Although by Common Law imprisonment only involves deprivation of liberty, yet by a series of statutes extending from the middle of the eighteenth century to the present day, the nature and methods of imprisonment have undergone successive modification. These I propose to trace shortly, so that the present system of imprisonment, in its two principal forms--"with," and "without hard labour"--may be understood. There is probably no legal phrase so imperfectly understood, or which in its application has been so embarrassing to the administration, or which has to a greater extent misled the Courts of law in assigning punishment, as the phrase "hard labour." By its comparison with the French "_travaux forcés_" it has created an impression in foreign countries that it is a very severe penalty, applied only for the greatest crimes; at home it obscures the principle that in prison all labour is hard, _i.e._, that all prisoners are punished with an equal prescribed task, whether they be sentenced to imprisonment with or without hard labour: and in penal servitude, where the manual labour is of the hardest, the phrase has no legal existence. The reform of the English Prison System originated towards the end of the eighteenth century with the public exposure made by the great Howard on the deplorable condition of our gaols, and his statue in St. Paul's Cathedral fitly commemorates the gratitude of his country for the services he rendered to humanity. The story of his life is well known: how, being seized by a French privateer on his way to Lisbon in 1755, he was thrown into a dungeon at Brest, and so had personal experience of the horrors of imprisonment: how in 1773 the duties of his office as High Sheriff of the County of Bedford led him to inquire into the state of Prisons in England and Wales: how in 1774 he was examined by the House of Commons on the subject, and had the honour of receiving the thanks of that Body: how he devoted his later life to the inspection of prisons at home and abroad until his celebrated work on the "State of Prisons," published modestly at his own expense in a provincial town, awakened the public conscience to all the horrors of imprisonment; how, owing to his influence, not only statesmen, lawyers, and philosophers, but all the uninstructed public opinion of the day, now, for the first time, began to realize that the whole penal system was a scandal and a disgrace.