85. Permissive registration, meaning that the adoption of registration would be discretionary in the local authority. The adoptive principle is of course widely followed in local legislation and has already been used in regard to charities in the case of street collections. Its inherent weakness is that it leaves the way open to the same subject being treated differently in adjoining areas and thus much of the moral effect is lost. Apart from this abstract objection, however, we feel that there are practical reasons against a system of permissive registration for charities. Charities which had reason to fear supervision would obviously establish themselve in non-registering areas which would consequently become the very areas in which supervision was most needed. Moreover, it would be quite impossible to prevent unregistered charities from making appeals outside those areas without, for example, restraining them from advertising in newspapers with a general circulation. It may be said that one advantage would be that no authority would be called upon to make a show of administering a scheme with which it was out of sympathy and that the general standard of administration among the adopting authorities would therefore probably be high. But however valuable this might be, it does not, in our opinion, outweigh the manifest attendant disadvantages of such a system.

86. It may, of course, be urged that in time non-registering areas would be forced into line. Experience shows that this result is not always produced and the existence of even one non-conforming area would be a source of continued danger. Though the idea may have for some attractions which are not to be found in other systems we feel no hesitation in concluding that it is not one that should be adopted.

87. So far, then, our general conclusion is that universal compulsory registration closely co-ordinated and accompanied by systematic supervision, is the only form of control which could usefully be applied to collecting charities in general.

EXTENT OF FRAUD AND MISMANAGEMENT.

88. We have now to consider the extent of evil and abuse in connection with charity. The difficulty of arriving at any estimate of the number of charities with which we are concerned has already been mentioned; the task of establishing the number of fraudulent or badly-managed charities is even more difficult. Experienced witnesses have placed before us examples of such charities, but none has ventured on an estimate of their number, and we have found it quite impossible to arrive at any estimate at all of the amount of money which is improperly collected or expended. Before considering this further it will be convenient to give by way of example a few of the cases which have been brought to our notice, and we cannot do better than to select those which were put in by Mr. Price of the Charity Organisation Society. Mr. Price's experience is acknowledged to be un

rivalled in this class of work and covers a generally wider field than that of any other witness who gave evidence before us.

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(a) A small society with a pretentious title was founded in a poor London district by a man who had retired from a position in the public service on a pension of 20s. a week. In a very short time he had placed over 10,000 collecting boxes in restaurants and public houses in London and other towns. Six women are regularly employed to clear the boxes at 188. a week or 2s. 6d. a day and travelling expenses. As the collectors are authorised to take their expenses out of the money cleared from the boxes, there is an obvious temptation to dishonesty. The collecting is on such a wide scale that it has been found necessary to establish branch offices in Bristol and Manchester. No proper accounts are published.

(b) House-to-house collections were recently made in Leicester for a British Dockers' and Seamen's Society in Rotherhithe and a Seamen's Mission with various addresses in Dockland. The former proved to have no existence, and its founder, who had been falsely posing as Rector of a parish in Devon, was eventually sentenced to two months' imprisonment on a charge of giving false information to the Registrar of Births regarding his own illegitimate child.

(c) A Seamen's Mission was started by a man who had been discharged from the post of collector in another society. He printed on his prospectuses the addresses of several missions and societies as though they were branches of his own. A few meals and addresses were given, but the principle occupation of the founder and two associates was the collection of funds to pay themselves £5 a week each.

(d) A Day Nursery was started in Stepney in 1885 by A. B., a native of Cape Colony, who had had a short and unsatisfactory career in connection with a a well-known religious mission in London. The charitable provision was of very low standard and intermittent, but for nearly forty years it furnished an excuse for an active campaign of collection by circular and personal canvassing. In order to reinforce his appeals, the founder assumed the title of Bishop and the degree of Doctor of Divinity, and a good many educated people in the West End appear to have had no difficulty in accepting his claims, and one of them left a substantial reversionary legacy to the institution. charity collapsed in 1923, and in April, 1925, Mr. Justice Coleridge made an order for the administration of the legacy when it matures or the cy-près principle.

The

(e) B. C. had organised collections for two blind societies. neither of which had any actual existence, though one of them had been officially registered as a "Friendly Society." He was convicted and fined £10. Three months later he

pleaded guilty to a similar charge at the sessions, and was sentenced to six months' imprisonment with hard labour. The evidence showed that the collectors were paid 50 per cent. of their takings, while the principal took £1 a week as salary in addition to another 25 per cent. of the money collected, and there were other deductions.

The passing of the Blind Persons Act in 1920, with its provision that blind charities must be registered, interrupted B. C.'s career. But he is busy again to-day begging for shadowy charities for the sighted, where no registration is required. The case is well known to the police.

(f) C. D., who was formerly employed by B. C. in connection with several of his charities for the blind, started one on his own account. It failed to obtain registration and the balance at the bank was estreated by the Charity Commissioners under the powers conferred upon them by the Blind Persons Act. Thereupon C. D. converted his office and staff into a Branch of a Society and Institute which was registered as a war charity by an extra-Metropolitan Urban District Council. This charity in its turn was removed from the register. C. D. then started a Blind Relief Society, registering it as a Benevolent Society under the Friendly Societies Act. As soon as the fact was brought to the notice of the authorities they took action and the society came to an end. It has been succeeded by another society which is outside the scope of registration authorities."

