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than £IOO upon credit. This seems to be the first statutory reference to credit betting which has become such a burning question during the last century. With respect to such cases it was enacted that the losers should not be compelled to pay the sum lost and that the winner was liable to forfeit to any one suing him within the year three times the excess of the winnings over the sum of £IOO, half to go to the King and the other half to the prosecutor. As Lord Justice Fletcher Moulton comments in Moulis v. Owen [supra), " This state of things continued until the Act of 9 Anne, c. 14." This Act made a very great change in the law as regards gaming and gaming contracts. At the date of its passing it was perfectly legal to play for ready money to any amount, and the winner could keep the winnings. A loser might also lose to the limit of £IOO on credit and still be liable to have his debts enforced against him by action at law. If, however, the losses on credit exceeded £IOO no portion was recoverable by process of law, and the winner was liable to serious penalties. 18. The statute of Anne made a radical change. Although it purported, as to its incidence, to be limited to the prevention of " excessive and deceitful gaming/' it enacted that if a person should lose £lO or upwards at any one time or sitting and should pay his losings he could recover them from the winner by action if the action were brought within three months, and that if he did not do so any other person could thereafter obtain them by action against the winner, and the amount recovered was to go as to one-half to the person suing, and as to the other half to the use of the poor of the parish where the offence was committed. The Act contained other stringent enactments against cheating and professional gamblers. Incidentally, it also declared void " all notes, bills, bonds, judgments, mortgages, or other securities or conveyances for gaming consideration or for the reimbursement of any money knowingly lent or advanced for such gaming or betting as aforesaid." 19. Then followed several statutes passed over an extended period by which additional games were declared unlawful. One of these statutes, 18 Geo. 11, c. 34, added " roulet " \sic\ to the list of forbidden games and strengthened the law against gaming in various ways. It included a provision that any one who won or lost at play or betting at any one time the sum or value of £lO should be liable to prosecution. Then came the Act of 5 and 6 Will. IV, c. 41, which is commonly known as the Gaming Act, 1835. It qualified the effect imposed by 9 Anne, c. 14, on securities given for gaming debts. While such securities were declared void, an innocent holder for value of a note given for a gaming consideration could not recover upon it. This, in practice, was found to be provocative of injustice and, accordingly, the Gaming Act of 1835 provided that notes, bills, and mortgages which by the statute of Anne would be rendered void by reason of their having been given for a gaming consideration