession of it has a
prima facie authority to fill iip the omission in any way he
thinks fit.
(2.) In order that any such instrument when completed may
be enforceable against any person who became a party thereto
prior to its completion, it must be filled up within a reasonable
time, and strictly in accordance with the authority given.
Reasonable time for this purpose is a cj^uestion of fact.
Provided that if any such instrument after completion is
negotiated to a holder in due course it shall be valid and
effectual for all purposes in his hands, and he may enforce it
as if it had been tilled up within a reasonable time and strictly
in accordance with the authority given (g).
21. (1.) Every contract on a bill, whether it be the di-awer's. Delivery,
the acceptor's, or an indorser's, is incomplete and revocable,
until delivery of the instrument in order to give effect
thereto.
Provided that where an acceptance is written on a bill, and
the drawee gives notice to or according to the directions of the
person entitled to the bill that he has accepted it, the accept-
ance then becomes complete and irrevocable.
(2.) As between immediate parties, and as regards a remote
party other than a holder in due course, the delivery —
(a.) in order to be effectual must be made either by or
under the authority of the party drawing, accepting, or
indorsing, as the case may be :
(b.) may be shown to have been conditional or for a special
purpose only, and not for the pui-pose of transferring the
property in the bill (A).
(/) See Grant, p. 102.
{(/) For definition of " holder in due course," see sect. 29.
(A) As to deposit of bills with banker for special purposes, p. 252, 2.jG.
{I) See sects. 54 (2), 55, GO, 80 and 82.
(/«) By sect. 73, this section applies to cheques. As regards the
banker's obligation to know his customer's signature at common law,
sec Grant, p. 11 ; and for cases in which the customer has been dis-
allowed U) set up a forgery, sec Grant, p. 1 7. As to forged indorccmcnts
on cheques, see sects. CO and 82.
45 & 46 Vict. c. 61. 781
agent has "but a limited authority to sign, and the principal is
onl}' bound by such signature if the agent in so signing was
acting within the actual limits of his authority (m).
26. (1.) Where a person signs a bill as drawer, indorser, or Person sigTi-
acceptor, and adds words to his signature, indicating that ho ing as agent
signs for or on behalf of a principal, or in a representative °'" ^'^ repre-
character, he is not personally liable thereon ; but the mere ^^^*^*'.^^'®
addition to his signatui'e of words describing him as an agent,
or as filling a representative character, does not exempt him
from personal liability.
(2.) In determining whether a signature on a biU is that of
the principal or that of the agent by whose hand it is written,
the construction most favourable to the validity of the instru-
ment shall be adopted (o).
T/ic Consideration for a Bill.
27. (1.) Yaluable consideration for a bill may bo con- -Value and
stituted by — holder for
(a.) Any consideration sufficient to support a simple con- "*''^^^^-
tract ;
(b.) An antecedent debt or liability. Such a debt or liabi-
lity is deemed valuable consideration whether the bill is
payable on demand or at a future time.
(2.) Where value has at any time been given for a bill the
holder is deemed to be a holder for value as regards the ac-
ceiitor and all parties to the bill who became parties prior to
such time.
(3.) Where the holder of a bill has a lien on it, arising
either from contract or by implication of law, he is deemed to
be a holder for value to the extent of the sum for which he
has a lien (/j).
28. (1.) An accommodation party to a bill is a person who Accommoda-
has signed a bill as drawer, acceptor, or indorser, without re- tio^ ^il^ ^^
ceiving value therefor, and for the purpose of lending his P^'^*^'
name to some other person.
(2.) An accommodation party is liable on the bill to a holder
for value ; and it is immaterial whether, when such holder
took the bill, he knew such party to be an accommodation
party or not {q).
(h) See Grant, pp. 300, 301.
(o) As to the liability of an agent signing without authority, see Grant,
p. 301. The Companies Act is not affected by this act, see sect. 97 ; and
consequently the in-ovisions of the -ITth section of the former statute, re-
lating to the signing of bills by agents, still remain in force.
(j») As to banker's lien, see Grant, p. 244.
((/) As to notice of dishonour being dispensed with in case of accom-
modation bill, see sect. 50 (2) (c) and (d), and Grant, p. 530.
782
SUPPLEMENT.
Holdei" in
due course.
Presumptiou
of value and
arood faith.
29. (1.) A holder in due course is a holder who has taken
a bill, complete and regular on the face of it, under the fol-
lowing conditions ; namely —
(a.) That he became the holder of it .before it was overdue,
and without notice that it had been previously dis-
honoured, if such was the fact :
(b.) That he took the bill in good faith and for value, and
that at the time the bill was negotiated to him he had no
notice of any defect in the title of the person who nego-
tiated it.
(2.) In particular the title of a person who negotiates a bill
is defective within the meaning of this act when he obtained
the bill, or the acceptance thereof, by fraud, duress, or force
and fear, or other unlawf id means, or for an illegal considera-
tion, or when he negotiates it in breach of faith, or iinder
such circumstances as amount to a fraud.
(3.) A holder (whether for value or not), who derives his
title to a bill through a holder in due course, and who is not
himself a party to any fraud or illegality affecting it, has all
the rights of that holder in due course as regards the acceptor
and all parties to the bill prior to that holder {>•).
30. ( 1 . ) Every party whose signature appears on a bill is
prima facie deemed to have become a party thereto for value.
(2.) Every holder of a bill is prima facie deemed to be a
holder in due course ; but if in an action on a biU it is ad-
mitted or jiroved that the acceptance, issue, or subsequent
negotiation of the bill is affected with fraud, duress, or force
and fear, or illegality, the burden of proof is sliifted, imless
and until the holder proves that, subsequent to the alleged
fraud or illegality, value has in good faith been given for
the bill.
Negotiation
of bUl.
Kcgotiatioyi of Bills.
31. (1.) A bill is negotiated when it is transferred from one
person to another in such a manner as to constitute the trans-
feree the holder of the bill (s).
(2.) A bill payable to bearer is negotiated by delivery (/).
(^.) A bill payable to order is negotiated by the indorse-
ment of the holder completed by delivery {u).
(4.) A\Tiere the holder of a bill payable to his order trans-
fers it for value without indorsing it, the transfer gives the
(;•) The expression "holder iu duecoui'.so" is substituted for the com-
mon law expression, "bona fide holder and for value." As to the rights
of a " holder in due course," see sect. 3S.
(a) For definition of holder, see sect. 2.
{t) As to delivery, see sects. 2,21.
(«) See as to indorsement, sects. 32, 33, 31, 35.
45 & 46 Vict. c. 61. 783
transferee sucli title as tlie transferor liad in tlie Lill, and tlie
transferee in addition acquires the right to have the indorse-
ment of the transferor.
(5.) Where any person is under obligation to indorse a hill
in a representative capacity, he may indorse the bill in such
terms as to negative personal liability (x).
32. An indorsement in order to operate as a negotiation Requisites
must comply with the following conditions, namely — of a valid
(1,) It must be written on the bill itself and be signed by ii^iorseinent.
the indorser. The simple signature of the indorser on
the bill, without additional words, is sufficient.
An indorsement written on an allonge (y), or on a "coj)y"
of a bill issued or negotiated in a country where "copies"
are recognized, is deemed to be written on the bill itself.
(2.) It must be an indorsement of the entire bill. A partial
indorsement, that is to say, an indorsement which pur-
ports to transfer to the indorsee a part only of the amount
payable, or which purports to transfer the bill to two or
more indorsees severally, does not operate as a negotia-
tion of the bill.
(3.) Where a bill is payable to the order of two or more
payees or indorsees who are not partners all must indorse,
unless the one indorsing has authority to indorse for the
others.
(4.) Where, in a bill payable to order, the payee or in-
dorsee is wrongly designated, or his name is misspelt, he
may indorse the bill as therein described, adding, if he
think fit, his proper signature.
(5.) AYhere there are two or more indorsements on a bill,
each indorsement is deemed to have been made in the
order in which it appears on the bill, until the contrary
is proved.
(6.) An indorsement may be made in blank or special. It
may also contain terms making it restrictive (;:).
33. Where a bill purports to be indorsed conditionally the Conditional
condition may be disregarded by the payer, and paj-meut to indorsement,
the indorsee is valid whether the condition has been fulfilled
or not (rt).
34. (1.) An indorsement in blank specifies no indorsee, and Indorsement
a bill so indorsed becomes payable to bearer. in blank and
(2.) A special indorsement specifies the person to wliom, or ^T^tial in-
to whose order, the bill is to be payable. ' orsemen .
{x) See sects. 16, 25, 26, and Grant, p. 301.
(;/) j^ ' ' allonge " is a slip of paper annexed to the bill Avhere there is
no room left for further indorsements.
{z) See sect. 35.
(n) This is new. As regards the old law, sec aiife, p. 298.
784
SUPPLEMENT.
Restrictive
indorsement
(.3.) The provisions of tTiis act relating to a payee apply,
■with the necessary modifications, to an indorsee under a
special indorsement (c).
(4.) AVhen a bill has been indorsed in blank, any holder
may convert the blank indorsement into a special indorsement
by writing above the indorser's signature a direction to pay
the bill to or to the order of himself or some other person.
35. (1.) An indorsement is restrictive which prohibits the
further negotiation of the bill, or which expresses that it is a
mere authority to deal with the l)ill as thereby directed, and
not a transfer of the ownership thereof ; as, for example, if a
bill be indorsed " Vaj I), only," or "Pay D. for the account
of X.," or " Pay 1). or order for collection."
(2.) A restrictive indorsement gives the indorsee the right
to receive payment of the bill and to sue any party thereto
that his indorser could have sued, but gives him no power to
transfer his rights as indorsee, unless it expressly authorize
him to do so.
(3.) Where a restrictive indorsement authorizes further
transfer, all subsequent indorsees take the bill with the same
rights, and subject to the same liabilities as the first indorsee
under the restrictive indorsement (r/).
36. (1.) "Wliere a bill is negotiable in its origin, it continues
of overdue or ^q }jq negotiable until it has been (a) restrietively indorsed,
dishonoured ^j. ^-^^-^ discharged by payment or otherwise (e).
(2.) Where an overdue bill is negotiated, it can only be
negotiated subject to any defect of title affecting it at its
maturity, and thenceforward no person who takes it can
acquire or give a better title than that which the person from
whom he took it had (/).
(3.) A bill payable on demand is deemed to be overdue
■within the meaning and for the purposes of this section when
it appears on the face of it to have been in circulation for an
unreasonable length of time. What is an unreasonable length
of time for this purpose is a question of fact (y).
(4.) Except where an indorsement bears date after the
maturity of the bill, every negotiation is prima facie deemed
to have been effected before the bill was overdue.
(5.) Where a bill which is not overdue has been dishonoured,
any person who takes it with notice of the dishonour takes it
subject to any defect of title attaching thereto at the time of
Negotiation
(c) See sects. 7, 8.
{d) As regards restrictive indorsements at common la'w, sec ante, p. 299.
