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made to tho German debtor prior to the war. Under the agreement botwecn the parties this sum could bo repaid from the Ist July, 1916, at the rate of 2,003 marks yearly on the creditor giving three months' notice. In that case the Tribunal held that, notwithstanding the dissolution of the contract effected by Article 299 (a), the contract must continue to govern the repayment which had to take place ; that such dissolution had, without any notice from the creditor, made payable the debt according to tho terms of, and at the date when such debt was stipulated to be payable by, the contract itself ; accordingly, such instalments as beeamo due from the Ist October, 1916, to the Ist October, 1919, inclusive, were payable in sterling at tho pre-war rate under Article 296, but the remaining two instalments, which could not under tho contract have fallen due until 1920 and 1921, could not bo claimed through, tho Clearing Office. The Tribunal added, that this conclusion was not substantially in conflict with the decision in Kitzinger v. Dann (supra), in which case the only question at issue was the necessity of giving notice. In that ease, subject to the question of notice, the amounts were clearly due, and tho contract contained no terms as to payment at fixed dates, as in the case before them. (c.) Another analogous case involving an important point of principle was that of the British Clearing Office against the Gorman Clearing Office in the matter of Public Trustee v. Enders'sohe Erben. There the British creditor, acting as executor of a British national who died in 1915, claimed payment under Article 296 (2) at the sterling equivalent at pre-war rate of a loan of 20,000 marks granted before the war by the British national to certain German nationals upon mortgage of lauded property in Germany. Tho German Clearing Office contested the claim on the ground that the debt oxisted under a contract of mortgage which came within the exceptions mentioned in paragraph 2 (c) of tho annex to Section. V, Part X, of the Treaty, and was accordingly not dissolved at the outbreak of war, and that, as the necessary three months' notice to redeem had not been given, the sum had never become payable during the war. The British Clearing Office maintained that under German law there were two contracts —(1) a personal contract of loan, and (2) the contract of hypotheca or mortgage —and that tho former contract, which was distinct and separate from the other, must be considered as having been dissolved as from the outbreak of war, leaving only the pecuniary obligation to repay tho debt subsisting. The German Clearing Office contended that the debt was not separable from tho mortgage, and that the repayment of the loan would lead to the extinction of the mortgage contract contrary to paragraph 2 (c) of the above-mentioned annex. The Tribunal referred to the decision in the case of Gunn v. Gunz (supra) to the effect that Article 299 (a) of the Treaty applied to contracts of loan and superseded for such contracts notice required either by the contract or by domestic law. They considered that it lay in the very nature of the contract of mortgage that it was only accessory to and dependent on tho existence of the debt which was thereby guaranteed. If the dissolution of the contract of loan led to the total or partial repayment of the debt to the creditor, the effect of such repayment on the mortgage must bo determined according to the law which was applicable. They were, therefore, of opinion that tho contract of loan was to be considered as having been dissolved as from the time when tho parties became enemies, and that, accordingly, the amount of the loan became a debt payable during the war and eamo within Article 296 of tho Treaty. (2.) Disposal of Security deposited for Debt. Tho question as to the right of a British national to claim repayment of a debt from a German national under Article 296 in a ease where security had been deposited for the debt came before the Tribunal in the important case of tho British Clearing Office ?;. the German Clearing Office in tho matter of a claim by Win. Brandt, Sons, and Co. against Ludwig Tillmann (Recueil, I, p. 554). The German debtor did not contest the amount of the claim, but the Gorman Clearing Office contended that as security has been given to the creditor they would contest the claim until tho security was handed over. This the British Clearing Office refused to do, on the ground that, under paragraph 4 of the annex to Section IV, Part X, these securities were subjected to the charge imposed on the property of German nationals situated in British territory. They claimed that tho right of retention of the security under Article 297 (b) was an absolute and unqualified right; that no contrary stipulation excluding the security from the effect of Article 297 (6) could be found, but that, on the contrary, Article 296 (a) expressly provided, that tho debt must bo settled solely under the terms of that article, and that accordingly the British creditor was not entitled to realize the security and pay himself out of it. This the British Clearing Office argued involved no hardship upon the debtor, as he would, under Article 297 (/*), be entitled to a credit through the Clearing Office for the full value of the security. The Tribunal refused to adopt the contention, of the German Clearing Office that the effect of the Treaty was merely to constitute the German Government as a surety as regards the British Government, and decided that tho rights of the British Government under Articlo 297 could not be held to have been affected or limited in the way suggested, and that even if the implication of suretyship thus arose it would not affect Article 297 (b), which would override it. They therefore held that the German Clearing Office had no right to demand either the handing-over of the securities deposited by the German debtors with the British creditors as a condition of crediting the British Clearing Office with the full amount of the debt admitted by the debtor, or to demand that the debt should be reduced by tho amount of the proceeds or value of tho securities. (3.) Liability of Government for Payment of Debts established against its Nationals. Under Articlo 296 (b) of the Treaty the Governments of the respective countries are made responsible for the payment of enemy debts due by their nationals, except, inter alia, in cases where before the war the debtor was in a state of bankruptcy or failure or had. given formal indication of insolvency. The Tribunal had to consider the meaning of these words in the claim of Seligman v. Liebermann (Recueil, I, p. 730) for various amounts lent by the British creditor to the German debtor before the war, and also for certain further moneys which fell to be paid by the British creditor during the war for the debtor by virtue of a contract. The debtor had not apparently contested the claim, but the German Government intervened on the ground that at the date of outbreak of war the debtor was insolvent, and that therefore the Government guarantee specified in Article 296 (b) did not take effect. It was admitted that the debtor was not bankrupt before the war, although some evidence was called to show that he had for some time prior thereto been in embarrassed circumstances and owed more monoy that he was in a position to pay. The Tribunal did not consider that the debtor "was in a state of failure in the sense which they attached to that expression, and came to the conclusion that the Treaty had really contemplated an official statement of insolvency of tho debtor before the outbreak of war as a necessary condition for the exclusion of the Government guarantee. No such official statement of insolvency had in fact been made, and accordingly the Tribunal declared that tho guarantee of the German Government for the debt could not bo excluded. They further refused to admit an alternative claim put forward by the German Government that, on payment to the creditor of the sum awarded by the Tribunal, that Government should be entitled to receive from the creditor certain insurance policies which had been formerly assigned to the creditor by way of security. This point, they held, was covered by the former decision in the case of Brandt v. Tillman (supra). (4.) Compensation for British Goods seized by Germany. Turning to tho cases relating to exceptional war measures and liquidations, probably the most important of these docidod by the Tribunal up to the present time is that of McLeod, Russell, and Co.u. the German Government (Recueil, I, p. 547). This was a case in which the British claimants claimed a credit under Article 297 (7*) (1) and also compensation under Articlo 297 (e) in respect of tho requisition by the Gorman authorities of certain bales of juto warehoused in Hamburg at tho outbreak of war, the price for which had been assessed by the Roiehswirtschaftsgoricht. The jute had been requisitioned by the civil authorities at tho instanco of tho military, and the German Govemmont contended that the measure under which the requisition had boon made was of a general nature equally affecting the