Public Health Act 1875 vested the powers and duties of surveyors of highways and vestries in urban authorities, while the Local Government Act 1894 transferred to the district councils of every rural district all the powers of rural sanitary authorities and highway authorities (see ENGLAND: _Local Government_). The Highway Act of 1835 specified as offences for which the driver of a carriage on the public highway might be punished by a fine, in addition to any civil action that might be brought against him--riding upon the cart, or upon any horse drawing it, and not having some other person to guide it, unless there be some person driving it; negligence causing damage to person or goods being conveyed on the highway; quitting his cart, or leaving control of the horses, or leaving the cart so as to be an obstruction on the highway; not having the owner's name painted up; refusing to give the same; and not keeping on the left or near side of the road, when meeting any other carriage or horse. This rule does not apply in the case of a carriage meeting a foot-passenger, but a driver is bound to use due care to avoid driving against any person crossing the highway on foot. At the same time a passenger crossing the highway is also bound to use due care in avoiding vehicles, and the mere fact of a driver being on the wrong side of the road would not be evidence of negligence in such a case. The "rule of the road" given above is peculiar to the United Kingdom. Cooley's treatise on the _American Law of Torts_ states that "the custom of the country, in some states enacted into statute law, requires that when teams approach and are about to pass on the highway, each shall keep to the right of the centre of the travelled portion of the road." This also appears to be the general rule on the continent of Europe.