(c) As to discharge of bill, sec sects. ')9 ct seq.
{/) As to defective title, see sect. 29 (2).
(/■/) This provision, though it does not apply to notes (see sect. 86 (3) ),
applies to cheques (sec sect. 73). Sec as to the common law rule regard-
ing the latter instnunents, a)ile, pp. 57, 58,
4o & 46 Vict. c. 61. 785
dishonour, but iiotliiug in this sub-section shall affect the
rights of a holder in due course (h).
37. "Where a bill is negotiated back to the drawer, or to a Negotiation
prior indorser or to the acceptor, such party may, subject to °^ ^^^ ^^
the provisions of this act(/), re-issue and further negotiate fiabie thereou
the bill, but he is not entitled to enforce pajinent of the bill
against any intervening party to -whom he was previously
liable.
38. The rights and powers of the holder of a bill are as Rights of the-
folloAVS : holder.
(1.) He may sue on the bill in his own name :
(2.) "Where he is a holder in due course, he holds the bill
free from any defect of title of prior parties, as well as
from more personal defences available to prior parties
among themselves, and may enforce payment against all
parties liable on the bill :
(3.) Where his title is defective (a) if he negotiates the
bill to a holder in due course, that holder obtains a good
and complete title to the bill, and (b) if he obtains pay-
ment of the bill, the person who pays him in due course
gets a valid discharge for the bill (A).
General Ditties of the Holder.
39. (1.) "W^here a bill is payable after sight, presentment When pre-
fer acceptance is necessary, in order to fix the maturity of the sentment for
instrument. ^ _ neceLw' ''
(2.) "WTiere a bill expressly stipulates that it shall be
presented for acceptance, or where a bill is drawn payable
elsewhei'e than at the residence or place of business of the
drawee, it must be presented for acceptance before it can be
presented for payment.
(3.) In no other case is presentment for acceptance neces-
sary in order to render liable any j)arty to the bill.
(4.) "Where the holder of a bill, drawn payable elsewhere
than at the place of business or residence of the drawee, has
not time, with the exercise of reasonable diligence, to present
the bill for acceptance before presenting it for payment on the
day that it falls due, the delay caused by presenting the bill
for acceptance before presenting it for payment is excused,
and does not discharge the drawer and indorsers [k).
40. (1.) Subject to the provisions of this act(/), when a Time for
bill payable after sight is negotiated, the holder must either presenting
^ '' & o ' IjJ^j payable
~~~ after sight.
(A) As to "holder in due course," and "defects of title," see sect. 29.
This section does not apply to a person deriving a title through a forgciy,
see sect. 24.
(?■) See sects. 59 (3) and 61.
{Jc) This provision is new.
(/) See pect. 41 (2).
r86
f5UPPLEMENT.
Rules as to
jDresentment
for accept-
ance, and
excuses for
non-present-
ment.
Non-accept-
ance.
Dishonour
Ly non-
acceptance
and its con-
sequences.
present it for acceptance or negotiate it within a reasonable
time.
(2.) If he do not do so, the drawer and all indorsers prior
to that holder are discharged.
(3.) In determining what is a reasonable time within the
meaning of this section, regard shall be had to the nature of
the biU, the usage of trade with respect to similar biUs, and
the facts of the particular case.
41. (1.) A bill is duly presented for acceptance which is
presented in accordance with the following rules :
(a.) The presentment must be made by or on behalf of the
holder to the drawee or to some person aixthorized to
accept or refuse acceptance on his behalf at a reason-
able hour on a business day and before the bill is
overdue :
(b.) Where a bill is addressed to two or more di-awees, who
are not partners, presentment must be made to them all,
unless one has authority to accept for all, then present-
ment may be made to him only :
(c.) Where the di-awee is dead, presentment may be made
to his personal representative :
(d.) Where the drawee is bankrupt, presentment may be
made to him or to his trustee :
(e.) Wliere authorized by agreement or usage, a present-
ment through the post office is sufficient.
(2.) Presentment in accordance with these rules is excused,
and a bill may be treated as dishonoured by non-acceptance —
(a.) Where the drawee is dead or bankrupt, or is a fictitious
person or a person not having capacity to contract by
biU :
(b.) Where, after the exercise of reasonable diligence, such
presentment cannot be effected :
(c.) Where although the presentment has been irregular,
acceptance has been refused on some other ground.
(3.) The fact that the holder has reason to believe that the
bill, on presentment, will bo dishonoured does not excuse
presentment.
42. (1.) AVhen a bill is duly presented for acceptance and
is not accepted within the customary time («), the person
presenting it must treat it as dishonoured by non-acceptance.
If he do not, the holder shall lose his right of recourse against
the drawer and indorsers.
43. (1.) A bill is dishonoured by non-acceptance —
(a.) AVhen it is duly presented for acceptance, and such an
acceptance as is prescribed by this act is refused or cannot
be obtained ; or
(«) ITsually 21 houvH. Sec Byles on Bills, p. 18.'), 13th vd.
45 & 46 YicT. c. 01. 787
(b.) When presentment for acceptance is excused and tho
bill is not accepted.
(2.) Subject to the provisions of this act (o) when a bill is
dishonoured by non-acceptance, an immediate right of recourse
against the di-awer and iudorsers accrues to the holder, and no
presentment for payment is necessar}-.
44. (1.) The holder of a biU may refuse to take a qualified Duties as to
acceptance, and if he does not obtain an unqualified acceptance q.uanned ac-
niay treat the bill as dishonoured by non-acceptance. ^^^ ances.
(2.) Where a qualified acceptance is taken, and the drawer
or an indor&er has not expressly or impliedly authorized the
holder to take a qualified acceptance, or does not subsequently
assent thereto, such drawer or indorser is discharged from his
liability on the bill.
The provisions of this sub-section do not apply to a partial
acceptance, whereof due notice has been given. Where a
foreign bill has been accepted as to part, it must be protested
as to the balance.
(3.) When the drawer or indorser of a bill receives notice
of a qualified acceptance, and does not within a reasonable
time express his dissent to the holder he shall be deemed to
have assented thereto (/»).
45. Subject to the provisions of this act a bill must be duly Rules as to
presented for payment (y). If it be not so presented the prescutment
drawer and iudorsers shall be discharged. °^ pajTnen .
A bill is duly presented for payment which is presented in
accordance with the following rules : —
(1.) Where the bill is not payable on demand, presentment
must be made on the day it falls due (?•).
(2.) "S^Tiere the bill is payable on demand, then, subject to
the provisions of this act, presentment must be made
within a reasonable time after its issiie in order to render
the drawer liable, and within a reasonable time after its
indorsement, in order to render the indorser liable (s).
In determining what is a reasonable time, regard shall be
had to tho nature of the bill, the usage of trade with
regard to similar biUs, and the facts of the jiarticular
case {().
(3.) Presentment must be made by the holder or by some
person authorized to receive payment on his behalf at a
reasonable hour on a business day, at the proper jDlace as
hereinafter defined, either to the person designated by
(o) See sect. 65.
Ip) See further as to qualified acceptances, (oite, p. 102, and sect. 19.
(q) See next section.
(»■) See sect. 14.
(«) As to cheques, see sect. 74.
{i) See as to cheques, p. 49.
788
SUPPLEMENT.
Excuses for
delay or non-
presentment
for paymeut.
the bill as payer, or to some person authorized to pay or
refuse payment on his behalf if with the exercise of
reasonable diligence such person can there be found.
(4.) A bill is presented at the proper place : —
(a.) Where a place of payment is specified in the bill and
the bill is there presented,
(b.) "Where no place of payment is specified, but the
address of the drawee or acceptor is given in the bill,
and the bill is there presented,
(e.) AVhere no place of pa^-ment is specified and no
address given, and the bill is presented at the drawee's
or acceptor's place of business if known, and if not, at
his ordinary residence if known,
(d.) In any other ease if presented to the drawee or
acceptor wherever he can be found, or if presented at
his last known place of business or residence.
(5.) "Where a bill is presented at the proper place, and
after the exercise of reasonable diligence no person
authorized to pay or refuse paj'ment can bo found there,
no further presentment to the drawee or acceptor is
required.
(G.) Where a bill is drawn upon, or accejjted by two or
more persons who are not partners, and no place of pay-
ment is specified, presentment must be made to them all.
(7.) Where the drawee or acceptor of a bill is dead, and no
place of payment is specified, presentment must he made
to a personal representative, if such there be, and with
the exercise of reasonable diligence he can be found (»).
(8.) AVhere authorized by agreement or usage a present-
ment through the post ofiice is sufficient.
46. (1.) Delay in making presentment for payment is
excused when the delay is caused by circumstances beyond
the control of the holder, and not imputable to his default,
misconduct, or negligence. When the cause of delay ceases
to operate presentment must be made with reasonable dili-
gence.
(2.) Presentment for payment is dispensed with, —
(a.) AMiere, after the exercise of reasonable diligence,
presentment, as required by this act, cannot be effected.
The fact that the holder has reason to believe that the bill
will, on presentment, be dishonoured, does not dispense
with the necessity for presentment,
(b.) Where the drawee is a fictitious person.
(c.) As regards the drawer where the drawee or acceptor is
(«) The case of the acceptor having become bankrupt is not dealt with.
It is presumed, however, the presentment would still have to be made to
him. As to i)rcsentment of notes, see an/', p. 31.j.
45 & 46 Vict. c. 61. 789
not bound, as between liimself and the drawer, to accept
or pay the bill, and the drawer has no reason to beliovo
that the bill would be paid if presented.
(d.) As regards an indorsor, where the bill was accepted or
made for the accommodation of that indorser, and he has
no reason to expect that the bill would be paid if pre-
sented.
(e.) By waiver of presentment, express or implied.
47. (1.) A bill is dishonoured by non-payment (a) when Dishonour by
it is duly presented for pa^nnent and payment is refused or °^J|^"^^^^'"
cannot be obtained, or (b) when presentment is excused and
the bill is overdue and unpaid.
(2.) Subject to the provisions of this act (x), when a bill is
dishonoured by non-payment, an immediate right of recourse
against the drawer and indorsers accrues to the holder.
48. Subject to the provisions of this act (y), when a bill has Notice of
been dishonoured by non-acceptance or by non-payment, '^^'^^^g""^ ^j
notice of dishonour must be given to the drawer and each ^Q^.^otl^e^
indorser, and any drawer or indorser to whom such notice is
not given is discharged ; Provided that —
(1.) Where a bill is dishonoured by non-acceptance, and
notice of dishonour is not given, the rights of a holder in
due course subsequent to the omission, shall not be prejudiced
by the omission.
(2.) Where a bill is dishonoured by non-acceptance and
due notice of dishonour is given, it shall not be necessary to
give notice of a subsequent dishonour by non-payment unless
the bill shall in the meantime have been accepted.
49. Notice of dishonour in order to be valid and effectual Tailes as to
must be given in accordance with the following rules : — honour
(1.) The notice must be given by or on behalf of the
holder, or by or on behalf of an indorser who, at the
time of giving it, is liimself liable on the bill.
