in 1800 was raised to the bench. As a judge he was even more successful than as an advocate. One most important lawsuit which came before him, when sitting as a judge of first instance, wan that in which the property of the 'Free Church' was claimed by members of that body who objected to its union with the. 'United Presbyterians' (1900). Low decided against this claim, and his judgment was adhered to by the inner house of the court of session, whose decision was, however, reversed on appeal to the House of Lords (1904). He resigned, owing to bad health, in the autumn of 1910, died at The Laws on 14 October of that year, and was buried at Whitsome, Berwickshire. Low, who married (1875) Annie, daughter of the Hon. Lord MacKenzie (Scottish judge), left one son. Mr. Jamea A. Low, C.A., Edinburgh, and two daughters. A portrait of him by Fiddes Watt is at The Laws.
[Scotsman and The Times, 15 Oct. 1910; Roll of the Faculty of Advocates; Records of the Juridical Society.]
LOW, Sir ROBERT CUNLIFFE (1838–1911), general, born at Kemback, Fifeshire, on 28 Jan. 1838, was second in a family of four sons and two daughters of Sir John Low [q. v.], general in the Indian army, by his wife Augusta, second daughter of John Talbot Shakespeare, of the East India Company's civil service. His eldest brother is Mr. William Malcolm Low, formerly of the Bengal civil service, who was M.P. for Grantham from 1886 to 1892.
After education at a private school Low received a commission as comet in the Indian army on 26 Aug. 1854, and was posted to the 4th Bengal cavalry. His first service was in the expedition against the Santals, and won him promotion to lieutenant on 29 Sept. 1855. On the outbreak of the Indian Mutiny his regiment joined the rebels, and Low was subsequently attached to the Delhi field force. He took part in the action at Badli-ke-Serai on 8 June 1857 and in the brilliant victory of John Nicholson [q. v.] at Najafghar (25 Aug.). During the siege and fall of Delhi (20 Sept.) he served as A.D.C. to General (Sir) Archdale Wilson fq. v.], and was mentioned in despatches (Lond. Gaz. 15 Dec. 1857). After accompanying Sir Colin Campbell (afterwards Lord Clyde) [q. v.] on his march to the second relief of Lucknow (19 March 1858), Low was appointed brigade-major to the Agra field force, and rendered useful service in the pursuit and capture of rebels in Central India. At the and of the oampaign he received the medal with two clasps and the thanks of the governor-general of India.
Promoted captain on 1 Jan. 1801 he commanded a company in the second Yusafsai expedition under Sir Neville Chamberlain [q. v. Suppl. III. and was awarded the medal with clasp. He attained the rank of brevet-major on 16 Feb. 1872 and of lieut.-colonel on 8 Feb. 1878. The following year he commanded the 13th Bengal lancers in the campaign against thie Zakha Khel Afridis of the Bazar Valley. On the renewal of the Afghan war Low shared in the punitive expedition against the Zaimukhts in Dec. 1879, and was prosent at the assault of the Zava heights. In June 1880 Sir Frederick (afterwards Lord) Roberts secured his appointment as director of the transport service. Under Low's energetic and intelligent management the transport organisation worked smoothly and efficiently (Lord Roberts, Forty-one Years in India, 30th edit. 1898, p. 466); and his services on the march from Kabul to Kandahar were generously acknowledged by the commander-in-chief (Lond. Gaz. 7 Nov. 1879, 3 Dec. 1880). He was rewarded with the C.B., the medal with clasp, and the bronze star.
Low became colonel on 8 Feb. 1882, and was nominated brigadier-general In Hay 1886 to command the second-class district of Bareilly. In the following July he was detached for service in Upper Banna, where a desultory armed resistance was prolonged for two years after the annexation of the country. He was given the command of a brigade at Minbu, and daring the period of pacification he was incessantly engaged in arduous guerrilla warfare. He was mentioned in despatches (Land. Gaz. 2 Sept. 1887), received the thanks of the governor-general of India, and was created K.C.B. In 1888 he resumed charge of the Bareilly district, and had the command of the first-class district of Lucknow from 1892 to 1895. Meanwhile he was promoted major-general on 5 Oct. 1893.
His proved capacity for organisation led to nis nomination as commander-in-ohief of the Chitral relief expedition. Advancing from Nowshera in the spring of 1895 Low concentrated his whole force on the Malakand pass, and on 3 April stormed the heights, which were held by 6000 Plathans. The enemy were again defeated at the Panjkora, and a flying column, despatched by Low under Sir William Gataore [q. v. Suppl. II], reached Chitral on 15 May
