REVIEWS. 22$ If these Societies had for their object merely the protection of the lower animals, though they might be benevolent, they could hardly be called philanthropic, or chari- table. But the court considered that the advancement of morals among men was also involved in their object, and that they were therefore brought within the term charity. So, a Society for the Prevention of Cruelty to Animals, a Home for Lost Uogs,a Society for Protection of Animals liable to Vivisection, ( 35 Ch. D. 472 ), and an institution for studying and curing diseases of beasts and birds useful to man, ( i De G. & Jo. 72 ), have been held charitable. Trusts — Fraudulent Sale — Following Proceeds. — Plaintiff was induced by the fraud of B to sell him sugar on credit. B resold on credit and later made an assignment for the benefit of creditors. Plaintiff then, on discovering the fraud, sued B's assignee for the proceeds of the resales. The particular proceeds could be identified. Held, plaintiff has an equitable lien on the proceeds. Avierican Sugar- Kejining Co. v. bancher, 40 N. E. Rep. 206 ( .. Y.). The case is interesting as involving a constructive trust of the proceeds of personal property, where the trustee was neither a fiduciary nor awrongdoer who lacked title ab initio. The trust was, however, properly implied because of the fraud, and equity " makes use of the machinery of a trust for the purpose of affording redress in cases of fraud. " Bispham on Equity, § 91. Given the trust, the proceeds, if identified, can be followed. Newton v. Porter^ 69 N. Y, 1 33. REVIEWS. Commentaries on the Law of Private Corporations. By Seymour D. Thompson, LL. D. San Francisco : Bancroft- Whitney Co. 1895. 8vo. 6 vol. It is unsatisfactory to make comment upon a work of such importance and magnitude as Thompson on Corporations, before the work is given to the public in its completeness ; for any judgment passed on the scope and thoroughness of the treatment of the Law of Corporations, when two of the six volumes have yet to appear, must necessarily lack finality. There- fore it has been deemed best to postpone consideration of this publication until it can be reviewed as a whole. The last volume is announced fur publication in November. MtTNiciPAL Home Rule. A Study in Administration. By Frank J. Goodnow, A. M., LL. B., Proftssor of Administrative Law in Columbia College. New York and London : Macmillan & Co. 1895. ^^o* PP- ^^^^j 283. The only objecionable thing about this book is its title, which gives no adequate idea of the nature or value of the contents. The author has given the reader not only a thoughtful treatise on the proper sphere of municipal action, but also an admirable summary of the present state of the law. There is no other book which contains so valuable a statement, in so small a space, of the law on certain elementary points relative to municipal corporations. Chapters VL to XL (both inclusive) fully justify the hopi modestly expressed in the Preface, that the book may be useful from the legal as well as from the political point of view. These chapters discuss the liability of municipal corporations for torts, and the degree of protection afforded to municipal property by the constitutional provisions respecting private property. This part of the book forms an admirable introduction to what Professor Goodnow aptly terms the *' great work " of 30