(2.) Notice of dishonour may be given by an agent either
in his own name, or in the name of any party entitled to
give notice whether that party be his principal or not.
(3.) AVhere the notice is given by or on behalf of the
holder, it enures for the benefit of all subsequent holders
and all jn-ior indorsers who have a right of recourse
against the party to whom it is given.
(4.) Where notice is given by or on behalf of an indorser
entitled to give notice as hereinbefore provided, it enures
for the benefit of the holder and all indorsers subsequent
to the party to whom notice is given.
(5.) The notice may be given in writing or by personal
communication, a"nd may be given in any terms which
(x) See sects. Co— C8. (jj) See sect. 50.
790 SUPPLEMENT.
sufficientl}^ identify tlio bill, and intimate that tlie bill has
been dishonoured by non-accej^tanee or non-payment.
(6.) The return of a dishonoured bill to the drawer or an
indorser is, in point of form, deemed a sufficient notice of
dishonour.
(7.) A written notice need not be signed, and an insufficient
written notice may be supplemented and validated by
verbal communication. A misdescription of the bill shall
not vitiate the notice unless the i^arty to whom the notice
is given is in fact misled thereby.
(8.) Where notice of dishonour is required to be given to
any person, it may be given either to the i:)arty himself,
or to his agent in that behalf (y).
(9.) Where the drawer or indorser is dead, and tlie party
giving notice knows it, the notice must be given to a
personal representative if such there bo, and with the
exercise of reasonable diligence he can be found.
(10.) Where the drawer or indorser 'is bankrupt, notice
may be given either to the party himself or to the
trustee.
(11.) Where there are two or more drawers or indorsers
who are not partners, notice must be given to each of
them, unless one of them has authority to receive such
notice for the others.
(12.) The notice may be given as soon as the biU is dis-
honoured and must be given within a reasonable time
thereafter.
In the absence of special circumstances notice is not deemed
to have been given within a reasonable time, unless, —
(a.) where the person giving and the person to receive
notice reside in the same place, the notice is given
or sent off in time to reacli the latter on the clay
after the dishonour of the bill.
(b.) where the person giving and the person to receive
notice reside in different places, the notice is sent off
on the day after the dishonour of the bill, if there
be a post at a convenient hour on that day, and if
there be no such post on that day then by the next
post thereafter (z).
(13.) Where a bill when dishonoured is in the hands of an
agent, he may either himself give notice to the parties
liable on the bill, or he may give notice to his principal.
If he give notice to his principal, he must do so within
the same time as if he were the holder, and the principal
((/) A ' ' referee in case ' ' of need does not appear to be an agent for an
indorser for this purpose. See In re Leeds Bankhuj Co., Ex pari e Trail ffe,
L. R., 1 Eq. 1.
(:) See as to clulace of business or
residence of some person other than the draAvee, has been
dishonoured by non-acceptance, it must be protested for
non-payment at the place Avhere it is expressed to be pay-
able, and no further presentment for payment to, or
demand on, the drawee is necessary.
(7.) A protest must contain a copy of the bill, and must be
signed by the notary making it, and must specify —
(a.) The person at whose request the bill is protested :
(b.) The place and date of protest, the cause or reason
for protesting the bill, the demand made, and the answer
given, if any, or the fact that the drawee or acceptor could
not be found.
(8.) AVhere a bill is lost or destroyed, or is wrongly detained
from the person entitled to hold it, protest may be made on a
copy or written particulars thereof {e).
(9.) Protest is dispensed with by any circumstance which
would dispense with notice of dishonour (/). Delay in noting
(t) See further as to lo.st bills, sects. 69, 70.
(/) Soft. r.o.
45 & 46 Vict. c. 61. 793
or protesting is oxc-used wlieu tlie delay is caused Ly circuiu-
stanees beyond the control of the holder, and not imputable to
his default, misconduct, or negligence. AVhen the cause of
delay ceases to operate the bill must be noted or protested
"svith reasonable diligence.
52. (1.) "When a biU is accepted generally presentment for Duties of
payment is not necessary in order to render the acceptor bolder as
liflblp legaras
(2.) When by the terms of a qualified acceptance (^) pre- acceptor,
sentment for payment is required, the acceptor, in the absence
of an express stipulation to that effect, is not discharged by
the omission to present the bill for payment on the day that it
matures.
(3.) In order to render the acceptor of a bill liable it is not
necessary to protest it, or that notice of dishonour should bo
given to him.
(4.) Where the holder of a bill presents it for payment, he
shall exhibit the biU to the person from whom he demands
payment, and when a bill is j)aid the holder shall forthwith
deliver it up to the party paying it.
Liabilities of Parties.
53. (1.) A bill, of itself, does not operate as au assign- Funds in
ment of funds in the hands of the drawee available for the J{J°^gg°^
pajTiient thereof, and the drawee of a bill who does not accept *^ ^^
as required by this act is not liable on the instrument. This
sub-section shall not extend to Scotland.
(2.) In Scotland where the drawee of a bill has in his hands
funds available for the payment thereof, the bill_ operates as
an assignment of the sum for which it is di-awn in favour of
the holder, from the time when the bill is presented to the
drawee.
54. The acceptor of a bill, by accepting it — Liability of
(1.) Engages that he will pay it according to the tenor of his acceptor.
acceptance :
(2.) Is precluded from denying to a holder in due course :_
(a.) The existence of the drawer, the genuineness of his
signature, and his capacity and authority to draw the
biU;
(b.) In the case of a bill payable to drawer's order, the
then capacity of the drawer to indorse, but not the
genuineness or validity of his indorsement ;
(c.) In the case of a bill payable to the order of a third
person, the existence of the payee and his then capacity
to indorse, but not the genuineness or validity of his
indorsement.
(-7) See sects. 19, 44.
794
SUPPLEMENT.
Liability of
drawer or
indorscr.
Stranger
signing bill
liable as in-
dorscr.
Measure of
damages
against par-
ties to dis-
lionoured bill.
55. (1.) The drawer of a bill by drawing it —
(a.) Engages that on due presentment it shall be accepted
and paid according to its tenor, and that if it be dis-
honoured he will compensate the holder or any indorser
who is compelled to pay it, provided that the requisite
proceedings on dishonour be duly taken ;
(b.) Is precluded from denying to a holder in due course the
existence of the payee and his then capacity to indorse.
(2.) The indorser of a bill by indorsing it—
(a.) Engages that on due presentment it shall be accepted
and paid according to its tenor, and that if it be dis-
honoured he will compensate the holder or a subseqiient
indorser who is compelled to pay it, provided that the
requisite proceedings on dishonour be duly taken ;
(b.) Is precluded irom denying to a holder in due course
the genuineness and regularity in all respects of the
di-awer's signature and all previous indorsements;
(c.) Is precluded from denying to his immediate or subse-
quent indorsee that the bill was at the time of his
indorsement a valid and subsisting bill, and that he had
then a good title thereto.
66. Where a person signs a bill otherwise than as drawer
or acceptor, he thereby incurs the liabilities of an indorser to
a holder iu due course.
67. AVhere a bill is dishonoured, the measure of damages,
whicli shall be deemed to be liquidated damages, shall be as
follows :
(1.) The holder may recover from any party liable on the
bill, and the drawer who has been compelled to pay the
bill may recover from the acceptor, and an indorser who
has been, compelled to pay the bill may recover from the
acceptor or from the drawer, or from a prior indorser —
(a.) The amount of the bill:
(b.) Interest thereon from the time of presentment for
payment if the bill is payable on demand, and from
the maturity of the bill in any other case :
(c.) The expenses of noting, or, when protest is neces-
sary, and the protest has been extended, the expenses
of protest.
(2.) In tho case of a bill which has been dishonoured
abroad, in lieu of the above damages, the holder may
recover from the drawer or an indorser, and tlie draAver
or an indorser who has been compelled to pay the bill
may recover from any party liable to him, the amount of
the re-exchange (A) with interest thereon until tlie time of
payment.
(/() E,c-exchange is the difference iu the value of a bill occasioned by
its being dishonoured in a foreign countiy iu which it was payable. The
45 & 46 Vict. c. 61. 795
(3.) Where by this act interest may be recovered as
damages, siicli interest may, if justice reqiiire it, be
witlilield wholly or in j)nvt, and where a bill is expressed
to be payable with interest at a given rate, interest as
damages may or may not be given at the same rate as
interest proper.
58. (1.) Where the holder of a bill payable to bearer Transferor by-
negotiates it by delivery without indorsing it, he is called a delivery and
<( + „ 4? -u 1 T )) o 7 transferee.
" transieror by dellvcr3^
(2.) A transferor by delivery is not liable on the instru-
ment.
(3.) A transferor by delivery who negotiates a bill thereby
warrants to his immediate transferee being a holder for value
that the biU is what it purports to be, that he has a right to
transfer it, and that at the time of transfer he is not aware of
any fact which renders it valueless (?').
Discharge of Bill.
59. (1.) A bill is discharged by pajonent in due course by Payment in
or on behalf of the drawee or acceptor. *^l">^i° course.
" Payment in due course " means paj^ment made at or after
the maturity of the bill to the holder thereof in good faith
and without notice that his title to the bill is defective (A-).
(2.) Subject to the provisions hereinafter contained, when a
bill is paid by the drawer or an indorser it is not discharged;
but
(a.) where a bill payable to, or to the order of, a third
party is paid by the drawer, the drawer may enforce
payment thereof against the acceptor, but may not re-
issue the bill.
(b.) where a bill is paid by an indorser, or where a bill
payable to drawer's order is paid by the drawer, the
party pajdng it is remitted to his former rights as regards
the acceptor or antecedent parties, and he may, if he
thinks fit, strike out his own and subsequent indorse-
ments, and again negotiate the bill.
(3.) Where an accommodation bill is paid in due course by
the party accommodated the bill is discharged.
60. AVhen a bill payable to order on demand is cbawn on a Banker pay-
banker, and the banker on whom it is drawn pays the bill in ing demand
draft whereon
existence and amount of it depend on the rate of exchange between the
two countries. Byles on Bills, p. 418, 13th edit.
(/) For definition of the terms "delivery" and "bearer," and for
"holder" and "value," sec sect. 2; and see further as to the trans-
feror's liability, Grant, p. 343.
(/l) Payment to a person claiming through a forged indorsement docs
not discharge the payer (see sect. 24), except in the case mentioned in the
next section.
796
SUPPLEMENT.
indorsement
is forged.
Acceptor the
holder at
matvirity.
Express
waiver.
Cancellation.
Alteration of
bill.
good faith and iu tlie ordinary course of business, it is not
incumbent on tlie banker to show that the indorsement of the
payee or any subsequent indorsement "^as made by or under
the authority of the person whose indorsement it purports to
be, and the banker is deemed to have paid the bill in due
course, although such indorsement has been forged or made
without authority (tn).
61. 'WTien the acceptor of a bill is or becomes the holder of
it at or after its maturity, in his own right, the bill is dis-
charged.
