The subject who presented this anomaly of development of the scalp was M. B., aged 66, a peasant woman from the province of Comasca. Of medium height, regular conformation of body, dark complexion, irides dark chestnut, thick and black eyebrows, hair thick, strong, black, with only a few white ones, notwithstanding her advanced age. Her mother, a brother, and a sister have been insane. She suffered some years ago from puerperal mania, and was finally admitted to the asylum at Como labouring under simple lypemania, on 25th March, 1884. She died suddenly from syncope on the 27th of the same month. The autopsy revealed advanced fatty degeneration of the heart and liver.

The case of Neill, the Lambeth poisoner, recently sentenced to death and executed for a diabolical murder, raised several points of medico-legal interest. (1.) The highly technical character of the chemical evidence which Mr. Justice Hawkins and the jury ex necessitate rei accepted from Dr. Stevenson without being able, as the learned judge very frankly admitted, to follow the elaborate tests by which that distinguished expert arrived at his conclusions, has once more brought to the public notice the position of scientific witnesses in the Courts of Law. Dr. Cook, of Bristol, in a notable letter to the “Law Times,” has suggested a new solution of the vexed and inveterate problem, How should scientific facts be established in juridical proceedings ? Let the tribunals, says Dr. Cook in effect, recognize their own incapacity and a fortiori that of jurymen to understand scientific processes, and let a commission of experts be appointed to inquire into and report upon issues referred to it by the judge presiding over the trial of any complicated medico-legal case. This commission would consist of, say, three members. It would have power to call before it the expert witnesses for the prosecution, and, if there were any, for the defence; to examine and cross-examine them; to hear counsel on the matters in dispute, and possibly to see the crucial tests performed before preparing and presenting its report. This scheme, which is partly borrowed from the continental system of preliminary reports, seems to us, however, to lie open to two objections. In the first place it would involve expense. The members of the scientific commission, unlike the arbitrators of a tribunal de commerce in France or Belgium, would have no career before them as the goal of their labours, and could not be expected to act gratuitously. Dr. Cook estimates that an annual sum of £2,000 would cover the working expenses of his proposal, and the British taxpayer could no doubt be induced to make this sacrifice if he were convinced that it contributed to the interests of justice. But a more serious objection remains behind. Suppose that the commission differed in opinion, could the judge safely advise the jury in a case of life and death to act upon the report of a bare majority? Would the jury take such advice even if it were given, and in every such case would not the tribunal be thrown back upon that very weighing of scientific testimony and balancing of scientific authority which it is Dr. Cook's great object to avoid ? We venture to think that there is a more excellent way. The law has given many hostages to the principle ubique in qua arte credendum. The Admiralty Division hardly ever disposes of a difficult question of shipping law without the aid of the elder brethren of Trinity House as nautical assessors. Every court, from the highest to the lowest, that possesses jurisdiction in patent cases has power to summon expert assistance. In the High Court of Justice itself judicial references are scarcely less common than public trials, and under the Rules of Court the judges are enabled to call in scientific experts in every cause other than a criminal prosecution by the Crown. If this power were simply made universal the end in view would be attained without expensive or elaborate machinery. The task of advising would belong to the assessor; the responsibility of deciding would rest, as at present, with the judge and the jury. (2.) On the trial itself we do not propose to dwell. The prosecution was conducted by the Attorney-General, Sir Charles Russell, with great ability, and in the main with exemplary moderation. The defence was all that could be expected under the circumstances, but the learned counsel for the prisoner—Mr. Geoghegan—like Serjeant Shee in defending Palmer, was, metaphorically speaking, placed in a cleft-stick. He had both to impeach and to uphold the scientific accuracy of the expert of the prosecution. The symptoms of Matilda Clover's death, said the learned gentleman in substance, may not have been due to strychnine poisoning, for Dr. Stevenson is fallible, and his tests may have yielded wrong results. But Ellen Donworth's death (with which Neill was not charged) must have been caused by strychnine, for Dr. Stevenson found it in her body, and Dr. Stevenson could not have been mistaken. A short interval of time, of course, elapsed between the use of these mutually destructive arguments which Mr. Geoghegan was compelled by the weakness of his case, and, indeed, by the very logic of his position, to employ. But their glaring inconsistency did not escape the eyes of the jury, and must have told heavily against the prisoner's chances of acquittal. There can be no doubt that Neill was properly convicted. No direct evidence of administration, indeed, was forthcoming, and the evidence of identity was so weak that we can readily understand the anxiety with which the counsel for the Crown are said to have watched the progress of the case. But the circumstantial evidence was strong enough to justify the verdict of guilty which the jury unhesitatingly returned. The alleged inadequacy of Neill's motive need not greatly concern us. To a well-regulated mind no such thing as an adequate motive for the commission of a crime can possibly exist, but on the unstable mental equilibrium of persons like Neill, the slightest and most obscure motive may operate with even more power. The old story told by Count Cenci to Cardinal Camillo throws some light on such judicial enigmas:

Shakespeare so clearly held up the mirror to nature that every special student finds his specialty recognized by the great dramatist. We do not for a moment suppose that Shakespeare made a prolonged study of the insane or of the mental defects associated with senility, yet when he came to portray a weak-minded old man his observation in no way misled him, and we have in his Lear one of the most masterly descriptions of a demented king that any literature, whether special or general, can provide.

