he United
Kingdom or in the colonies, in his trustee in bankruptcy. Having thus
denuded him of everything, it has been held to follow that the bankrupt's
discharge must also receive recognition in a colonial court.

_France_.--Bankruptcy in France is regulated by the Commercial Code of
1807, amended and supplemented by the law of 9th June 1838. By Article 437
of the code bankruptcy is defined as the state of a trader who is unable to
meet his commercial engagements. Simple insolvency of this kind is known in
France as _faillite_. Insolvency attended with circumstances of misconduct
or fraud is known as _banqueroute simple_ or _banqueroute frauduleuse_.
Only a trader can become bankrupt. The debt, too, for obtaining
adjudication must be a commercial debt, the laws regulating bankruptcy
being designed exclusively for the protection of commerce. To be made a
bankrupt a trader need not be insolvent: it is sufficient that he has
suspended payment. Commercial companies of all kinds are liable to be
declared bankrupt in the same manner as individual traders. A trader-debtor
can be adjudicated bankrupt upon his own petition, or upon the petition of
a creditor, or by the court itself _proprio motu_. A petitioning debtor
must within fifteen days file at the [v.03 p.0331] office of the Tribunal
of Commerce of the district, a declaration of suspension, with a true
account of his conduct and of the state of his affairs, showing his assets,
debts, profits and losses and personal expenses. On adjudication the
Tribunal of Commerce appoints a person, called a _syndic provisoire_, to
manage the bankrupt's estate, and a _juge commissaire_ is also named to
supervise the syndic. A bankruptcy terminates by an ordinary composition
(_concordat_), a sale of the debtor's assets (_union_), or a composition by
relinquishment of assets. It is a striking feature of the French system,
and highly creditable to French commercial integrity, that a discharge in
bankruptcy, even when accompanied by a _declaration d'excusabilite_, leaves
the unpaid balance a debt of honour. At the time of the French Revolution
the National Convention passed a resolution that any man who contracted a
debt should never be free from liability to pay it. The spirit of this
resolution still survives, for until a trader has paid every penny that he
owes he is not rehabilitated and remains under the stigma of various
disabilities: he has no political rights, he cannot hold any publ