RECENT CASES. 241 by the stevedores of both parties. The jury, on this evidence, found that the shipowners were not "ready and willing to do their part of that which it was customary for them to do. " Held, that nevertheless the shipowner was entitled to demurrage. The obligation of the consignee to pay demurrage is absolute. The readiness and willingness of the master to do his part is not a condition precedent or concurrent. The consignee is liable unless he was prevented from unloading by the act of the master. Budgett 6^ Co. v. Binnington & Co.y 39 W. R. 13 (Eng.). Corporations — Resignation of Director.- — Where the charter contains nothing in regard to the resignation of directors, they contract to serve until their resignation is accepted by the company, and cannot be free from their office merely by tendering their resignation. 7/ seems also that the board of directors, with general power to manage the company's affairs, have no implied power to accept such resignation. Municipal Land Co. v, Pollingtony 63 L. T. Rep. N. s. 238 (Eng.). Criminal Law — Construction of Statutes. — The selling liquor to a minor on his representation that it is needed for his sick mother's immediate use, but without a written order, though within the letter, is not within the spirit, of Pen. Code Tex. art. 376, which makes it a misdemeanor for any person to knowingly sell liquor to a minor without the written consent of his parent or guardian. Waldstien v. State, 14 S. W. Rep. 394 ( Tex. ). Criminal Law — Evidence of Accomplices. — It is a general rule of prac- tice to advise a jury not to convict on the uncorroborated testimony of an ac- complice, but it is not error to refuse to do so. Com.w. Wilson, 25 N. E. Rep. 16 (Mass. ). Equity Jurisdiction — Statute of Limitations — Fraud. — A plaintiff sues in equity because he is barred at law, and claims that he is barred at law by reason of having failed to bring suit in time, and that his failure to bring suit in time was caused by the fraudulent conduct of defendants. Held, that, as the fraud charged is collateral to the plaintiff's cause of action (contract ) and not the foundation of the suit, equity will afford no relief. JaJ/rey v. Bear, 42 Fed. Rep. 571. Insolvency — Assets — Alabama Claims. — The assignee of one who made an assignment in bankruptcy before 1871 is not entitled to the sum paid the assignor for " war premiums " out of the residue of the Geneva Award. Such claims were expressly excluded from the award by the commissioners, therefore it cannot be said that at the time of his assignment the assignor had any right against Great Britain or the United States. Tajt v. Marsily, 24 N. E. Rep. 926 (N. Y.). Insolvency — Fraudulent Conveyances. — Where one of the terms of the sale of his business by an insolvent debtor is that he is retained in the manage- ment thereof at a salary, there is a benefit secured to him which renders the transaction fraudulent as against creditors. Stephens v. Reginstein et al., 8 So. Rep. 68 (Ala.). Libel — Criminal Prosecution. — The following false words were published by a newspaper : **It is now almost forgotten that Governor Haney pardoned his own brother out of the penitentiary. " Held, that they constituted a libel for which a criminal prosecution could be maintained. It is enough in a criminal action that the alleged libellous words were directed against a family. State v. Brady, 24 Pac. Rep. 948 (Kan.). Lien — Innkeeper — Married Woman's Separate Property. — Where a husband and wife stay together at a hotel, and the husband is the sole contract- ing party to whom credit is given, the separate property of the wife is not liable for the unpaid balance of the hotel charges; but the innkeeper has his lien on the wife's goods and luggage, because he was as much compelled to receive them as the husband's goods. Gordon v. Silber, 25 Q. B. D. 491 ( Eng, ). L"ss of Consortium. — A wife cannot maintain an action against another woman for debauching her husband. Doe v. Roe, 20 Atl. Rep. 82 ( Me. ). A similar decision was reached lately in Wisconsin (45 N. W. Rep. 523). But see Westlake v. Westlake, 34 Ohio St. 621, and Lynch v. Knight, 9 H. of L. Cas. i^-j "J, contra. Measure of Damages. — In an action against a town for injuries resulting