62. (1.) When the holder of a bill at or after its maturity
absolutely and unconditionally renounces his rights against
the acceptor the bill is discharged.
The renunciation must be in tvriting («), unless the bill is
delivered up to the acceptor.
(2.) The liabilities of any party to a bill may in like
manner be renounced by the holder before, at, or after its
maturity ; but nothing in this section shall affect the rights of
a holder in due course without notice of the renunciation.
63. (1.) "Where a bill is intentionally cancelled by the
holder or his agent, and the cancellation is apparent thereon,
the bill is discharged.
(2.) In like manner any party liable on a bill may be dis-
charged by the intentional cancellation of his signature by
the holder or his agent. In such case any indorser who
would have had a right of recourse against the party whose
signature is cancelled, is also discharged.
(3.) A cancellation made imintentionally, or under a mis-
take, or without the authority of the holder, is inoperative ;
but where a bill or any signature thereon appears to have
been cancelled the burden of proof lies on the party who
alleges that the cancellation was made unintentionally, or
under a mistake, or without authority.
64. (1.) AVhere a bill or acceptance is materially altered
without the assent of all parties liable on the bill, the bill is
avoided except as against a party who has himself made,
authorized, or assented to the alteration, and subsequent
indorsers.
Provided that, —
Where a bill has been materially altered, biit the alteration
is not ajiparent, and the bill is in the liands of a holder
in duo course, such holder may avail himself of the bill
{ill) Tliis enactment, so far as it extend.s to cheques, is similar to 16 & 17
Vict. c. 59, s. 19 (see ante, sect. 22), which act, it must be noticed, is not
repealed. See further, sects. 73, 74.
{ii) This is new. Formerly not even a wi'iting was reqiiired. Con-
eideration for the renunciation need not exist.
45 & 46 Vict. c. 61. 797
as if it had not been altered., and may enforce payment
of it according to its original tenour (o).
(2.) In particular the following alterations are material,
namely, any alteration of the date, the sum payable, the time
of payment, the place of payment, and, where a bill has been
accepted generally, the addition of a place of payment with-
out the acceptor's assent (j;;).
Acceptance and Payment for Honour.
65. (1.) Where a bill of exchange has been ^j?-o^fs/e('/(y) for Acceptance
dishonour by non-acceptance, or protested for better security, f«r honour
and is not overdue, any person, not being a party already ^"P"^'^ protest.
liable thereon, may, with the consent of the holder, intervene
and accept the bill supra protest, for the honour of any party
liable thereon, or for the honour of the person for whose
accoxmt the bill is drawn.
(2.) A bill may be accepted for honour for part only of the
sum for which it is drawn.
(3.) An acceptance for honour supra protest in order to be
valid must —
(a.) be written on the bill, and indicate that it is an accept-
ance for honour :
(b.) be signed by the acceptor for honour (?•).
(4.) "Where an acceptance for honour does not expressly
state for whose honour it is made, it is deemed to be an
acceptance for the honour of the drawer.
(5.) Where a bill payable after sight is accepted for honour,
its maturity is calculated from the date of the noting for
non-acceptance, and not from the date of the acceptance for
honour.
66. (1.) The acceptor for honour of a bill by accepting it Liability of
engages that he will, on due presentment, pay the bill accord- acceptor for
ing to the tenor of his acceptance, if it is not jiaid by the ^°^^^-
drawee, provided it has been duly presented for payment, and
protested for non-payment, and that he receives notice of these
facts.
(2.) The acceptor for honour is liable to the holder and to
all parties to the bill subsequent to the party for whose
honour he has accepted.
(o) This important provision is new. An alteration may, however, be
such as to constitute the instrument a new bill, and as such render it
void under the Stamp Act for want of a stamp.
{p) As to alteration of cheque before this act, see Grant, p. 14 ; and
as regards bank notes, see Addendum.
[q) As to when noting is equivalent to protest, see sect. 93.
(;•) An acceptance for honour supra protest need not be made before
a notary public. Payment for honour supra protest, on the other hand,
must be. See sect. 68 (3), (4).
798
SUPPLEMENT.
Presentment
to acceptor
for honour.
Payment for
honour supra
protest.
67. (1.) Whei'G a dishonoured bill has been accepted for
honour supra protest, or contains a reference in case of need,
it must he 2^roteste(l{t) for non-payment before it is presented
for payment to the acceptor for honour, or referee in case of
need.
(2.) "Where the address of the acceptor for honour is in the
same place Trhere the bill is protested for non-payment, the
bill must be presented to him not later than the day following
its maturity; and where the address of the acceptor for honour
is in some place other than the place where it was protested
for non-pajanent, the bill must be forwarded not later than
the day following its maturity for presentment to him.
(3.) Delay in presentment or non-presentment is excused
by any circumstance which would excuse delay in present-
ment for payment or non-presentment for payment (ii).
(4.) When a bill of exchange is dishonoured by the acceptor
for honour, it must be protested for non-payment by him.
68. (1.) "Where a bill has been protested {t) for non-pay-
ment, any person may intervene and pay it supra protest for
the honour of any party liable thereon, or for the honour of
the person for whose account tlie bill is drawn.
(2.) AVhere two or more persons offer to pay a bill for the
honour of different parties, the person wdiose payment will
discharge most parties to the bill shall have the preference.
(8.) Payment for honour supra protest, in order to ojDerate
as such and not as a mere voluntary payment, must be attested
by a notarial act of honour, which may be appended to the
protest or form an extension of it.
(4.) The notarial act of honour must be founded on a
declaration made by the payer for honour, or his agent in
that behalf, declaring his intention to pay the bill for honour,
and for whose honour he pays.
(5.) Where a bill has been paid for honour, all parties
subsequent to the party for whose honour it is paid are dis-
chai'ged, but the payer for honour is subrogated for, and
succeeds to both the rights and duties of, the holder as
regards the party for whoso honour ho pays, and all parties
liable to that party.
(6.) The payer for honour on paying to the holder the
amount of the bill and the notarial expenses incidental to its
dishonour is entitled to receive both the bill itself and the
protest. If the holder do not on demand deliver them up ho
shall bo liable to tlio payer for honour in damages.
(7.) Where the holder of a bill refuses to receive payment
supra protest ho shall lose his right of recourse against any
party who would have been discharged by such payment.
{() As to notiug iu lieu of protest, sec scot. 93. {n) See sect. 46.
45 & 46 Vict. c. G1. 799
Lost Instrttments.
69. "Where a bill 1ms been lost before it is overdue, the Holder's
person who was the holder of it may aj)ply to the drawer to rig^^t to
give him another bill of the same tenor, giving security to f" ,?TJn
the drawer if required to indemnify him against all persons
whatever in case the bill alleged to have been lost shall bo
found again.
If the di-awer on request as aforesaid refuses to give such
duplicate bill, he may be compelled to do so {x).
70. In any action or proceeding upon a bill, the court or a Action on
j udge may order that the loss of the instrument shall not be ^°^* ^^^^•
set up, i)rovided an indemnity be given to the satisfaction of
the court or judge against the claims of any other person upon
the instrument in question (j-).
BUI in a Set.
71. (1.) Where a bill is drawn in a set, each part of the Rules as to
set being numbered, and containing a reference to the other ®'-'*'^-
parts, the whole of the parts constitute one bill (y).
(2.) Where the holder of a set indorses two or more parts
to ditferent persons, he is liable on every such part, and every
indorser subsequent to him is liable on the part he has him-
self indorsed as if the said parts were separate bills.
(3.) Where two or more parts of a set are negotiated to
different holders in due course (~), the holder whose title first
accrues is as between such holders deemed the true owner of
the bill ; but nothing in this sub-section shall affect the rights
of a person who in due course accepts or jiays the part first
presented to him.
(4.) The acceptance may be written on vmj part, and it
must be written on one part only.
If the drawee accepts more than one part, and such ac-
cepted parts get into the hands of different holders in due
coiu'se, he is liable on every such part as if it were a separate
bill.
(5.) "WQien the acceptor of a bill drawn in a set pays it
without requiring the part bearing his acceptance to be de-
livered uj) to him, and that part at maturity is outstanding
in the hands of a holder in due course, he is liable to the
holder thereof.
(6.) Subject to the preceding rules, where any one part of
a bill di-awn in a set is discharged by payment or otherwise,
the whole bill is discharged.
{x) As to the former law respecting lost cheques and bills, see Grant,
p. 89, and as to the loss of bank notes, Grant, p. 3.5o.
(y) Foreign bills are frequently drawn in parts. Bvles, p. 393, 13th cd.
iz) See sect. 29.
800
SUPPLEMENT.
Conflict of Laios.
Rules where 72. Where a bill drawn in one country is negotiated, ac-
laws conflict, cepted, or payable in another, the rights, duties, and liabili-
ties of the parties thereto are determined as follows :
(1.) The validity of a bill as regards requisites in form is
determined by the law of the place of issue {a), and the
validity as regards requisites in form of the supervening
contracts, such as acceptance {a), or indorsement {a), or
acceptance supra protest, is determined by the law of the
place where such contract was made.
Provided that — ■
(a.) AVhere a bill is issued out of the United Kingdom
it is not invalid by reason only that it is not stamped
in accordance with the law of the place of issue :
(b.) AVhere a bill, issued out of the United Kingdom,
conforms, as regards requisites in form, to the law
of the United Kingdom, it may, for the purpose of
enforcing payment thereof, be treated as valid as
between all persons who negotiate, hold, or become
parties to it in the United Kingdom.
(2.) Subject to the provisions of this act, the interpretation
of the drawing, indorsement, acceptance, or acceptance
supra protest of a biU, is determined by the law of the
place where such contract is made.
Provided that where an inland bill is indorsed in a foreign
country the indorsement shall as regards the payer be
interpreted according to the law of the United Kingdom.
(3.) The duties of the holder with respect to presentment
for acceptance or payment and the necessity for or suf-
ficiency of a protest or notice of dishonour, or otherwise,
are determined by the law of tlie place where the act is
done or the bill is dishonoured.
(4.) Where a bill is drawn out of but payable in the United
Kingdom and the sum payable is not expressed in the
currency of the United Kingdom, the amount shall, in
the absence of some express stipulation, be calculated
according to the rate of exchange for sight drafts at the
place of payment on the day the biU is payable.
(5.) Where a bill is drawn in one country and is payable in
another, the due date thereof is determined according to
the law of the place where it is payable.
PAPT III. — Cheques ox a Banker.
Cheque dc- 73. A cheque is a bill of exchange drawn on a banker pay-
fined, able on demand.
Except as otherwise provided in this part, the provisions of
(«) For definition of these tcnns, see sect. 2.
45 & 46 Vict. c. 61. 801
this act applicable to a bill of exchange payable on demand
ajiply to a cheque {b).
