pts on a similar footing to that of the English
act.

The Judicial Factors Act of 1889 contains a provision calculated to check
excessive costs of administration, by requiring that where the remuneration
of a trustee under a sequestration is to be fixed by the commissioners,
intimation of the rate of remuneration is to be given to the creditors and
to the accountant of court before being acted on, and the latter officer is
empowered, subject to appeal, to modify the same if he deems it expedient.

It may be pointed out that the Deeds of Arrangement Act 1887, which applies
to England and Ireland, does not apply to Scotland, and there is no
analogous provision requiring registration of private deeds of assignment
for the benefit of creditors as a condition of their validity in that
country.

Finally, it is to be noted that the office of accountant in bankruptcy,
which was established by the Bankruptcy Act of 1856, has under the Judicial
Factors Act 1889 been abolished, the duties being merged in those of the
office of accountant of the court of session.

_Irish Bankruptcy Legislation._

The Irish law of bankruptcy is regulated by the two leading Irish statutes
of 1857 and 1872, together with the Irish Debtors Act 1872, and corresponds
in its main features to some of the older English enactments, with
modifications adopted from the English act of 1869. It may be pointed out,
however, that the system of liquidation by arrangement and composition
without the approval or control of the court, which proved fatal to the
success of the latter, has not at any time been imported into the Irish
law. A special act was passed in 1888 for establishing local bankruptcy
courts in certain districts in Ireland, and an act was also passed in 1889,
applying the main provisions of the English Act of 1888, relating to
preferential payments in bankruptcy, to Ireland.

The Deeds of Arrangement Act 1887, which has been already discussed above
under the head of English bankruptcy legislation, also applies in its main
provisions to Ireland, and as supplemented by the Irish Deeds of
Arrangement Amendment Act 1890, places the law relating to this branch of
insolvency procedure upon a similar footing in both countries, so far as
regards the publicity of such deeds. The last-mentioned act also requires a
similar registration of all petitions for arrangement under the Bankruptcy
Act 1857.

(J. SM.*)

COMPARATIVE LAW

_British Empire_.--In mo