222 HARVARD LAW REVIEfV. of the trust res led to much confusion of reasoning, although the decision was correct. A much sounder case is that of In re Barned's Banking Co., 39 L. J. Ch. 635, which held that the relation created by a deposit of money with a bank for the purpose of removing an indebtedness to a third party is not one of trust, but of debtor and cred- itor. Business expediency requires that a bank be permitted to mingle with its own funds deposited for such purposes. There can, therefore, be no specific trust res, and the bank must be regarded as the debtor of the depositor. REVIEWS. The Law of Wills, for Students. By M. M. Bigelow. Boston : Little, Brown, & Co. 1898. pp. xxxii, 398. In contrast with the voluminous text-books at present in vogue, it is refreshing to notice a small, compact, and well-written law-book. Such a book is Mr. Bigelow's work on the law of wills. No claim is made to any great originality ; limitation of space forbids full discussion of prin- ciple. But as a summary, the book has a distinct reason for its existence, which is no small praise. If criticism were to be offered, it would be that for so compact a work the details of the minute rules for the " sec- ondary construction " of wills are examined with a care more than likely to confuse the student, and of value chiefly to a professional. Yet it is mainly for the student that the book is written. The substantive law is completely stated. The ground taken in regard to the construction of wills is somewhat to be regretted, the adherence to the narrow rule as set forth by Sir James Wigram (p. 161). A broader rule would have been more satisfactory. See Notes. In view, moreover, of the full discussion of how to construe an ambiguous word by the context, the rules of construction by means of extrinsic facts are neglected, — rules which seem to be, not as the author contends, merely rules for defin- ing the primary meaning of the words, but rules of construction for de- termining between the primary and the secondary meanings (p. 162). One other matter is too severely stated, the test of undue influence (p. 85). While the author admits that persuasion by wife or child may not amount to undue influence, he says that persuasion by one whose power is illegiti- mate, as, for instance, a mistress, is undue. This conclusion hardly seems sound. Undue influence must be coercion. Mental coercion it may be, but persuasion is not coercion at all. Wingrove v. Wingrove, 1 1 P. D. 81. Criticism, however, may give a false impression, for there are few things to be criticised adversely. The many applications of the rules of revocation are well treated, and the author's adherence to principle is commendable when he finds " grounds to doubt " whether a will can be looked upon as revoked when the testator's purpose to revoke was frus- trated by the misconduct of another. In general, as a handbook of the subject, the work succeeds. j. g. p. The Hudson's Bay Company's Land Tenures and the Occupation OF AssiNiBoiA BY LoRD Selkirk's Settlers. With a List of Grantees under the Earl and the Company. By Archer Martin. London : WilHam Clowes & Sons, Limited. 1898. pp. ix, 238. In 1634 a vast tract of American territory was granted the "Gover- nor and Company of the Hudson Bay Adventurers." The Company, in
