_Id._... It will not be forgotten that, in more than one of the older civilisations, the father had the power of life and death over the members of the family, even past adult age. And, to come to quite recent times, and this our England, Mrs. Wolstenholme Elmy, to whose unflagging energy, during some fifteen years of labour, was mainly attributable (as the Parliamentary sponsors of the measures know) the amelioration in the English law concerning wives and mothers, embodied in the Married Women’s Property Acts of 1870 and 1882, together with the later and beneficent Guardianship of Infants Act, 1886, relates, in her record of the history of this latter Act:— “It will be remembered that so recently as 1883, a young lady petitioned that she might be allowed to spend her summer holidays with her own mother, from whom she was separated for no fault of her own or of her mother’s, but in virtue of the supreme legal rights of her father. The Court refused her petition, natural and proper as it seems to everyone of human feelings; and the words of the Master of the Rolls in giving judgment, on the 24th of July, 1883, are more significant and instructive as to the actual state of the law than the words of any non-professional writer can be:—‘The law of England _recognises the rights of the father_, not as the guardian, but _because he is the father of his children_.... _The rights of the father are recognised because he is the father_; his duties as a father are recognised because they are natural duties. The natural duties of a father are to treat his children with the utmost affection, and with infinite tenderness.... The law recognises these duties, from which if a father breaks he breaks from everything which nature calls upon him to do; and, although the law may not be able to insist upon their performance, it is because the law recognises them, and knows that in almost every case the natural feelings of a father will prevail. The law trusts that the father will perform his natural duties, and does not, and, indeed, cannot, inquire how they have been performed.... I am not prepared to say whether _when the child is a ward of Court, and the conduct of the father is such as to exhaust all patience—such, for instance, as cruelty, or pitiless spitefulness carried to a great extent—the Court might not interfere. But such interference will be exercised_ ONLY IN THE UTMOST NEED, AND IN MOST EXTREME CASES. It is impossible to lay down the rule of the Court more clearly than has been done by Vice-Chancellor Bacon in the recent case of “_Re._ Plowley” (47 “L.T.,” N.S., 283). In saying that this Court, “whatever be its authority or jurisdiction, _has no authority to interfere with the sacred right of a father over his own children_,” the learned Vice-Chancellor has summed up all that I intended to say. _The rights of a father are sacred rights, because his duties are sacred._...’