RECENT CASES. 293 caused by the infliction upon the body of putrid animal matter containing poisonous " kicillus anthrax " is death from disease, and not from accident, within the terms of an accident policy. Ruger, C. J., and O'Brien, J., dissenting. Bacon v. Mutual Accident Association, 25 N. E. Rep. 399 (N. Y.). Insurance — Laches of Assignee. — A life-insurance policy was assigned to W., who later reassigned a part of it to the insured. Both assignments were so attached that they could be easily removed. The insured detached the assign- ments and surrendered the old policy to the company, procuring instead a paid- up policy, which he assigned to a purchaser for value, without notice of the pre- vious assignments. Held, that W. was guilty of such laches that he could not take advantage of the priority of his assignment. Bridge v. Wheeler, 25 N. E. Rep. 612 (Mass.). Judgment — Satisfaction. — Property is levied on and sold by direction of the execution creditor who purchases it for the amount of his judgment with notice that it does not belong to the execution debtor. Held, that such purchase is a satisfaction of the judgment though the debtor had no title or interest what- ever in the property, and the purchaser (the execution creditor) refuses to accept it. The doctrine of caveat emptor is strictly applied, and the purchaser operates as an irrevocable satisfaction of the judgment. Thomas v. Glazener, 8 So. Rep. 153 (Ala.). Libel — Corporations — Charge of Corruption. — A corporation cannot main- tain an action for libel in respect of an imputation of corruption, for it cannot be guilty of corruption, although the individuals composing it may. Mayor, etc., of Manchester . IVilliams, 4 ]irist, 191 (Eng.). Municipal Corporations — Delegation of Power. — The power to make certain regulations in regard to contagious diseases was delegated to an executive committee, who appointed local sub-committees. In the absence of any regu- lations by these sub-committees in relation to dogs, and without revoking the power granted them in this respect, the committee itself made certain regulations in regard to dogs. Held, that these regulations were valid. The delegation did not deprive the executive committee of the right to exercise the powers dele- gated. Huth v. ClarJ^e, 63 L. T. Rep. n. s. 348 (Eng.). Real Property — Action against a Railroad for Damages — Res Adjudicata. — A railroad having been constructed along a street on which plaintiff owned two lots, a few hundred feet apart, he brought action against the railroad company for damages to one of these lots by reason of the construction and opera- tion of the railroad, and recovered a judgment. He subsequently brought another action for damages to the other lot, arising from the same cause. Held, that the judgment in the former suit was a bar to the action for damages to the other lot accruing prior to the former suit from the same cause, the matter being res adjudicata ; that the cause of action was the construction and operation of the railroad ; and that this was but one cause of action, irrespective of the number of pieces of property damaged. Beronis v. Southern Pac. R. R. Co., 24 Pac. Rep- 1093 (Cal.). Real Property — Easements — Ancient Lights — Future Damage. — Action to restrain the obstruction of ancient lights. The court granted an injunction on the following ground: That although the injury to the premises in their present use may not be so considerable as to justify the granting of an injunction, yet the probable injury in the future use to which, from the circumstances, the premises may reasonably be expected to be put, would be considerable, and so the plain- tiff entitled to an injunction. Dicker v. Popham et al., 63 L. T. Rep. n. S. 379 (Eng.). The court follows the rule laid down in Aynsley v. Glover, 18 Eq. 551, that equity will not interfere unless the injury is such that the plaintiff would get considerable damages at law. In finding considerable damages the court follows Moore v. Hall, 3 Q. B. Div. 178, which departed from former decisions, and in assessing damages considered the probable injury to the possible future use of the premises. In this case, for the first time, as said by the court, the right of the plaintiff to relief rests mainly in damages likely to accrue in the future. Real Property — Emblements — Land Set off as Alimony. — A growing crop of wheat sown by a husband on his laud pending a suit for divorce and
