Egypt [mixed suits], 615, 616). The usual mode in England of enforcing liability under a guarantee is by action in the High Court or in the county court. It is also permissible for the creditor to obtain redress by means of a set-off or counter-claim, in an action brought against him by the surety. On the other hand, the surety may now, in any court in which the action on the guarantee is pending, avail himself of any set-off which may exist between the principal debtor and the creditor. Moreover, if one of several sureties for the same debt is sued by the creditor or his guarantee, he can, by means of a proceeding termed a third-party notice, claim contribution from his co-surety towards the common liability. Independent proof of the surety's liability under his guarantee must always be given at the trial; as the creditor cannot rely either on admissions made by the principal debtor, or on a judgment or award obtained against him (_Ex parte Young In re Kitchin_, 17 Ch. Div. 668). Should the surety become bankrupt either before or after default has been made by the principal debtor, the creditor will have to prove against his estate. This right of proof is now in England regulated by the 37th section of the Bankruptcy Act, 1883, which is most comprehensive in its terms. Rights of sureties. A person liable as a surety for another under a guarantee possesses various rights against him, against the person to whom the guarantee is given, and also against those who may have become co-sureties in respect of the same debt, default or miscarriage. As regards the surety's rights against the principal debtor, the latter may, where the guarantee was made with his consent but not otherwise (see _Hodgson_ v. _Shaw_, 3 Myl. & K. at p. 190), after he has made default, be compelled by the surety to exonerate him from liability by payment of the guaranteed debt (_per_ Sir W. Grant, M.R., in _Antrobus_ v. _Davidson_, 3 Meriv. 569, 579; _per_ Lindley, L.J., in _Johnston_ v. _Salvage Association_, 19 Q.B.D. 460, 461; and see _Wolmershausen_ v. _Gullick_, 1893, 2 Ch. 514). The moment, moreover, the surety has himself paid any portion of the guaranteed debt, he is entitled to rank as a creditor for the amount so paid, and to compel repayment thereof. In the event of the principal debtor's bankruptcy, the surety can in England, if the creditor has not already proved in respect of the guaranteed debt, prove against the bankrupt's estate, not only in respect of payments made before the bankruptcy of the principal debtor, but also, it seems, in respect of the contingent liability to pay under the guarantee (see _Ex parte Delmar re Herepath_, 1889, 38 W.R. 752), while if the creditor has already proved, the surety who has paid the guaranteed debt has a right to all dividends received by the creditor from the bankrupt in respect thereof, and to stand in the creditor's place as to future dividends.