The facts of this remarkable and extremely narrow case, which was tried by Mr. Justice Gorell Barnes and a special jury, at the close of last year, are too fresh in the minds of our readers to require or to justify recapitulation at any length, and it may suffice to state that the point at issue was whether certain testamentary documents executed by a Chancery lunatic, Miss Ellen Roe, were or were not vitiated by the alleged mental unsoundness of the testatrix. The evidence was very evenly balanced. On the one hand, Miss Ellen Roe had been found lunatic by inquisition; no supersedeas had been obtained. The Lord Chancellor's visitors were of opinion that she did not possess testamentary capacity at the critical period; the deceased lady had proposed to bequeath her property to the Dean of Norwich, and to leave legacies to the Archbishop of Canterbury and the Lord Chancellor, and a strong effort was made to show that she was under the influence of an insane aversion towards her sisters, and that the case, therefore, came within the ratio decidendi of Dew v. Clark and similar authorities. On the other hand, it was contended, and evidence was adduced to prove, that the only form of insanity from which Miss Roe had ever suffered was temporary alcoholism, and that her aversion to her sisters was at first merely the indifference caused by long absence from home, and afterwards the dislike which the inmate of an asylum is apt to feel to the persons whom she supposes to have put her there. It was also proved that one of the Chancery Visitors had expressed an opinion that Miss Roe might be allowed to make a will—although, of course, without undertaking to say that it would be valid—and that the actual preparation and execution of the disputed instrument were preceded and accompanied by every possible precaution on the part of testatrix's solicitor. In the event the jury pronounced in favour of Miss Roe's testamentary capacity—a conclusion at which we might not perhaps have been able to arrive—but which it was perfectly possible for reasonable men to adopt under the circumstances, and the verdict was received in Court with the popular applause which the judicial obliteration of the stigma of insanity never fails to elicit. The course of this case was seriously impeded by the fact that all the reports of the Chancery Visitors with regard to Miss Roe were presumably destroyed at her death, and, at any rate, were not forthcoming for the purposes of the trial. We trust that Section 186 of the Lunacy Act, 1890, which renders this absurdity possible and lawful, will receive the early attention of the Legislature.

The case of Morley v. Loughnan is equally interesting to the student of human nature, the lawyer, and the psychologist. The details of the strange and painful story on which it turned are, no doubt, familiar to our readers, but a sketch of the salient features may not be inopportune. The late Mr. Henry Morley, from whom the defendant, Mr. W. H. Loughnan, a prominent member of the Close Sect of Plymouth Brethren, was alleged to have obtained sums of money, amounting to about £140,000, by undue influence, was an epileptic, possessed the exaggerated warmth of sentiment, the liability to alternate depression and elation, and the need for external guidance, which epileptics frequently display, and though not positively insane, passed at least the greater portion of his life on the borderland between the world of sane men and the realm of minds diseased. Conscious of the risks to which his son's mental condition exposed his substantial fortune, Mr. Morley's father had placed him under the friendly control of “companions;” and, when the narrative opens, this desirable appointment had just fallen to the lot of Mr. W. H. Loughnan. In the creed of the Close Sect of Plymouth Brethren the duties of entire dedication of property to religious purposes and sequestration from worldly society hold a cardinal place, and Mr. Loughnan laboured faithfully, and not without success, to imprint them upon the mind of his impressionable ward. At no time, however, was the balance between these great principles very accurately adjusted in Mr. Loughnan's teaching. At first the duty of dedication received excessive prominence, and Mr. Morley was dramatically asked whether the luxury with which he was surrounded was worthy of a disciple of Christ. Then the duty of sequestration became the lesson of the hour, and the imperative claims of dedication were somewhat feebly insisted on. At length Mr. Morley, after having written a letter of farewell to the world, went to live with his protector. Mr. Loughnan lent himself nobly to the task of making his self-invited guest's seclusion from temporalities complete, managing his business, conducting his correspondence, accepting large donations from his superabundant wealth, and drawing around him a close cordon of associations, corroborative of his own influence, from which Mr. Morley was only released by the hand of death. Then it appeared that Mr. Loughnan had benefited by his ward's weak generosity to the extent of £140,000, and the executors of the deceased gentleman properly subjected the nature of the relationship that had existed between Mr. Morley and his “companion” to the searching scrutiny of the Chancery Division. Into the miserable devices by which Mr. Loughnan endeavoured to resist first, the executor's claim, and, secondly, the exposure which its prosecution involved, we need not enter. Suffice it to say that Mr. Justice Wright, sitting as an additional judge of the Chancery Division, held that the gifts from Mr. Morley to the defendant were vitiated by the undue influence of the latter, and that the plaintiffs were entitled to receive the whole amount from him, and even from the innocent subdonees into whose hands part of the spoil had passed. We observe with surprise the statement in the pages of a legal contemporary that “this case presented no new legal difficulties.” The inaccuracy of this assertion is readily demonstrable. There are two classes of cases in which donations are set aside on the ground of undue influence; first, cases in which there is positive evidence that coercion has been brought to bear upon the donor; secondly, cases in which there existed a relation between the donor and the donee, capable of giving, and Calculated to give rise to undue influence, and the donee is unable to prove affirmatively that the donor had independent advice. Mr. Justice Wright held that in the case of Morley v. Loughnan there was positive proof of undue influence having been exercised. But his lordship was also prepared to hold, if necessary, that the relation between Mr. Morley and Loughnan was such a relation as brought the defendant within the second class of cases above referred to, and threw upon him the onus—which he had utterly failed to discharge—of vindicating the voluntary character of the gifts. This, if we mistake not, is a distinct advance upon previous decisions, and it will render the law of undue influence for the future much more difficult of evasion than it has been in the past.

In the year 1890 the late Dr. Henry Monro sketched the following suggestions for a petition to Parliament on the subject of habitual intemperance.