484 HARVARD LAW REVIEW. SO far as to let in a charge of that amount, payable to the lunatic's executors, in lieu of treating the allowance as an advancement. In 1884 the same case came up again, in Re Beridge, 50 L. T. N. s. 653, C. A. (Sparrow, the lunatic, seems to have had his name changed to Beridge in the interim). It appeared that the nephew's private income of ;^220 had increased to ^^300, and that he had married and had a son, thus practically destroying the chances of the next remainder-man in tail, who had opposed the previous petition, but who now assented. The petitioner prayed an increase of his allowance to £1000. Other next of kin op- posed. Baggallay, L. J., said that the question was, " What would be a reasonable allowance to enable the nephew to maintain his position of a clergyman . . . without any cure, ... a married man with one child, and who possibly may have more children." Cotton, L. J., dissented from any allowance, on the ground princi- pally that so large an allowance charged by way of mortgage would leave the estate unwisely incumbered at the lunatic's death. Lindley, L. J., said that they did not differ in principle, and that to him some addition seemed only reasonable, considering the peti- tioner's prospects and "the large [family?] living we have heard of," to which, it seems, the clergyman might hope to present himself. The allowance was increased to jCjoo. Cotton's argument, although cogent, goes rather to show the viciousness of treating the allowance as an advancement, and of making such a beneficiary mortgage his future. 1882. /// /-^ Evans, L. R. 21 Ch, D. 297 (C. A.). Here the lunatic had a surplus income of ^975 after his mainte- nance in the asylum was provided for. The petitioner was worthy, being a clergyman eighty-one years of age, with eight dependent children and no means, reduced to indigence through no fault of his own by the Disestablishment of the Irish Church. He was one of eight first cousins and next of kin, another of the eight being heir-at-law. It did not appear that the lunatic had ever heard of him. Jessel, M. R., commented upon that fact, but said that it made no difference. He decided the case upon the absence of any claim, legal or moral, of a mere cousin. " South of the Tweed, that is not, I believe, considered to constitute a strong claim. ... It has never been said that ... it is to be presumed that it is a matter of interest to him [the lunatic] what becomes of his first cousins." The only comment necessary to make upon this decision is, that it probably accurately expresses the extent of the average Eng-
