disposition of the testator, as if it had been deposited in his own drawer. It must be inferred that the testator meant to pass it by one of the two descriptions which he has used. In no sense was it money on security, and in a reasonable sense it was money in hand, and passed therefore to the wife"

So, in Taylor v. Taylor (1 Jurist., 401), where the testator bequeathed all his ready money, Lord LANGDALE said "It is true that in strict legal language, what is called money deposited at a banker's is nothing more than a debt, and cannot be called ready money, but in the ordinary language of mankind money at a banker's is called ready money, and we must construe a will according to the ordinary language of mankind"

Again in Parker v. Marchant (1 Y. & C., 290), BRUCE, V. C., said "Undoubtedly an ordinary balance in a banker's hands is, in a sense, a debt due from him-certainly he may be sued for it as a debt. But it may be equally true that in a sense it is ready The term debt,' however technically correct, money. is not colloquially, or familiarly applied to a balance at a banking house. No man talks of his banker in that character being indebted to him. Men speaking of such a subject say that they have so much at their banker's, or so much in their banker's hands, a mode of expression indicating virtual possession, rather than that right to which the law applies the term chose-in-action. Agreeing that the term (ready money) is applicable to money in the purse, or the house, I cannot agree that it is confined to money so placed. Money paid into a banking house, in the ordinary mode, is so paid for the purpose of being not safe merely, but ready as well as safe." And, consequently, the V. C. held that a Bank Credit, or deposit passed under the term "ready money." And this opinion was confirmed on appeal (1 Phil., 356) by Lord LYNDHURST "Nobody can doubt that in the ordinary use of language, money at a banker's would be considered as 'ready money.' Everybody speaks of the sum which he has at his banker's as money: my money at my banker's' is a usual mode of expression. And if it is money at the banker's, it is emphatically ready money, because it is placed there for the purpose of being ready when occasion requires: it is received upon the understanding that it shall be so ready. If a man goes to his banker, the money is counted out to him on the table. If

he sends an order for the money, it is counted out to his servant, or the person in whose favour that order is made. I consider, therefore, that it is strictly 'ready money' according to the ordinary acceptation of those terms among mankind”

So again in Manning v. Purcell (2 Sm. & Giff., 284), the question was whether a balance on a current account, and a balance on a deposit account payable on demand, passed under the word moneys in a will, STUART, V. C., said-"The question as to the next subject of gift which the plaintiffs deny to be included in the gift of moneys,' is as to the balances of the testator at his banker's. The testator seems to have had balances upon a current account, and balances upon a deposit account. Now, the balance upon the current account certainly passed. It is also my opinion that the money, the evidence of which was the deposit notes, also passed under the description of moneys. It has been maintained in argument, that the deposit notes are the vouchers given by the bankers with whom the deposits were made as security for money, and they have been likened to the case of money secured by a bond. It is said that the balance due is simply a debt, and the deposit note is evidence of the debt, just as a bond, which shews a debt, and binds the obligor to the payment of it. But moneys deposited by a testator with his bankers, on a deposit account, the balance carrying interest, is so much money at the disposal of the testator, and is as readily accessible by him as moneys in an ordinary current account. The fact that interest is allowed upon these deposits, is a reason for the depositor more reluctantly drawing upon his deposit account; but in point of fact, there is no distinction at all shewn to me upon the custom of the bankers. The bankers have been examined in this case, and the habit is so notorious on this, that it would not require evidence to shew that where a banker holds money for which he gives a deposit note, it is just as accessible to his customer as if it was held on a current

account

"If a customer having a balance of £10,000 at his banker's wants £1,000, he must take a piece of paper and deliver it to the bankers before the bankers would pay him the money which they hold for him. Now, with respect to the deposit money, the customer, if he wants that money, or any part of it, must bring the deposit receipt instead of an ordinary cheque; but that does not

make it less accessible to him than if the bankers held it liable to be paid on cheques. If the slightest doubt were cast upon the accessibility of a depositor's money which a banker holds on deposit receipts, it would soon put an end to the account altogether

"My decision proceeds upon this, that as to the deposit notes, as much as to the current account, the relation of banker and customer exists; that the bankers holding money of a customer, whether on a deposit account or a current account, unless there is some express contract to take it out of the ordinary case of deposit, holds it as money, and as money, so readily accessible to the customer on the relation of banker and customer, that it is held to pass under the description of money generally

