As another illustration of the disappearance of certain forms of corruption once extremely common the famous case of Lord Bacon may be cited. His offence as Lord Chancellor consisted not in the taking of presents from suitors, for to do so after judgment was the open practice of the time. Inadvertently, however, Bacon accepted a present before a case was decided, and this was made the basis of the charge of corruption which brought about his downfall. The morality of the time had reached a stage at which it perceived clearly the corrupting effect upon the judicial mind of presents in advance of a decision, and held them to be bribes. It had not reached the modern point of view that the expectation of a present after giving decision is also corrupting, particularly since the present of one of the litigants is very likely to be larger than that of the other. One can safely maintain that the open receipt of presents by judicial officers of higher rank is extremely rare in English speaking countries and in Western Europe at the present time. Judges of our own lower courts are sometimes accused of truckling to the party influences to which they owe their election, but so far as it exists this is a much more subtle and surreptitious form of corruption than present giving, or as it would frankly be called nowadays, bribe-giving by litigants.[26] Any approach, or even appearance of approach, to offences of the latter sort would call forth sharp expressions of condemnation. In his “Four Aspects of Civic Duty,” President Taft presents a very striking and acute argument on the necessity of the exercise of extreme circumspection by judicial officials which will serve to illustrate the progress in morals from Lord Bacon’s time to the present: “A most important principle in the success of a judicial system and procedure is that the administration of justice should seem to the public and the litigants to be impartial and righteous, as well as that it should actually be so. Continued lack of public confidence in the courts will sap their foundations. A careful and conscientious judge will, therefore, strive to avoid every appearance from which the always suspicious litigants may suspect an undue leaning toward the other side. He will give patient hearing to counsel for each party, and, however clear the case may be to him when stated, he will not betray his conclusion until he has heard in full from the party whose position cannot be supported. More than this, it not infrequently happens, however clear his mind in the outset, that argument, if he has not a pride of first opinion that is unjudicial, may lead him to change his view.