74. Subject to the provisions of this act (c) — Presentment
(1.) Where a cheque is not presented for payment "u-ithiu of cheque for
a reasonable time of its issue, and the drawer or the P^y™^^*-
person on whose account it is drawn had the right at the
time of such presentment as between him and the banker
to have the cheque paid and suifers actual damage
through the dela}', he is discharged to the extent of
such damage, that is to say, to the extent to which such
drawer or person is a creditor of such banker to a larger
amount than he would have been had such cheque been
paid.
(2.) In detemiining what is a reasonable time regard shall
be had to the nature of the instrument, the usage of
trade and of bankers, and the facts of the particular
case.
(3.) The holder of such cheque as to which such drawer or
person is discharged shall be a creditor, in lieu of such
drawer or person, of such banker to the extent of such
discharge, and entitled to recover the amount from
him(f/).
75. The duty and authority of a banker to pay a chec^ue Revocation of
drawn on him by his customer are determined b}' — banker's
(1.) Countermand of paj-ment : authority.
(2.) Notice of the customer's death (e).
Crossed Cheques {/).
76. (1.) Where a cheque bears across its face an addition General and
of — special cross-
(a.) The words "and company" or any abbreviation thereof ings defined,
between two parallel transverse lines, either with or
without the words " not negotiable " ; or
{h) A cheque being thus made equivalent to a bill payable on demand,
not merely will those sections which especially deal with such bills (see
sects. 36 (3), 45 (2) and 60) apply to cheques, but, it is presumed, all
those sections of the act which deal with, and are applicable to, bills
g'enerally. For definition of a "bill payable on demand," see sect. 10.
The term " banker" is defined by sect. 2.
{c) See excuses for Non-preseutment, stated in sect. 46.
{d) This section is new and alters the common law.
[e) As to the effect of death at common law, see Grant, pp. 85, 88.
Notice of an act of bankruptcy by the customer also determines the
banker's authority. See sect. 97, by which the bankruptcy laws are
preserved.
(/) The Crossed Cheques Act of 1876 is repealed by the present act
(see second schedule), but its provisions are, with one or two additions,
substantially re-enacted by the following sections. For a full discussion
on the old law relating to crossed cheques, see Grant, p. 63. The pro-
\'isions of this act as to crossed cheques apply also to all dividend
warrants, see sect. 95.
802
SUPPLEMENT.
Crossing by
di'awer or
after issue.
Crossing a
material part
of cheque.
Duties of
banker as to
crossed
cheques.
(b.) Two parallel transverse lines simply, either with or
without the words "not negotiable " ;
that addition constitutes a crossing, and the cheque is crossed
generally.
(2.) AVhere a cheque bears across its face an addition of
the name of a banker, either with or without the words
"not negotiable," that addition constitutes a crossing, and
the cheque is crossed specially and to that banker.
77. (1.) A cheque may be crossed generally or specially by
the drawer.
(2.) A\Tiere a cheque is uncrossed, the holder (y) may cross
it generally or specially (A).
(3.) Where a cheque is crossed generally the holder may
cross it specially.
(4.) AVhere a cheque is crossed generally or specially, the
holder may add the words "not negotiable."
(5.) Where a cheque is crossed special!}^, the banker to
whom it is crossed may again cross it specially to another
banker for collection.
(6.) "WTiere an uncrossed cheque, or a cheque crossed gene-
rally, is sent to a banker for collection, he may cross it spe-
cially to himself (A).
78. A crossing authorized by this act is a material part of
the cheque ; it shall not be lawful for any person to obliterate
or, except as authorized by tliis act, to add to or alter the
crossing (?').
79. (1.) Where a cheque is crossed specially to more than
one banker except when crossed to an agent for collection
being a banker, the banker on whom it is drawn shall refuse
payment thereof.
(2.) Where the banker on whom a cheque is drawn which
is so crossed nevertheless pays the same, or pays a cheque
crossed generally otherwise than to a banker, or if crossed
specially otherwise than to the banker to whom it is crossed,
or his agent for collection being a banker, he is hable to the
true owner of the cheque for any loss he may sustain owing
to the cheque having been so paid.
Provided that where a cheque is presented for payment
which does not at the time of presentment appear to be
crossed, or to have had a crossing which has been obliterated,
or to have been added to or altered otherwise than as autho-
rized by this act, the banker pa^'ing the cheque in good faith
and without negligence shall not be responsible or incur any
liability, nor shall the payment be cjuestioned by reason of
(ff) The " holder" is defined by scot. 2.
(A) These clauses are new.
(i) See further as to " alterations," sect. G4.
15 & 4G Vict. c. G1. 803
the cheque having been crossed, or of the crossing having
been obliterated or having been added to or altered otherwise
than as authorized by this act, and of payment having been
made otherwise than to a banker or to the banker to whom
the cheque is or was crossed, or to his agent for collection
being a banker, as the case may be.
80. "Where the banker, on whom a crossed cheque is drawn, Protection to
in good faith and Avithout negligence pavs it, if crossed gene- banker and
raUy, to a banker, and if crossed specially, to the banker to ™^^ ^^^""^
whom it,is crossed, or his agent for collection being a banker, cjogged.
tlie banker paying the cheque, and, if the checxue has come
into the hands of the payee, the drawer, shall respectively be
entitled to the same rights and be placed in the same position
as if payment of the cheque had been made to the true owner
thereof.
81. Where a person takes a crossed cheque which bears on Effect of
it the words "not negotiable," he shall not have and shall crossing on
not be capable of giving a better title to the cheque than that ^° ^^'
which the person from whom he took it had.
82. ^Miere a banker in good faith and without negligence Protection to
receives payment for a customer of a cheque crossed generally collecting
or specially to himself, and the customer has no title, or a
defective title thereto, the banker shall not incur any liability
to the true owner of the cheque by reason only of having
received such paj-ment.
PAET IV.— Promissory Notes (k).
83. (1.) A promissory note is an unconditional promise in Promissoiy
writing made by one person to another signed by the maker, ^°*® defined,
engaging to pay, on demand or at a fixed or determinable
future time, a sum certain in money, to, or to the order of, a
specified person or to bearer.
(2.) An instrument in the form of a note payable to maker's
order is not a note within the meaning of this section unless
and until it is indorsed by the maker.
(3.) A note is not invalid by reason only that it contains
also a pledge of collateral secimty, with authority to sell or
dispose thereof.
(4.) A note which is, or on the face of it purports to be,
both made and payable within the British Islands is an inland
note. Anj other note is a foreign note (l).
84. A promissory note is inchoate and incomplete until dc- Delivery
livery (?n) thereof to the payee or bearer. necessary.
85. (1.) A promissory note mav be made by two or more Joint and
^ " several notes.
{k) As regards bank note, see Grant, p. 340.
(/) As to inland and foreign bills, see sect. 4.
{m) See fin-thcr as to doliveiy, soct.i. 2, 21.
.804
SUPPLEMENT.
Note payable
on demand.
Presentment
of note for
payment.
Liability of
maker.
Application
of Part II. to
notes.
makers, and tliey may be liable thereon jointly, or jointly and
severally, according to its tenour.
(2.) Where a note runs "I promise to pay," and is signed
by two or more persons, it is deemed to be their joint and
several note.
86. (1.) Whore a note payable on demand {n) has been
indorsed, it must be presented for payment within a reason-
able time of the indorsement. If it be not so presented the
indorser is discharged.
(2). In determining what is a reasonable time, regard shall
be had to the nature of the instrument, the usage of trade,
and the facts of the particular ease.
(3.) Where a note payable on demand is negotiated, it is
not deemed to be overdue, for the purpose of affecting the
holder with defects of title of which he had no notice, by
reason that it appears that a reasonable time for presenting it
for payment has elapsed since its issue.
87. (1.) Where a promissory note is in the body of it
made payable at a particular place, it must be presented for
payment at that place in order to render the maker liable. In
any other case, presentment for payment is not necessary in
order to render the maker liable.
(2.) Presentment for payment is necessary in order to render
the indorser of a note liable.
(3.) AVhere a note is in the body of it made payable at a
particular place, presentment at that place is necessary in
order to render an indorser liable ; but when a place of pay-
ment is indicated by way of memorandum only, presentment
at that place is sufficient to render the indorser liable, but a
presentment to the maker elsewhere, if sufficient in other
respects, shall also suffice (o).
88. The maker of a promissory note by making it —
(1.) Engages that he will pay it according to its tenour ;
(2.) Is precluded from denying to a holder in due course
the existence of the payee and his then capacity to
indorse.
89. (I.) Subject to the provisions in this part and, excejit
as by this section provided, the provisions of this act relating
to bills of exchange apply, with the necessary modifications,
to promissory notes.
(2.) In applying those provisions the maker of a note
shall be deemed to correspond with the acceptor of a bill, and
the first indorser of a note shall be deemed to correspond with
the drawer of an accepted bill payable to drawer's order.
(3.) The following provisions as to bills do not apply to
notes ; namely, provisions relating to —
(a.) Presentment for acceptance ;
(w) Sec sect. 10.
{o) See Grant, p. lOG ; and sec sect. 52.
45 & 46 Vict. o. G1. 805
(b.) Acceptance ;
(c.) Acceptauce supra protest ;
(d.) Bills iu a set.
(4.) Wliere a foreign note is dishonoured, protest thereof
is unnecessary.
PAET y. — SuPrLEMEXTARY.
90. A thing is deemed to be done in good faith, within the Good faith,
meaning of this act, where it is in fact done honestly, whether
it is done negligently or not {p).
91. (1.) Where, by this act, any instrument or writing is Signature,
required to be signed by any person, it is not necessary that
he should sign it with his own hand, but it is sufficient if his
signature is written thereon by some other person by or under
his authority.
(2.) In the case of a corporation, where, by this act, any
instrument or writing is required to be signed, it is sufficient
if the instnmient or writing be sealed with the corporate seal.
But nothing in this section shall be construed as requiring
the bill or note of a corporation to be under seal(y).
92. Where, by this act, the time limited for doing any act Computation
or thing is less than three days, in reckoning time non-business of time,
days are excluded (r).
" Non-business days," for the purposes of this act, mean —
(a.) Sunda}', Good Friday, Christmas Day:
(b.) xi bank holiday under the Bank Holidays Act, 1871,
or acts amending it :
(c.) A day appointed by royal proclamation as a public
fast or thanksgiving day.
Any other day is a business day.
93. For the purposes of this act, where a bill or note is When noting
required to be protested within a specified time or before some equivalent to
further proceeding is taken, it is sufficient that the bill has protest.
been noted for protest before the expiration of the specified
time or the taking of the proceeding ; and the formal protest
may be extended at any time thereafter as of the date of the
noting (s).
94. Where a dishonoured bill or note is authorized or Protest when
required to be protested, and the services of a notary cannot notary not
be obtained at the place where the bill is dishonoured, any accessible,
householder or substantial resident of the place may, in the
presence of two witnesses, give a certificate, signed by them,
attesting the dishonour of the bill, and the certificate shall iu
all respects operate as if it were a formal protest of the bill.
{p) See on this subject, Grant, (r) See sects. 49 (12), 67 (2).
p. 355. (.v) See sects. 65 to 68.
