Known as the Early Journal Content, this set of works include research articles, news, letters, and other writings published in more than 200 of the oldest leading academic journals. The works date from the mid--seventeenth to the early twentieth centuries. We encourage people to read and share the Early Journal Content openly and to tell others that this resource exists. People may post this content online or redistribute in any way for non--commercial purposes. Read more about Early Journal

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... ntent at http://about.jstor.org/participate--jstor/individuals/early-journal--content. JSTOR is a digital library of academic journals, books, and primary source objects. JSTOR helps people discover, use, and build upon a wide range of content through a powerful research and teaching platform, and preserves this content for future generations. JSTOR is part of ITHAKA, a not--for--profit organization that also includes Ithaka S+R and Portico. For more information about JSTOR, please contact support@jstor.org. RECELNT IMPORTANT DECISIONS RECELNT IMPORTANT DECISIONS porch, over the line, was a violation of the building restriction, and was really part of the building and not a porch. Brandenburg v. Lager, 272 Ill. 622. But even in Illinois they held that a projection in the nature of a bay window, built up solid from the ground, came within the exception of "bay windows." Keith v. Goldsmith, I94 Ill. 488. The true ground for these decisions, holding such structures as part of the building and not within the exception of porches, seems to be to carry out the intention of the parties, in reserving an easement to light, air and vision. Loomis v. Collins, 272 Ill. 221, and not to let mere architectural, technical phraseology defeat that intention. Marsh v. Marsh, 89 N. J. Eq. IIo. In the principal case the court relied on the technical phraseology and the expert evidence of architects in arriving at their decision, which accounts for its variance with the Illinois and New Jersey cases. See II ILL. L. Riv. 576 for a discussion of the Illinois cases on this point. FIRE-ACCIDENTAL-LIABILITY FOR.-P occupied rooms over a garage, part of which was let to D, who kept a motor car there. D's servant, an unskilled chauffeur, having occasion in the course of his employment to move the car started the engine, and without negligence on his part, and from some unexplained reason, the petrol in the carburetor caught fire and burned the car, the garage, and P's rooms and furniture. If the servant had promptly turned off the tap from the carburetor to the petfol tank, the fire would have done no harm; but he failed to do this. P sued for damages. The English statute of I774, substantially re-enacting 6 Anne; C. 31, S. 6, provided "No action shall be maintained against any person in whose building any fire shall accidentally begin, nor any recompense be made by such person for any damage suffered thereby, any law, usage or custom to the contrary notwithstanding." Held, this act did not apply and D was liable. Musgrave v. Pandelis [I919] 2 K. B. 43. The court argues that at common law one was liable for fire originating on his own property: (I) for its mere escape; (2) or if the fire was negligently or wilfully caused; or (3) on the principle of Rylands v. Fletcher (I868) L. R. 3 H. L. 330, that he has brought a non-natural and dangerous thing on his premises which gets away from him and does harm. The Statutes of Anne, and of I774, were to meet the liability under (I) above, and did not apply when the fire was caused either deliberately or negligently, under (2) above. Filliter v. Phippard, II Q. B. 347; if that is true as to (2) why should it affect liability under (3) the principle of which existed long before Rylands v. Fletcher was decided? The question then is, is a motor car with its petrol tank full or partially filled with petrol, a dangerous thing to bring into a garage, within the principle of Rylands v. Fletcher? Lush, J., in the trial court, and Bankes, Warrington, and Duke L. JJ. in the Court of Appeal, all agreed that it was. The question then is, Did the fire accidentally begin? The fire in the carburetor did accidentally begin; but it did not destroy the garage and the plaintiff's property. It would almost immediately have burned out without damage except for the negligence of D's servant. The fire that did the damage was the raging fire from the petrol tank; this did not accidentally