In the afternoon Professor Benedikt presided, and M. Van Hamel read his report on the “Cellular System from the point of view of Biology and of Criminal Sociology.” He concluded that there should be a very careful selection of cases for cellular isolation, subject to psychical and medical examination. The results depended quite as much on the treatment adopted during the cellular confinement as on the confinement itself. On the proposition of M. Garofalo a commission was appointed to carry on a series of observations on 100 criminals and 100 honest persons whose antecedents were perfectly well known. On the proposition of M. Semal, the Congress affirmed the necessity of a psycho-moral examination of the prisoner as a preliminary to conditional liberation. It was resolved also that it is desirable that law students should be instructed and examined in legal medicine; and, on the proposition of M. Eschenauer, that the direction and instruction of young children in reformatories should be confided to experienced women. In his closing discourse Professor Brouardel remarked how various and complex are the issues raised by criminal anthropology. They were dealing with one of the most interesting and profound of all problems--a problem which had in all ages exercised the human mind. The Congress had brought together some of the materials for a future edifice, although they were not yet able to raise it. The _Archives de l’Anthropologie Criminelle_ was the official journal of the Congress, and the number for September 1889 was entirely devoted to its proceedings. The next Congress will be held at Brussels in 1892. APPENDIX C. _The International Association of Penal Law._ This association was founded in 1889 on the initiative of Professor von Liszt. Its success was immediate, especially among lawyers, professors of law, and magistrates; and this success is a remarkable proof of the great movement for penal reform which is now everywhere making itself felt. Nearly twenty countries in Europe and America are represented by the association. It is truly international; no attempt is made to discuss national modifications, or to advocate the doctrine of any school. The conditions of membership involve adhesion to the following propositions:-- I.--The mission of penal law is to combat criminality regarded as a social phenomenon. II.--Penal science and penal legislation must therefore take into consideration the results of anthropological and sociological studies. III.--Punishment is one of the most efficacious means which the state can use against criminality. It is not the only means. It must not, then, be isolated from other social remedies, and, especially, it must not lead to the neglect of preventive measures. IV.--The distinction between accidental criminals and habitual criminals is essential in practice as well as in theory; it must be the foundation of penal law.