{q) See (irant, pp. 32, 33.
c;. 3 G
806
SUPPLEMENT.
Dividend
warrants may
be crossed.
Repeal.
Saving's.
33 & 34 Yict.
c. 97.
25 & 26 Vict.
0. 89.
Saving of
summary
diligence ia
Scotland.
Construction
■with other
acts, &c.
Parol evi-
dence allowed
in certain
judicial pro-
The form given in Scliedulo 1 to tliis act may "be nsed Trith
necessary modifications, and if xised shall he sufficient.
95. The provisions of this act as to crossed cheques shall
apply to a "^arrant for payment of dividend {t).
96. The enactments mentioned in the second schedule to
this act are hereby repealed as from the commencement of
this act to the extent in that schedule mentioned.
Provided that such repeal shall not affect anything done or
suffered, or any right, title, or interest acquired or accrued
before the commencement of this act, or any legal proceed-
ing or remedy in respect of any such thing, right, title, or
interest.
97. (1) The rules in bankruptcy relating to bills of ex-
change, promissory notes, and cheques, shall continue to apply
thereto notwithstanding anything in this act contained.
(2) The rules of common law inclitding the law merchant,
save in so far as they are inconsistent with the express pro-
visions of this act, shall continue to apply to bills of exchange,
p»romissory notes, and cheques.
(3) Nothing in this act or in any repeal effected thereby
shall affect —
(a) The provisions of the Stamp Act, 1870 (u), or acts
amending it, or any law or enactment for the time being
in force relating to the revenue :
(b) The provisions of the Companies Act, 1862, or acts
amending it, or any act relating to joint stock banks or
companies {x) :
(c) The provisions of any act relating to or confirming the
privileges of the bank of England or the bank of Ire-
land respectively (y) :
(d) The validity of any usage relating to dividend war-
rants, or the indorsements thereof.
98. Nothing in this act, or in any repeal effected thereby,
shall extend or restrict, or in any way alter or affect, the law
and practice in Scotland in regard to summary diligence (;:).
99. AVhere any act or document refers to any enactment
repealed by this act, the act or document shall be construed,
and shall operate, as if it referred to the corresponding provi-
sions of this act.
100. In any judicial proceeding in Scotland, any fact relating
to a bill of exchange, bank cheque, or promissory note, which
is relevant to any question of liability thereon, may be proved
(f) The Crossed Cheques Act, 1876, merely applied to dividend war-
rants of the Banks of England and Ireland. See Grant, p. 68.
(u) See Grant, Appendix, p. 643.
(x) See Grant, p. 639.
(y) See Appenc&x, p. 569.
(z) See 12 Geo. 3, c. 72. ss. 37, 39—43 : 1 & 2 Vict. o. 114, ss. 1, 9.
45 & 4G Vict. c. 61.
807
by parole evidence : Provided tliat this enactment shall not in ceedings in
anj' vraj affect the existing law and i^ractiee whereby the Scotland,
party who is, according to the tenour of any bill of exchange,
bank cheque, or promissory note, debtor to the holder in the
amount thereof, may be required, as a condition of obtaining
a sist of diligence, or suspension of a charge, or threatened
charge, to make such consignation, or to find such caution, as
the court or judge before whom the cause is depending may
recpiire.
This section shall not apply to anj^ case where the bill of
exchange, bank cheque, or promissory note has undergone
the sesennial prescription.
SCHEDULES.
FiKST Schedule.
Fonn of protest which may be used when the services of a notary cannot Sect. 94.
be obtained.
Know all men that I, A. B. [householder], of , in the county
of , in the United Kingdom, at the request of C. D., there being
no notary piiblic available, did on the day of , 188 , at ,
demand payment [or acceptance] of the bill of exchange hereunder
written, from E. I'., to which demand he made answer [state answer,
if any] wherefore I now, in the presence of G. H. and /. E., do protest
the said bill of exchange.
(Signed) A. B.
j' T^' \ "Witnesses.
N.B. — The bill itself should be annexed, or a copy of the bill and all
that is wi'itten thereon should be underwritten.
Second Schedi'le.
Enactments eepealed.
■ Session and Cliapter.
9 Will. 3, c. 17 .
3 & 4 Anne, c. 8.
17 Geo. 3, c. 30
39 & 40 Geo. 3, c. 42
48 Geo. 3, c. 88 ...
Title of Act and Extent of Repeal.
An act for the better payment of inland bills of
exchange.
An act for giving like remedy upon promissorj*
notes as is now used upon bills of exchange,
and for the better payment of inland bUls of
exchange.
An act for further restraining the negotiation of
promissory notes and inland bills of exchange
imder a limited sum within that part of Great
Britain called England.
An act for the better observance of Good Friday in
certain cases therein mentioned.
An act to restrain the negotiation of promissory
notes and inland bills of exchange under a
limited sum in Eugland.
.3 G 2
808
SUPPLEMENT.
Second Schedule — fontlnucd.
Session and Chapter.
1 & 2 Geo. 4, c. 78
7 & 8 Geo. 4, c. 15
9 Geo. 4, c. 24..,
2 & 3 Will. 4, c. (18
C & 7 Will. 4, c. 58
8 & 9 Vict. c. 37 . .
in part.
19 & 20 Vict. c. 97
in part.
23 & 24 Vict. c. Ill
in part.
34 & 35 Vict. c. 74
39 & 40 Vict. c. 81
41 & 42 Vict. 0. 13
Title of Act and Extent of Repeal.
An act to regulate acceptances of bills of exchange.
An act for declaring the law in relation to bills of
exchange and promissory notes becoming pay-
able on Good Friday or Christmas Day.
An act to repeal certain acts, and to consolidate and
amend the laws relating to bills of exchange and
promissory notes in Ireland,
in part ; that is to say,
Sections two, four, seven, eight, nine,
ten, eleven.
An act for regulating the protesting for non-pay-
ment of bills of exchange drawn payable at a
place not being the place of the residence of the
drawee or drawees of the same.
An act for declaring the law as to the day on which
it is requisite to present for payment to acceptor,
or acceptors suprii protest for honour, or to the
referee or referees, in case of need, bills of ex-
change which have been dishonoured.
An act to regidate the issue of bank notes in Ire-
land, and to regulate the repayment of certain
sums advanced by the governor and company of
the bank of Ireland for the public service,
in part ; that is to say.
Section twenty-four.
The Mercantile Law Amendment Act, 1856,
in part ; that is to say.
Sections six and seven.
An act for granting to her majesty certain duties of
stamps, and to amend the laws relating to the
stamp duties,
in part ; that is to say,
Section nineteen.
An act to abolish days of grace in the -case of bills
of exchange and promissory notes payable at
sight or on presentation.
The Crossed Cheques Act, 1876.
The Bills of Exchange Act, 1878.
Enactment repealed as to Scotland.
19 & 20 Vict. c. GO
in part.
The Mercantile Law (Scotland) Amendment Act,
1856,
in part ; that is to say.
Sections ten, eleven, twelve, thirteen,
foiu'teen, fifteen, and sixteen.
( 809 )
BILLS OF SALE ACT (1878) AMENDMENT
ACT. 1882.
4.5 & -16 Vict. c. 4.'}.
A}i Act to amend the Bills of Sale Act, 1878 («).
[18th August, 1882.]
Whereas it is expedient to amend the Bills of Sale Act, 41 & 42 Vict.
1878: c. 31.
Be it enacted, &c., as follows :
1. This act may be cited for all purposes as the BiUs of Short title.
Sale Act (1878) Amendment Act, 1882 ; and this act and the
Bills of Sale Act, 1878, may be cited together as the Bills of
Sale Acts, 1878 and 1882.
2. This act shall come into operation on the 1st day of Commence-
November, 1882, which date is hereinafter referred to as the ment of act.
commencement of this act.
3. The Bills of Sale Act, 1878, is hereinafter referred to as Construction
"the principal act," and this act shall, so far as is consistent ^* ^°*-
•with the tenor thereof, be construed as one with the principal ^^ ^ ^^ ^^'^''•
act ; but unless the context otherwise requires shall not apply
to any bill of sale duly registered before the commencement
of this act so long as the registration thereof is not avoided by
non-renewal or otherwise.
The expression "bill of sale," and other expressions in this
act, have the same meaning as in the principal act, except as
to bills of sale or other documents mentioned in section four
of the principal act, which may be given otherwise than by
way of security for the payment of money, to which last-men-
tioned bills of sale and other documents this act shall not
apply (i).
4. Every bill of sale shall have annexed thereto or written Bill of sale to
thereon a schedule containing an inventory of the personal have schedule
chattels comprised in the bill of sale ; and" such bill of sale, "f^ached^^
save as hereinafter mentioned, shall have effect only in respect thereto,
of the personal chattels specifically described in the said
schedule ; and shall be void, except as against the grantor, in
respect of any personal chattels not so specifically described.
[a) Since the note on the draft bill of this act (see Grant, p. 565) was
printed the bill has become law. Certain amendments and alterations
having been made, however, it is thought advisable to insert the act in
its entirety.
[h] See, also, sect. 17.
810 SUPPLEMENT.
Bill of sale 5. Save as hereinafter mentioned, a bill of sale shall be void,
not to affect except as against the grantor, in respect of any personal
after -acquired chattels specifically described in the schedule thereto of which
property. ^-^^ grantor was not the true owner at the time of the execution
of the bill of sale.
Exception as 6. Nothing contained in the foregoing sections of this act
to certain shall render a bill of sale void in respect of any of the follow-
things. -^g things ; (that is to say),
(1.) Any growing crops separately assigned or charged
where such crops were actually growing at the time when
the bill of sale was executed.
(2.) Any fixtures separately assigned or charged, and any
plant, or trade machinery where such fixtures, plant, or
trade machinery are used in, attached to, or brought upon
any land, farm, factory, workshop, shop, house, ware-
house, or other place in substitution for any of the like
fixtures, plant, or trade machinery specifically described
in the schedule to such bill of sale.
Bill of sale 7. Personal chattels assigned under a bill of sale shall not
with power to \,q liable to be seized or taken possession of by the grantee
seize except ^^^, ^^-^^^ than the following causes :—
events to be (!•) If the gi'antor shall make default in payment of the sum
void. or sums of money thereby secured at the time therein
provided for pajonent, or in the performance of any cove-
nant or agreement contained in the bill of sale and
necessary for maintaining the security ;
(2.) If the grantor shall become a bankrupt, or suffer the
said goods or any of them to be distrained for rent, rates,
or taxes ;
(3.) If the grantor shall fraudulently either remove or
suffer the said goods, or any of them, to be removed from
the premises ;
(4.) If the grantor shall not, without reasonable excuse,
upon demand in writing by the grantee, produce to him
his last receipts for rent, rates, and taxes ;
(5.) If execution shall have been levied against the goods
of the grantor under any judgment at law :
Pro\ided that the grantor may within five days from tlio
seizure or taking possession of any chattels on account of any
of the above-mentioned causes, apply to the High Com-t, or
to a judge thereof in chambers, and such court or judge, if
satisfied that by payment of money or otherwise the said
cause of seizure no longer exists, may restrain the grantee
from removing or selling the said chattels, or may make such
other order as may seem just.
