28 JULY 1923, Page 19

PERIODICALS.

Law Quarterly Review.

Attention may be directed to an article by an American lawyer, Mr. Raymond G. Brown, of New York, on " Pro- hibition on the High Seas," which is designed to show, from a careful examination of the Eighteenth Amendment and of American case-law, that Congress in the Volstead Act of 1919 and the Supplementary Act of 1921 may have exceeded its powers under the Amendment in forbidding foreign ships to carry liquor under seal within American waters. " When- ever the municipal authorities, under colour of execution, legislation or judicial sanction, do violate international rights, then there is a foundation for damages, because municipal law cannot change International Law, even if it immunizes from local interference." Mr. Brown cites the ` Creole' case of 1853, in which the British owners were cast in damages for violating international law though they had not infringed,. the American law. It would seem, then, that the difficulty may yet be solved by appropriate action on the part of the Federal authorities, whether executive, legislative or judicial.