capital it controls "as economical, useful, and just" to its owners as possible. Natur ally they will be rules calculated to achieve the avowed object of the receivership, and the court, with its threefold functions of judge, legislator and administrator, is surely clothed with sufficient power to accomplish that object. Hut the status of the employé in the meantime is undergoing a transition— the transition, namely, from freedom to slavery. But the relation of the court to the trust is calculated to prejudice his action in adju dicating demands of others than employés. The duty of preserving the property for the beneficiaries would very naturally lead a judge to scrutinize closely, if not suspic iously, every claim that would take prece dence of theirs. Of this nature are claims for goods lost in transportation, for damages done to property during the receiver's man agement, for materials used to repair or im prove the property; for personal injuries, re ceived through negligence in the manage ment of the railway, and claims for destruc tion to property by fire caused by negligence of employés. In fact, claims that would, when satisfied, reduce the receivership prop erty to the injury of the beneficiaries, con stitute by far the largest class of claims that arise against a receiver. Every time, then, that such a claim is submitted to the court, it is called on to perform incompatible func tions. Its first duty is to preserve the trust property for the beneficiaries, and it cannot allow a claim against the receiver without impairing that property. What must be thought of a rule of law that gives the re ceiver's court exclusive jurisdiction of such claims? IN closing an article in the American Law Register for August on "The Provability of Tort Claims in Bankruptcy," Stanley Folz says: To summarize the results of this discus sion it may be said that under the Act of 1898 tort claims reduced to judgment be fore the filing of the petition are provable.
The rendition of a verdict prior to that time is not sufficient liquidation of such claims to render them provable as liquidated claims under Section 63, ч (i). Tort claims un liquidated when the petition is filed are not provable if they arise from personal torts. When based upon wrongs which enriched the bankrupt the decided cases hold that unliquidated tort claims may be proved un der Section 63. « (4), if the claimant can waive his remedy c.r delicio and sue in quasicontract. This last right is not conceded without a reservation as to its validity. It is urged that it is created only by a forced and strained construction of the act. by giv ing to the expression "implied contract" a meaning accorded it in no other statute. Even if this construction be correct, the remedy afforded is scarcely adequate to the relief desired. The right to prove should exist whenever the bankrupt's estate has been enriched by the unjust acquisition or conversion of the claimant's property; but under the most liberal construction of the Act of 1898 the right to prove in such cases exists only when an assumpsit action can be brought upon the tort. IN The Lmv Times (London), John Ellis writes as follows about "Esperanto for Lawyers": Esperanto, the artificial language invented by Dr. Zamenhof, of Warsaw, is intended to be used merely as a means of international communication. Whilst it gives no en couragement to the notion that all nations should speak one tongue, the idea that everyone should learn a second language for international use is the very foundation of Dr. Zamenhof's creation. In what way does Esperanto effect its purpose? It is marvellously easy to learn, and that by all nations. Its grammar con sists of only 16 rules, with no bewildering: exceptions or irregularities. These concise rules can be learnt in half an hour. The simplicity of English grammar has been outsimplified. The pronunciation is phonetic and euphonious, difficult sounds having been