8. The importance and the practical bearing of these investigations and decisions are evident. In modern times private bankers discontinued issuing notes, and merely created Credits in their customers' favour to be drawn against by Cheques. These Credits are in banking language termed Deposits. Now many persons seeing a material Bank Note, which is only a Right recorded on paper, are willing to admit that a Bank Note is cash. But, from the want of a little reflection, they feel a difficulty with regard to what they see as Deposits. They admit that a Bank Note is an "Issue," and "Currency," and "Circulation," but they fail to see that a Bank Credit is exactly in the same sense equally an "Issue," "Currency," and "Circulation"

When a banker, in exchange for money, or in exchange for the purchase of a Bill of Exchange, gives his Notes to his customer, he creates and Issues a Right of action against himself, which the customer may transfer to any one else. But also when a banker in exchange for money, or in Exchange for a Bill of Exchange, creates a Credit in his books in his customer's favour, he equally creates and "Issues" a Right of action against himself; and by delivering a cheque book to his customer he thereby engages to pay the Credit to any one else to whom his customer may transfer it. Either form of Credit, therefore, is equally the Issue of a Right of Action to the customer. He has exactly the same right to demand payment of his Credit from the banker,

and exactly the same right to transfer it to any one else, whether it be by Note or by Cheque

Unreflecting persons see only so many figures in a book; they are startled at hearing them called Wealth: but, in fact, these figures are only the evidence of so many transferable rights of action in the persons of the bankers' creditors. These rights are just as much "issued" and in "circulation" as if they were Notes. They are equally liabilities to pay on demand. No doubt it is usual in bank returns to distinguish between Notes and Credits; but suppose they were not so distinguished, but merely called liabilities, would not every one see that they stand on exactly the same footing? Would any one then make any difference between them?

Thus these Bank Credits, or Deposits, are a mass of Property, just like so much corn or timber; they are Pecunia, Bona, Res, Merx; they are now, though, of course, legally only debts, for all practical purposes the current coin of commerce: and the great medium of payment of the country and specie is now only used occasionally, and as a supplement to payments in Credits of different forms

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Nothing can be more unfortunate or misleading than the expression which is so frequently used that banking is only the Economy of Capital," and that the business of a banker is to borrow money from one set of persons and lend it to another set. Bankers, no doubt, do collect sums from a vast number of persons, but the peculiar essence of their business is, not to lend that money to other persons, but on the basis of this bullion to create a vast superstructure of Credit; to multiply their promises to pay many times: these Credits being payable on demand and performing all the functions of an equal amount of cash. Thus banking is not an Economy of Capital, but an increase of Capital; the business of banking is not to lend money, but to create Credit: and by means of the Clearing House these Credits are now transferred from one bank to another, just as easily as a Credit is transferred from one account to another in the same bank by means of a cheque. And all these Credits are in the ordinary language and practice of commerce exactly equal to so much cash or Currency

9. After the authoritative exposition we have given above of the real meaning of the word Currency, and the judicial decisions of what it includes, it is rather a work of supererogation to cite the opinions of lay writers. The controversies as to the meaning of Currency did not arise until Smith had been several years in his grave; but we think that no one who reads his work can form any doubt but that bills of exchange are necessarily included under his designation of paper money. The question, however, is extremely unimportant, and would take far too much space to examine thoroughly

The first occasion on which we have met the term Circulating Medium is in the debate on the Bank Restriction Act, 1797,* in which Mr. Fox said he wished that gentlemen, "instead of amusing themselves with new terms of Circulating Medium' and the like," which shews that it must then have been of very recent introduction. Mr. Pitt, in his reply, said "As so much has been said upon the nature of a Circulating Medium, he thought it necessary to notice that he did not for his own part take it to be of that empirical kind which had been generally described. It appeared to him to consist in anything that answered the great purposes of trade and commerce, whether in specie, paper, or any other term that might be used." It is quite evident, therefore, that bills of exchange, cheques, and bank credits would all be included under such a designation, because they all effect the circulation of merchandise

The first place in which we have met the doctrine that the word Currency, or Circulating Medium, is to be restricted to specie and Bank Notes only, is in a letter of Mr. Boyd, a well known financial agent, to Mr. Pitt. He says, p. 2-"By the words Means of Circulation,'Circulating Medium,' and 'Currency,' which are used almost as synonymous terms in this letter, I understand always ready money, whether consisting of Bank Notes or specie, in contradistinction to Bills of Exchange, Navy Bills, Exchequer Bills, or any other negotiable paper, which form no part of the circulating medium, as I have always understood the term. The latter is the circulator; the former are merely objects of circulation." But Mr. Boyd, in his preface, says-" But from the mere return of bank notes (without that of the balances on the books, * Parliamentary History of England, Vol. XXXIII., p. 340.