Education.-The Department of notwithstanding the severe losses of Education lost a number of teachers the epidemic. by their entry into military service and because of low salaries. Its work was seriously interrupted by the earthquake and the influenza epidemic. Notwithstanding these handicaps, the work accomplished was creditable, and the total enrollment increased 18,000 over the preceding year, being 160,794; in addition, 5,722 attended private schools. The number of teach ers employed was 2,984, of whom all but 148 were native Porto Ricans. Twenty new school buildings were completed during the year, 24 more are under construction, and 26 new school sites were acquired. The number of buildings used for schools was 1,724, 529 of which were public property and 1,195 were rented. The total expenditure for school work was $2,467,703.29. Although statistics show substantial progress, only a beginning has been made in the task of educating the people. The situation is thus described by the Governor in his annual report for 1919:

Commerce and Industries.-The external trade in the fiscal year 1919 reached a total of $141,869,400, being $4,223,096 in excess of the recordbreaking figures of the preceding year. The trade balance in favor of Porto Rico was $17,095,680. Exports increased about five and one-half million dollars over those of the preceding year, about half a million dollars being due to the increase in the price of coffee, though the crop itself was the smallest since 1905. There was an increase in sugar shipments, some of which, however, represented part of the 1918 crop which was held over awaiting shipment. Sugar remains the chief export, though its percentage of the total value of exports has dropped from 69 per cent. in 1916 to a little more than 60 per cent. in 1919. The production of 1919 was 47,795 tons less than the crop of 1918. There were notable increases in the exportations of coconuts and honey. Other articles of export decreased about a million and a half dollars, due to the lack of transportation facilities for fruit shipments and to the decline in the value of cigar and tobacco shipments.

Imports decreased nearly a million dollars, principally in the items of cotton goods, iron and steel manufactures, fertilizers, leather goods, and meats, and of beans and peas, due to home production. Increases were noted in importations of rice and wheat flour, fish, and dairy products.

The total exports for the last three fiscal years are shown in the following table:

Much has been already accomplished, wide popular interest has been created in the education of the children, and an excellent foundation has been laid upon which to build an adequate modern school system for all the children of the Island. The need now is for larger funds for every phase of educational work. The last Legislature rose to the occasion and increased appropriations so that next year the expenditures from all local sources will reach about $3,000,000. If Congress would supplement the local effort by a generous appropriation of Federal funds, rapid progress could be made. Sanitation. The regular work of the Department of Health was also greatly interrupted by efforts to control the influenza. Of the total number of deaths in the fiscal year ending June 30, 1919, 39,974, those due to the epidemic were 10,888, which increased the death rate from 27.71 per thousand in 1918 to 31.75. Seventytwo per cent. of the total deaths was due to tuberculosis, malaria, hookworm, and infant mortality. The tuberculosis sanitarium is nearing completion, and other hospitals are being constructed. The figures for infant mortality, though slightly below those for the two preceding years, are distressingly high. Much attention is being devoted to this subject. The excess of births over deaths was 13,374, war.

Coffee
Sugar
Tobacco

Fruits
All other

Total

.$80,970,917

$41,362,229 $48,132,419

5,879,652
3,459,569

5,505,316

6,065,573

16,142,555

15,188,678

11,723,712

3,628,214

2,898,580

$54,015,903 $74,294,022 $79,496,040

American goods comprised 93 per cent. of total purchases, and 89 per cent. of all shipments were to the United States, as compared with 89 per cent. and 80 per cent., respectively, in 1914, the last year before the

VIRGIN ISLANDS

General Conditions.-A change of administration took place in the Virgin Islands on April 8, 1919, when Rear-Adm. James H. Oliver, U. S. N., was relieved by Rear-Adm. Joseph W. Oman, U. S. N., as governor.

The Governor's report shows that many minor improvements were made during the fiscal year ending June 30, 1919, but that no active work along the lines of expansion has been possible owing to lack of funds. Pressing problems are an increase of educational facilities, maintenance of efficient police protection, improvements in the medical service and sanitation service, the dredging of St. Thomas Harbor, and the establishment of public libraries and of a poor farm to care for the paupers. During the wa many additional cases of poverty were added to the already large number of poor, and it is estimated that fully 2,500 persons, 10 per cent. of the population, may be classed as paupers.

The Governor reports that the amount annually appropriated by Congress has not permitted of much improvement over the old order of things, and there is urgent need for additional funds if the Government is to be run in a manner approaching

lowed by American laws, customs, and ideals as soon as possible. These people are pleading to be Americanized. There are great possibilities in these islands. They should no longer be neglected.

The most important agriculture in the islands is sugar, of which approximately 10,000 tons was exported in the fiscal year. During the year the Government succeeded in opening the Porto Rican market to cattle from the Virgin Islands. About $30,000 worth of cattle were exported, and it is thought that the cattle-raising industry will eventually become an important one. Exportation of cattle to Porto Rico was formerly prohibited on the ground that the Virgin Islands were in the tick-infested area.