Bill of sale to 8. Every bill of sale shall be duly attested, and shall be
bo void unless registered under the principal act within seven clear days
recdstcrod" f^fter the execution thereof, or if it is executed in any place
45 & 46 Vict. c. 40. 811
out of England tliou within seven clear clays after the time
at which it would in the ordinary course of post arrive in
England if posted immediately after the execution thereof ;
and shall truly set forth the consideration for which it was
given; otherwise such bill of sale shall be void in respect of
the personal chattels comprised therein (c).
9. A bill of sale made or given by way of security for the Form of bill
payment of money by the grantor thereof shall be void unless of sale,
made in accordance with the form in the schedule to this act
annexed.
10. The execution of every bill of sale by the grantor shall Attestation.
be attested by one or more credible witness or witnesses, not
being a i^arty or parties thereto. So much of section ten of
the principal act as requires that the execution of every bill
of sale shall be attested by a solicitor of the Supreme Court,
and that the attestation shall state that before the execution
of the bill of sale the effect thereof has been explained to the
grantor by the attesting witness, is hereby repealed.
11. Where the affidavit (which under section ten of the Local regis-
principal act is required to accompany a bill of sale when tration of con-
presented for registration) describes the residence of the t^'^*^ °* °^^
person making or giving the same or of the person against
whom the process is issued to be in some place outside the
London bankruptcy district as defined by the Bankruptcy 32 & 33 Vict.
Act, 1869, or where the biU of sale describes the chattels c. 71, s. 60.
enumerated therein as being in some place outside the said
London bankruptcy district, the registrar under the j)rincipal
act shall forthwith and within three clear days after registra-
tion in the principal registry, and in accordance with the
prescribed directions, transmit an abstract in the prescribed
form of the contents of such bill of sale to the county court
registrar in whose district such places are situate, and if such
places are in the districts of different registrars to each such
registrar.
Every abstract so transmitted shall be filed, kept, and
indexed by the registrar of the county court in the prescribed
manner, and any person may search, inspect, make extracts
from, and obtain copies of the abstract so registered in the
like manner and uj)on the like terms as to jDayment or other-
wise as near as may be as in the case of bills of sale registered
by the registrar under the principal act.
12. Every bill of sale made or given in consideration of Bill of sale
any sum under thirty pounds shall be void. under 30?. to
13. All personal chattels seized or of which possession is ^^ ■^°i^-
taken after the commencement of this act, under or by virtue Chattels not
of any bill of sale (whether registered before or after the *° be removed
{r) See Grant, p. 565.
812
SUPPLEMENT,
Bill of sale
not to protect
chattels
against poor
and parochial
rates.
Repeal of
part of Bills
of Sale Act,
1878.
Inspection of
registered
bills of sale.
Debentures
to wliich act
not to apply.
Extent of act,
commencement of this act), shall remain on the premises
Tvhere they were so seized or so taken possession of, and shall
not be removed or sold until after the expiration of five clear
days from the day they were so seized or so taken posses-
sion of.
14. A hill of sale to which this act applies shall be no pro-
tection in respect of personal chattels included in such bill of
sale which but for such bill of sale would have been liable to
distress under a warrant for the recovery of taxes and poor
and other parochial rates.
15. The eighth and the twentieth sections of the principal
act, and also all other enactments contained in the principal
act which are inconsistent with this act are repealed, but this
repeal shall not affect the validity of anything done or suf-
fered under the principal act before the commencement of
this act.
16. tSo much of the sixteenth section of the principal act as
enacts that any person shall be entitled at all reasonable
times to search the register and every registered bill of sale
upon payment of one shilling for every copy of a bill of sale
inspected is hereby repealed, and from and after the com-
mencement of this act any person shall be entitled at all
reasonable times to search the register, on payment of a fee
of one shilling, or such other fee as may be prescribed, and
subject to such regulations as may be prescribed, and shall
be entitled at all reasonable times to inspect, examine, and
make extracts from any and every registered bill of sale
without being required to make a written application, or to
sjoecify any particulars in reference thereto, upon payment
of one shilling for each bill of sale inspected, and such pay-
ment shall be made by a judicatiire stamp: provided that the
said extracts shall be limited to the dates of execution,
registration, renewal of registration, and satisfaction, to the
names, addresses, and occupations of the parties, to the
amount of the consideration, and to any further prescribed
particulars.
17. Nothing in this Act shall apply to any debentures
issued by any mortgage, loan, or other incorjiorated company,
and secured iipon the capital stock or goods, chattels, and
effects of such company.
18. This Act shall not extend to Scotland or Ireland.
SCHEDULE.
Eor.M OF Bill of Sale.
This Indentuee made the
of the one part, and C. D. of
in consideration of the sum of £
duv of , between ^L. B. of
of the other part, witnesseth that
now paid to ^. B. by C. J}., the
45 i.
ANTE-DATING BILL, 777.
«' AT SIGHT," BILL PAYABLE AT. (Sec On Demand.)
equivalent to bill payable on demand, 776.
BANK HOLIDAY, 777, 805.
BANK OF ENGLAND OR IRELAND, privileges remain the
same, 866.
BANKER,
definition of the word, 77^5.
lien on customers' bills, 7X1.
revocation of authority of, SOI.
paying draft with forged indorsement, 795.
paying cheque when customer's signature is forged, 780.
paying cro.ssed cheques, 802.
protection to bankers, 803.
protection to, collecting, ib.
INDEX TO SUPPLEMENT. 817
BANKRUPT,
definition of, 773.
presentment for acceptance to, 78G.
for payment, 788.
notice of dishonour to, 790.
saving of bankruptcy laws, 806.
BEARER,
definition of, 773.
bill to, 782.
how negotiated, ib.
what bills are payable to, 775.
indorsement in blank, ib., 783.
fictitious payee, 775.
liability of transferor to bearer, 795.
BETTER SECURITY, 797.
BILL OF EXCHANGE,
defined, 773, 774, 800.
foreign bill, 77-1.
inland bill, ib.
form and interpretation of, 774.
what bills are negotiable, 775.
dating, 776.
time of payment, 777, 805.
acceptance of, 778. (6Ve Acceptance.)
deUvery of, 779. {See Delivery.)
pai-ties to, 780. [See Capacity.)
consideration for, 781. (<%«; Consideeation.)
accommodation bill, ib.
negotiation of, 782. {See Indoesement.)
overdue, 784, 801.
duties of holder, 785. {See Holdee.)
presentment, ib. {See Peesentment.)
notice of dishonour, 789. {See Notice.)
noting bill, 791, 805.
liabilities of pai'ties, 793. {See Acceptoe ; Indoeser ; Drawee ;
Transferor.)
discharge of, 795.
acceptance and payment for honour, 797. {See Acceptor.)
lost bills, 799.
bills in a set, ib.
cancellation of, 796.
conflict of laws relating to, 800.
biU payable on demand, 776.
cheque is a bill payable on demand, 800.
stamp laws relating to, saved, 806.
BILLS OF SALE ACT, 1882.. 809.
BLANK,
signatiu'es, 779.
no date, 776.
indorsement in, 783.
CANCELLATION OF BILL, 796.
CAPACITY OF PARTIES, 780.
signature essential to liability, ib.
forged or unauthorized signature, ib.
agent, ib,, 783.
S18 INDEX TO SUPPLEMENT.
CASE OF NEED, 778.
presentment to acceptor, 798.
CHEQUE,
definition of, 800.
sections applicable to, 801.
presentment for payment to charge drawer, ib.
effect of delay, ib.
right of holder as against banker, lb.
mode of presentment, 787.
to charge indorser, ib.
revocation of banker's authority to pay, 801.
crossed cheques, ib., 806.
duties of banker relating to, 802.
"not negotiable," 801, 802.
protection to banker, 803.
collecting banker, ib.
effect of, on holder, ib.
crossing, material part, 802.
forged indorsement on, 795.
when overdue, 784.
equities attaching, ib.
discrepancy between words and figures, 776.
forgery of drawer's signature, 780.
banker's lien on, 781.
payment, 795.
cancellation, 796.
COMPANY, 780, 806.
COMPUTATION,
of time of paj-ment of bills, 777.
for acceptance, 778.
of sum payable, 776.
non-business days excluded, 805.
CONDITIONAL,
bill, 774.
indorsement, 783.
acceptance, 778, 787.
delivery, 779.
CONFLICT OE LAWS, 800.
CONSIDERATION,
what is A'aluable consideration, 781.
antecedent debt, ib.
holder of bUl having lien over,
accommodation bill, ib.
illegal, when it affects holder, 782.
presumption as to, ib.
COPY OF FOREIGN BILL, 783.
CORPORATION,
capacity as regards bills, 780.
is included in "person," 774.
COUNTERMAND of payment of cheque, 801 .
CROSSED CHEQUES, 801. (.SV.. Cheques.)
INDEX TO SUPPLEMENT. 819
DAMAGES, measure of, against parties to a bill, 79 1.
DATE,
omission of, 776.
not an essential element, lb.
authority to fill in, ib., 119.
ante- and post-dating, 777.
bill "afterdate," 742.
presentment of biU " after date," 787.
computation of time of payment, 777, 797, 800.
alteration of, material, 797.
DAYS or GRACE, 777.
on what bills allowed, ib. »_
proviso respecting, ib.
DEATH,
of drawer of cheque revokes banker's authority, 801.
its effect as regards presentment, 786, 788.
and "notice of dishonour," 790.
DEBT, antecedent, is a valuable consideration for bill, 781.
DEFINITIONS of words used in act, 773.
DELIVERY,
contract incomplete till, 773, 779.
exception, 779.
what constitutes, ib.
may be conditional, 779.
effect of, conditional, 780.
presumption as to, ib.
bill to bearer passes by, 782.
transferor by, 795.
his liability, ib.
what he warrants, ib.
DEMAND, BILLS PAYABLE ON,
what bills are, 776.
cheque is, 800. {See Cheque.)
when overdue, 784.
if overdue subject to equities, ib.
presentment of, 787.
banker pajnng, where indorsement forged, 795.
not entitled to days of grace, 777.
DESTRUCTION OF BILL, 792.
DISCmVRGE OF BILL, 793.
payment in due course, ib.
what it means, ib.
when payment will not be a, ib.
acceptor becoming holder at maturity, 794.
express waiver, ib.
cancellation, ib.
alteration, ib.
DISHONOUR,
by non-acceptance, 786. {See Acceptance.)
by non-payment, 793.
820 INDEX TO SUPPLEMENT.
DISHONOUR— row t In iied.
by acceptor for honour, 797.
notice of, 793.
effect of non-notice, ib.
riiles as to, ib.
excuses for non-notice and delay, 783.
DIVIDEND WARRANT,
may be crossed, 806.
usage relating to, retained, ib.
