The sexual struggle in the animal kingdom is not always of a violent kind. As Mr. Darwin has pointed out, males often try by peaceful emulation to charm the female. In many species of birds the male seems to endeavour to gain his bride by displaying his colours and ornaments before her, or exciting her by his love-notes, songs, and antics. But among the lower Mammals he wins her, apparently, much more through the law of battle than through the display of his charms.[958] There can scarcely be any doubt that the same was the case with primitive men; but we need not mount many steps of human progress to find that courtship involves something more than a mere act of strength or courage on the part of the male. It is not only in civilized countries that it often means a prolonged making of love to the woman. Mariner’s words with reference to the women of Tonga hold true for a great many, not to say all, savage and barbarous races now existing. “It must not be supposed,” he says, “that these women are always easily won; the greatest attentions and most fervent solicitations are sometimes requisite, even though there be no other lover in the way. This happens sometimes from a spirit of coquetry, at other times from a dislike to the party, &c.”[959] Though generally playing the less active part in courtship, the woman does not by any means indulge in complete passivity. Mr. Hooper tells us that, among the Indians at James’s Bay, “two young Indian women were observed some years ago in violent conflict.... After a lengthened and determined struggle the weakest succumbed to the superior prowess of her fortunate adversary. It appeared that these girls were in love with the same man, and had self-instituted this mode of deciding their claims.”[960] Among the Wintun of California, according to Mr. Powers, when any man other than a chief attempts to introduce into his wigwam a second partner of his bosom, the two women dispute for the supremacy, often in a desperate pitched battle with sharp stones; “they maul each other’s faces with savage violence, and if one is knocked down her friends assist her to regain her feet, and the brutal combat is renewed until one or the other is driven from the wigwam.”[961] Peltier states that, in the Australian tribe already referred to, the women, of whom from two to five commonly belong to each man, fight among themselves about him, “their weapons being heavy staves, with which they beat one another about the head till the blood flows.”[962] In the Kingsmill Islands, women sometimes, from jealousy, carry a small weapon, watching an opportunity of making an attack upon their rivals, desperate fights being the consequence;[963] and, among the Kamchadales also, the females are said to have fought for the males.[964] But far more commonly women try to secure men’s love by coquetry or the display of their charms. Finally, whilst the men are generally the courters, the