Education. Some improvement is noted in the public schools during the fiscal year 1919, although the department was greatly handicapped by the lack of funds. During the year two assistant directors of education were appointed, two new school buildings and a supply of maps, books, etc., were acquired, and a plan was perfected whereby a teacher's training class, composed of natives, has been organized. The most urgent needs are high schools and reform or training schools. There are over 3,000 school children, which represent about one-eighth of the population.

American standards. He states also Health and Sanitation.-Perhaps that there is growing unrest among the most important work accomthe inhabitants at the failure to plished since the transfer of the ischange the old Danish laws, continued lands to the United States has been in force by Congress under the act of in the department of health. In St. March 3, 1917, and that work is pro- Thomas the death rate has decreased gressing on the drafting of a modern from 39.4 to 23.9 per 1,000. Similar American code. As to this he says: favorable conditions exist in the mu"The inhabitants as a whole welcomed nicipality of St. Croix. Marked atthe change of sovereignty in the belief tention has been paid to infant-weland hope that conditions would be im- fare work, and the infant mortality proved, but the time is rapidly ap- per 1,000 births shows a striking reproaching when unrest and dissatis- duction from 248 in 1917 to 149 in faction will prevail unless something 1918. Food inspection received atmore tangible is done." As evidence tention during the year, and much of this unrest he refers to the testi- stress was laid on mosquito eradicamony before a committee of Congress A successful undertaking has in August, 1919. The report of this been the conducting of a training committee contained the following: school for native nurses at each municipal hospital. During the fiscal The Americans, since their occupation, year the American Red Cross comhave done considerable work along lines of sanitation. Apparently, there has been pletely equipped the municipal hosto education. The pitals with up-to-date furniture, surpeople of the islands feel that they have gical instruments, and laboratory apbeen neglected by the United States; that when the American flag went up in the pliances. There is an urgent necesVirgin Islands, it should have been fol- sity for increased hospital facilities.

no improvement as

tion.

VIII. LAW AND JURISPRUDENCE

FRANCIS M. BURDICK

FOREIGN JURISPRUDENCE

lands. The opinion contains an interesting discussion of the rights of aboriginal tribes in lands which they inhabit, and reaches the conclusion that in this particular instance the rights of the aborigines were at the disposal of the Crown after the flight of their king and the conquest of their lands.

Legislation.—The volume of peace the intention could be established by legislation during the year in Great orders-in-council dealing with the Britain is meager. Ch. 52 (8 and 9 George V) prohibits all persons from searching or boring for or getting petroleum within the United Kingdom unless acting on behalf of the Government or holding a license under the Act. Exceptions are made in favor of those who were using any supply of natural gas for commercial purposes when the Act was passed and of those who in the course of mining or other lawful operations might set petroleum free. By Ch. 59 power to determine the date of the termination of the Great War is given to His Majesty in Council, the only limitation being that "the date so declared shall be as nearly as may be the date of exchange or deposit of ratifications of the treaty or treaties of peace." This limitation is minimized by the annexed provision that "the date declared shall be conclusive for all purposes of this Act." Chapter 3 (9 George V) confers upon a Secretary of State power to regulate air navigation over the British Islands and the territorial waters adjacent thereto and adds various provisions to the Aerial Navigation Act of 1911 and 1913.

Judicial Decisions: Privy Council Decisions. The high political importance of topics which fall to the Privy Council for examination is illustrated by the case In re Southern Rhodesia (1919 A. C. 211, 88 L. J. P. C. 1). The conquest of a part of S. Rhodesia by the British South African Co. gave to the Company no political dominion over the territory but constituted it a sort of trustee or mandatary for its administration. It was not essential that the Crown should issue a formal proclamation of its intention to annex this region;

Contracts.-The defendant agreed to construct a steamer for plaintiff, subject to a proviso that if France became engaged in an European war by reason of which defendant could not within 18 months from the agreed date of completion deliver the steamer, the contract should be void, and all the money paid by the purchasers should be repaid to them. It was held that the Great War prevented defendant (a French company) from delivering the steamer and discharged it from all contract obligations. (New Zealand Shipping Co. v. Société des Ateliers et Chantiers de France, 1919 A. C. 1.)

A contract for the sale and delivery of goods "as requested" does not bind the seller for an indefinite period, but only for a reasonable time. Hence a buyer to whom goods were delivered as requested during a reasonable period cannot after the lapse of three years compel the seller to deliver the balance of the goods named in the contract. The seller is entitled to treat the contract as having been cancelled by the buyer. (Pearl Mill Co., Ltd., v. Ivy Tannery Co., Ltd.,-K. B.—.)

Parties had entered into an oral contract for the sale and purchase of a house. The vendor gave to the vendee a receipt for the deposit made by the latter, containing also a statement of the purchase price, of the