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were directory only and not of the essence of the gift,that is to say, to determine which conditions were

not precedent to the gift taking effect. Judgmentwas reserved on the conclusion of the hearing of the

summons, and Mr. Justice Swinfen Eady delivered a writtenjudgment on April 7th. The testator estimated the amount

of the residue at .615,000, but the actual amount proved tobe about .540,000. The will provides that an annuity of -E100is to be paid to the testator’s sister, Mrs. Mary Ann Stirk ;that during her lifetime the residue of the income of thetrust is to accumulate and be invested ; and that after herdeath the whole estate is to be realised and devoted to

charitable purposes. Various carefully thought out projectsand alternative schemes were provided for, but it is unneces-

sary to refer to these in detail since the court has decided

that the first object mentioned in the will is the proper oneto be carried out. Therefore the vicar and churchwardens of

St. Mary’s, Low Harrogate, are to receive the gift, the detailsof which are as follows: That the trustees are "to payand apply such sum or sums of money after the death of thesaid Mary Ann Stirk in the erection of a church with entirelyfree seats, monument-chapel, and if means permit of aschool house, in connexion with the Established Church ofEngland, and also a sum of .S1000 towards the endowmentof such church (according to the written instructions given),provided the remainder required by the Bishop of the diocesefor the endowment of the said church be found or con-tributed by the Ecclesiastical Commissioners or other Churchassociation within a reasonable time." " Any surplus upto .63000 that remains after carrying out the scheme men-tioned above is to be equally divided between four charitiesin Harrogate-namely, the Bath Hospital, the ConvalescentHospital, the Home for Incurables, and the Cottage Hos-pital ; and if a further sum of Z1000 remains it is to be

paid to the pension fund of Epsom College. The importantquestion was raised whether the accumulations of incomemight now be stopped, notwithstanding that the testator’ssister, Mrs. Mary Ann Stirk, is still living. As this ladyobjects to such a course being followed, on the ground thatif she lives beyond 21 years from the testator’s death, she, assole heiress-at-law and next of kin, may become entitledthenceforward during the residue of her life to the income ofthe estate, no immediate application and division of the

residuary estate can be made. Moreover, the amount whichthe Epsom College Pension Fund may receive is dependentupon the amount of the ultimate surplus, which in turn maydepend upon the length of time during which the income ofthe trust fund is allowed to accumulate. The accumulation

is, therefore, to be continued during the life of Mrs. MaryAnn Stirk, or until further order, not to exceed a period of21 years from the testator’s death.

THE LATE SIR DONALD CURRIE AND MEDICALEDUCATION.

IT is with great regret that we have learned the death ofSir Donald Currie which took place at Sidmouth on

April 13th. Sir Donald Currie was a man well known in

the shipping world as the head of the Union Castle Line,while he for many years represented West Perthshire in theHouse of Commons. With his career as merchant and

politician the world has been made very familiar by manyexcellent obituary notices in the press, but we wish

here to lay stress on the fact that he was one

of those philanthropists who, working unostentatiously,furthered many schemes for the welfare of his fellowcreatures. Of late years he had interested himselfin the needs of the Universities of Edinburgh and Belfast,and a little more than five years ago lent his support to themovement which has resulted in the incorporation of

University College, London, in the reorganised University ofLondon. To carry out this scheme it was necessary to find

funds for the erection of a school of final medical studies inconnexion with University College Hospital, and for this

purpose Sir Donald Currie gave a sum of .680,000. As if this

act of generosity was not sufficient, he further added a sum off.20,OOO for the erection of a nurses’ home and a maternitystudents’ house in connexion with the same institution, andgracefully added a further sum of f.2500 as a gift from hisdaughters to furnish the latter buildings. When we considerthe straitened circumstances into which medical educationin London has fallen, such generosity deserves from our

profession the warmest thanks and approval. Sir Donald

Currie, though well aware of the necessity for rich men togive of their wealth towards the maintenance of the hospitalsof London and elsewhere, a duty to which he again and againresponded, was none the less keenly alive to the necessityfor providing support for the medical schools of the metro-polis-institutions the maintenance of which is so importantto the public at large. Though, as he stated in public,there was some reason to hesitate to provide fundsfor hospitals, because in his opinion these should receive

support from the rates, there could be none when theneeds of the medical schools were considered. He looked

upon these as technical institutes of the greatest importanceto the capital of the Empire, and in the absence of Govern-ment subventions he felt it was the duty of those who couldgive help to do so. As might be expected, holdingthese views, he was keenly alive to the necessity for

supporting movements which had as their object the

advancement of medical knowledge; the problems of

disease, no less than high finance and politics, were readilygrasped by his acute intellect and at once secured his

sympathy and practical support. To him the present stateof medical education in this country was a matter of seriousimport, and he hoped that the time would soon come whenthe medical teachers, like those of any other departmentof learning, would receive adequate endowment. His

munificent gift for the purpose of the advancement of theinterests of the University of London was a practicalexpression of his cherished views. To him it seemed a

remarkable state of affairs that whilst on the continentmedical studies receive the support of the various Govern-ments, whether monarchical or democratic, and in Americaalmost fabulous endowment at the hands of its enlightenedrich, in London, with its unequalled opportunities for the

investigation of disease, medical studies were cramped, andthe hospital and medical school teachers were exploitedin the interests of the public at large by a system whichleft the support of teachers and schools to the chance

patronage of a comparatively few medical students.

CONGENITAL MALARIA.

THE possibility of the transmission of malaria to the

foetus in utero is a subject of discussion. The parasite hasbeen found in the blood of the new-born on several

occasions, but sufficient time had elapsed for post-natalinfection. Hitte has described malarial parasites in theblood of the umbilical cord in two cases, but in the articleon Malaria in Allbutt and Rolleston’s "System of Medi-cine " Professor W. S. Thayer pronounces the evidence

unconvincing. At a meeting of the Societe Médica1edes HÔpitaux of Paris on Feb. 5th M. Dumolard andM. Viallet reported the following case, which seems to

put beyond doubt the possibility of congenital infection. Amarried woman, aged 31 years, was admitted into the civilhospital of Mustapha. Algiers, on August 12th, 1908. Shehad three healthy children and was in the seventh month ofpregnancy. She lived in a malarious region but had always