DRAWEE. (&e AccEPTOE.)
addi'ess to, 77o.
may be to t\^:o or more, ib.
but not in the alternative, ib.
duties of holder towards, 793.
liability of, ib. {See Acceptoe.)
bill does not operate as an assignment of funds in hands of, ib.
payment by, 795.
time for drawee to elect to accept, 786.
bank. {See Cheque.)
DRAWER,
where same person as drawee, 775.
optional stipulations by, 778.
liability of, 794.
and engagements, ib.
measure of damages against, ib.
duties of holder towards, 785,
payment of bill by, 795.
his remedies, ib.
of cheque, 800. {See Ciieque.)
death of, revokes banker's authority, 801.
liability of, ib.
the effect of non-presentment as regards, ib.
DUE DATE, 777. {See Date.)
DURESS, 782.
EQUITIES on overdue bills, 784.
EXCHANGE (RATE OF), 800.
EXECUTORS,
presentment to, 786, 788.
notice of dishonour to, 793.
FAST DAY (PUBLIC), 777, 805.
FEAR, 782.
FICTITIOUS PARTY,
bill addressed to, 775.
drawee, 791.
payee, 775.
signing in assumed name, 780.
force, 782.
INDEX TO SUPrT.E^fENT. 821
rOREIGN BILL,
definition of, 774.
protesting, 742, 794.
conflict of laws, 800.
FOREIGN CrRRENGY, computation of amount pii.yable, 800.
FOREIGN LAWS, when given effect to, SCO,
FOREIGN NOTE, 803.
definition of, U).
protest not necessary, 80o.
FORGERY,
effect of, generally, 780.
banker pavina* demand draft -whereon is a forged indorsement,
795.
FRALT), 782.
FUNDS IN DRAWEE'S HANDS, bill does not operate as as.sign-
ment of, except in Scotland, 793. (.SV/- Scoxl.a.nd.)
GENERAL ACCEPTANCE, 778, 793. {See Acceptaxce.)
GOOD FRIDAY, 777, 805.
GRACE, DAYS OF, 777.
HOLDER,
definition of, 773.
for value, 781.
in due course, 782.
title of, ib.
of an accommodation bill, 781.
presumption of value and bnnu fide, 782.
rights of, 785.
general duties of, ib.
acceptor becoming, ib., 796.
HOLIDAY, bank or public, 777, 805.
HONOL'R. [See Acceptance for Hoxoue.)
acceptance or payment for, 797.
ILLEGALITY of consideration and its effect, 782.
INCOMPLETE BILL, 779.
INDORSEE,
included in "holder," 773.
provisions relating to payee, apply to, 784.
misdescription of, 783.
how he should sign, ih.
bill payable to two or more, Ih.
effect of restrictive indorsement upon, 784.
O. 3 H
822
INDEX TO supple:\[ent.
INDORSEMENT,
clefmition of, 773.
must be completed by delivery, ib., 779.
■with optional stipulation, 778, 779.
as agent, 780, 781, 783.
bill payable to order, negotiated by, 782.
rights of person taking such bill without, il).
requisites of a valid, 783.
effect of partial, ib.
to two or more, not partners, ib.
indorsee's name wrongly spelt, ib.
order of two or more indorsements, ib.
conditional indorsement, ib.
payer may disregard, ib.
in blank, ib.
special, ib.
blank, may be com-erted into special, 784.
restrictive, ib.
how it efPects indorsee, ib.
what it admits, 794.
of a bill in a set, 799.
forged, 795.
conflict of laws respecting, 800.
INDORSEE,
notice of dishonour to, 789.
general liability, 794.
what he is precluded from denying, ib.
stranger signing bill liable as, ib.
of bill in a set, 799.
damages against, 794.
INFANT, when, party to bill, 780.
INEORMAL INSTRUMENT, 778.
INLAND BILL, definilion of, 774.
INSTALMENT, sum in biU payable by, 776.
INSTRUMENT. {See Bill.)
what within act, 773.
inchoate, 779.
expressed to be on contingency not bill, 776.
INTEREST, 799.
sums payable by bill with, 77G.
included in damages, 794.
IRELAND, act applies to, 773.
ISSUE, definition of, 774.
JOINT AND SEVERAL, 803.
LAW MERCHANT,
how far retained, 806,
lieu on bill, 781.
INDEX. TO SUrrLEMENT. 823
LOST INSTRUMENT, 799.
holder's right to duplicate of, ib.
action on, ib.
MAKER OF NOTE, 803.
note payable to order of, ib.
presentment of note to, ib.
liability of, ib.
application of provisions to acceptor to, ib.
MATURITY,
how computed, 777.
of bill di-a-svn in one country and payable in another, 800.
of after sight bill accepted for honour, 797.
bill negotiated after, 784.
pajTiieut at, or after, 795.
MISDESCRIPTION, 777, 783.
MISSPELLING, 783.
MONTH, in bill, means calendar, 777.
NEED, referee in ca.se of, 778, 798.
NEGOTIATIONS. {See Lxdoesemext.)
meaning of, 775, 782.
of bill payable to bearer, ib.
to order, ib.
of overdue bill, 784.
of dishonoured bill, ib.
of bill to party already liable thereon, 785.
negotiability, 796.
when ceases, 784.
NON-BUSINESS DAYS, what they are, 805.
"NOT NEGOTIABLE,"
crossing cheque with words, 801.
effect of such a crossing, 803.
NOTARY PUBLIC,
protest where notary not accessible, 805, 807.
NOTICE OF DISHONOUR,
when it must be given, 789.
effect of non-notice, ib.
rules as to, ib.
how it must be given, ib.
where bill misdescribed, 790.
where drawer or indorser dead, ib.
or bankrupt, ib.
two or more drawers or indorsers, ib.
time when to be given, ib.
what is reasonable time, ib.
in cases of agency, ib.
excuses for non-notice and delay, 791.
not necessary as against acceptor, 793.
NOTING. {Sec Peotest.)
bill when dishonoured, 783.
when, is equivalent to protest, 805.
3h2
824 INDEX TO SUPPLEMENT.
OMISSION or DATE, 776.
OPTIONAL STIPULATION (by drawer or indorser), 778.
<' OKDEE," BILL PAYABLE TO, 774, 775. {See Indoesement.)
how negotiated, 782, 79-5.
OVERDUE BILL,
negotiation of, 784.
eqvxities attach to, ib.
bill payable on demand, ib.
cheques, ib.
PAEOLE EVIDENCE, allowed in certain proceedings in Scotland,
806.
PARTIAL ACCEPT.^^CE, 779.
PARTIAL INDORSEMENT,
what it is, 783.
does not negotiate bill, lb.
PARTICUL^VR FUND, order to pay out of, 774.
PARTNERSHIP,
included in "person," 774.
signature of, 780.
PAYEE,
must be described with reasonable certainty, 783.
bill payable to two or more payees, ib.
where fictitious person, lb.
when provisions as to, apply to indorser, 784.
indorsing, where wrongly described, 783.
PAYMENT,
" in due course " discharges bill, 795.
what is, "in due course," ib.
by drawer or indorser, ib.
of acconnnodation bill, ib.
of demand draft by banker whereon is a forged indorsement, ib.
of a forged bill in general, 780.
of crossed cheque, 802.
place of, 774.
PAYMENT FOR HONOUR, 798.
PERSON, definition of, 774.
PLACE,
of drawing, 774, 800.
of j)ayment, ib.
of presentment for acceptance, 786.
payment, 787.
POST-DATING BILL, 777.
POST OFFICE,
presentment through, 786, 788.
notice of dishonour through, 790.
PRESENTMENT,
for acceptance, 785.
when necessary, ib.
time for, of " bill after sight," ib.
rules as to, 786.
INDEX TO SUrrJ.EMENT. 825
PEESENTMENT— (•()«<(«««('.
fur acceptance — continued.
excuses for non-, 78G.
di-awee's time for accepting, ib.
through the post, ib.
for pajTnent, 787.
rules as to, ib.
excuses for delay or non-, 788.
not usually necessary to charge acceptor, 793.
to maker of note, 804.
to acceptor for honour, 798.
to referee in case of need, 778, 798.
PRINCIPAL AND AGENT,
liability of principal, 780, SOo.
person signing as agent, 781.
liability of, ib.
imauthorized signature, ib.
PROCURATION SIGNATURE, 781.
PROMISSORY NOTE,
definition of, 803.
requibites of, ib.
delivery necessary, ib.
inland and foreign, ib.
joint and several, ib.
payable on demand, 806.
presentment for payment, ib.
liability of maker, ib.
application of act to, ib.
PROTEST,
necessity of, as agaiuyt di-awer or indorser, 791.
as regards acceptor, 793.
of foreig-n bill, 792.
rules as to, ib.
•when noting equivalent to, 805.
■where no notary at hand, ib.
in proceedings for honour, 797, 798.
of copy of bill, -when lost or destroyed, 792.
in case of partial acceptance, 787.
QUALIFIED ACCEPTANCE, 778. {Sec Acceptance.)
■what is a, ib.
examples of, ib,
RATIPICATION, of forgery, 780.
RE-EXCHANGE, what it is, 794.
RE-ISSUE,
by acceptor, 785, 796.
by drawer or indorser, 785, 795.
REPEALS of former acts, 806, 2nd schedule.
RESTRICTIVE INDORSEMENT, 784.
SAVINGS, 806.
SCOTLAND,
act applies to, 773.
in, bill operates as an assignment of funds in hands of drawee, 793.
saving of summary diligence in, 806.
amendment as regards parole e\'idence in, ib.
82G INDEX TO SUPPLEMENT.
SET,
bills in, 799.
rules as to, ib.
SIGHT BILL. {See After Sight.)
is payable on demand, 776.
SIGNATUEE,
in blank, 779.
essential to liability, 780. ^
forged or unauthorized, ib.
procuration, ib.
■when a forged indorsement, 795.
SPECIAL CROSSING, 802.
SPECIAL INDOESEMENT, 783.
STRANGEE, liability of, backing bill, 794.
SUM PAYABLE, 776.
"sum certain," what it is, ib.
discrepancy between words and figui'es, ib.
omitted, 779.
alteration of, 797.
SUMMAEY DILIGENCE, 806.
SUNDAY, 777, 805.
THANKSGIVING DAY, 777, 805.
TIME OF PAYMENT. {Sec Payment.)
TRANSFER,
of bill by negotiation, 782.
of bill to order without indorsement, ib.
TRANSFEROR BY DELIVERY, 795.
VALUE, 781. {See Consideeation.)
defined, 774, 781.
antecedent debt, ib.
presumption, 782.
need not be stated in bill, 774.
holder for, 781.
WAIVER,
of bill or acceptance, 796.
must be in writing, ib.
of presentment for payment, 778, 789.
of notice of dishonour, 778, 791.
of protest, 778, 792.
C. F. EOWOETH, PEINTEE, BEEAM'S BUILDINQS, CHANCEEY LANE.
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