Fraud.

89. A glance at these cases, which were placed before us at an early stage of our enquiry, will show that each one of them is the work of some rogue who has set out to defraud the charitable public, in most instances over a long period of time. We found, however, that when other witnesses produced similar lists of cases the same people and organisations appeared again and again. B. C. is perhaps the most notorious of all the persons who engage in this occupation, and it was not surprising, therefore, to find that nearly every witness experienced in this particular side of the question had heard of and quoted him. But when we came to view the cases as a whole we were forced to the conclusion that the number of known persons who habitually prey upon the public in this way is very small indeed. Mr. Price felt unable to give an estimate of the number, and would not commit himself without detailed investigation to a figure higher than a hundred. It may, of course, be said that the very danger of these people lies in their being, at least to some extent, unknown, and that the known cases are only an indication of what is beneath the surface. But if this view is to carry weight it must be based on something better than surmise. Apart from the fact that our enquiries in different parts of the country covering the last ten years showed surprisingly few cases of known fraud which had not already been

quoted by witnesses who gave evidence before us, we found that the number of cases where there was even slight reason for suspecting it was even fewer. It is difficult to believe that any large number of undesirables can, over a long period, entirely hide themselves both from the police and from the Charity Organisation Society, and even if the tentative figure of a hundred is doubled, it still remains an exceedingly-almost insignificantly -small proportion of the whole.

90. It is plainly impossible even to guess at the amount of money which is either collected or expended fraudulently, but we have heard nothing to suggest that it is really substantial. It is true that in one well-known case of a ballot nearly £13,000 was collected and the whole of that sum frittered away, but there was good reason for doubt whether the promoters had any settled fraudulent intention. We can only say that we are not satisfied, on the evidence placed before us, that the sums purjoined from the public in this way form anything but a very small part of the total amount given in charity.

Maladministration.

91. We have found it very difficult to obtain concrete instances of mismanagement where no question whatever of fraudulent intent arises, partly perhaps because such cases do not readily come to light and even more because mismanagement is so often the unconscious preliminary to fraud. We have heard of several cases, particularly in connection with the War Charities Act, where inefficiency produced muddle which eventually became so gross that in the later stage a fraudulent element was certainly present, and we are inclined, indeed, to doubt whether gross mismanagement can ever be carried on continuously in completely good faith. The payment of extravagant salaries and commission, misleading or unnecessarily expensive advertising, and lack of discrimination in administering funds have been put to us in general terms as examples of minor mismanagement, but the evidence produced before us did not suggest that these faults are particularly widespread.

92. We are satisfied that apart from the comparatively few persons who engage in charitable work solely for their own profit, the great majority of charities are conducted by people who conscientiously carry out their work to the best of their abilities, and exercise reasonable care and prudence. On the other hand we do not in the least doubt that, judged perhaps by the highest standard, there is room for improvement in many cases, but since men and women are concerned, there would still be room for improvement no matter how far-reaching a system of supervision were imposed or however exacting its details. We believe that much good is already being done by the voluntary societies we have mentioned, and that their work would be facilitated and improved if some course such as that suggested later in this

report were adopted for putting an end to really bad charities. 93. Royal Commission on the Poor Law.-One other aspect of the question requires notice. The Report of the Royal Commission of 1909 on the Poor Law contained among its many recommendations a suggestion that a register of charities and of persons receiving both charitable and poor law relief should be compiled. It will be remembered that the Commissioners strongly urged close co-ordination between all forms of relief, and the preparation of a register was one of the suggested means of bringing this about. Their standpoint was, of course, entirely different from our own, and while giving their opinion due weight, we do not think it affords an argument for registration in the light in which we have to view it.

GENERAL CONCLUSION.

94. What we have to consider then is whether the extent of evil and abuse in connection with charity demands the setting up of a system of general supervision in the public interest, or whether, apart from abuse, supervision would be justified on other grounds. After very carefully considering the evidence before us we have arrived at the following conclusions:

95. We consider that a close and uniform supervision is the only form of supervision which could usefully be applied to charities generally, and even then we are doubtful whether it would bring about any real improvement of administration as distinct from the prevention or detection of fraud. Such a system would necessitate the erection of extensive administrative. machinery and might in practice involve an interference with charitable work of a character and extent which public opinion would not endorse. It could therefore be justified only if it is shown to be not only desirable but absolutely necessary in the public interest.

96. We see no ground for doubting that the great majority of charities are managed not only honestly but with reasonable prudence, and that such dishonesty as does exist is due mainly to the recurring operations of a few people, either known or suspected to be fraudulent, whose gains, in all probability, amount only to a very small part of the vast sums which are given for charity. It is our considered opinion that the demand for supervision, such as it is, does in fact rest almost entirely upon these persons' activities.

97. It seems to us important to remember that no system of control or punishment, whether in connection with charity or otherwise, can entirely prevent abuse or dishonesty. So long as illicit gains are to be had-even with difficulty-there will always be somebody who is willing to run the risk of getting them. This obvious truth does not always seem to be present in the minds of those who advocate the control of charities: they have some