(a) Bleakley v. Smith, 11 Sim. 150, where note that the only question argued and determined was as to the sufficiency of the vendor's signature.

(b) Plant v. Bourne, C. A., reversing Byrne, J., 1897, 2 Ch.

281. In that case the quantity mentioned was all the land the vendor had there, and he had shown the purchaser over it just before the contract was signed. The C. A. admitted oral evidence of these facts on the ground that the description in the memorandum must be taken to mean the vendor's 24 acres or those so pointed out by him. Byrne, J., had excluded this evidence because the memorandum did not say so, though he would have admitted the evidence if the description had been the 24 acres, etc. Quaere, whether in principle the judgment of Byrne, J., were not sounder than those delivered in the Court of Appeal, where the Lords Justices appear to have adopted as the rule of law, not the decision in Ogilvie v. Foljambe

The memorandum required by the Statute of Frauds need not be contained in one document; it may be made out from several documents-, if they can be connected together. It was formerly laid down that, in order to connect two documents together so as to establish a sufficient memorandum to satisfy the Statute of Frauds, one must contain some reference to the other (c). But later cases have established a wider rule, which appears to be this: - You are entitled to explain by parol evidence the meaning of any general expression used in any document (d). If therefore you have a document, signed by a party to be charged, which refers to an agreement made by him, but in such terms that the description of the agreement is obviously incomplete, you are entitled to give evidence to show what that agreement is, and if the evidence so adduced comprise another document containing all the terms of the agreement, or the terms not specified in the first document, the two documents may be read together as a memorandum sufficient to satisfy the Statute, although Memorandum may be made out by several documents.

Rule as to connecting documents.

(3 Mer. 53), that "Mr. Ogilvie's house" was a description siini-ciently certain to allow of its being elucidated by parol evidence, but the dictum of Grant, M. R., that "the subject-matter of the agreement is left indeed to be ascertained by parol evidence, and for that purpose, such evidence may be received"; sec 1897, 2 Ch". 287, 289. This dictum was of course uttered purely with reference to ascertaining what house answered to the description of Mr. Ogilvie'e house, lint. surely, apart from this, it is not the law that a written memorandum of a contract is sufficient to satisfy the Statute of l'Yauds, although the subject-matter of the agreement is left to be ascertained by parol evidence . Bee oases cited above, pp. 4, n. (j), 5, n. (o). It is respectfully submitted thai the actual decision of the Court of Appeal may be supported on the ground that a sale of 24 acres of land at Totmonslow would be a valid sale of 24 acres of land to be selected by the purchaser out of the vendor's land there: Shepp. Touch. 251: Tapley v. Eaaleton, the evidence connecting them be parol evidence only (e). But if a signed document contain a reference to an agreement made by the signer in such terms that a complete agreement is described, and no explanation of the terms of the document is required on the face of it, the party seeking to charge the signer is not entitled to give parol evidence that the agreement is other than is described, although the signer may prove by parol evidence that the agreement described in the writing does not contain some term of the agreement into which he entered, and so avoid the contract under the Statute of Frauds (/'). To give examples: - Parol evidence has been admitted to connect a signed letter referring to an agreement to purchase land with an other document giving the terms of purchase (g); to connect a letter promising to "grant the extension of lease you solicit" with another letter showing the day on which the term granted by the lease was to expire (h); to show that the "instructions" to a solicitor referred to in a letter were a written memorandum containing fully the terms of the agreement sought to be enforced (i); to connect a letter containing a promise to grant a lease for fourteen years "at the rent and terms agreed upon" with another document in which such rent and terms were specified (k); and to show that the purchase referred to in a signed receipt for 31l. "as a deposit of the purchase" of certain land was an agreement for purchase of which the terms were contained in a memorandum signed by the purchaser (l). So if one write a letter saying, "I accept your offer," there is no doubt that this may be shown by parol evidence to refer to another letter previously received, in which the terms of the offer are fully stated, so that a complete contract in writing may be established by the two letters read together (m). Similarly, parol evidence has been admitted to connect a letter addressed "Dear Sir" only with the envelope in which it was enclosed, and on which the purchaser's name was written (n). On the other hand, memoranda of sales written in auctioneers' books in terms, which needed no explanation, have been held insufficient to satisfy the Statute, on the ground that they contained no reference to special conditions on which the sales were made (o).

12 Ch. D. 683; and that being so, it was competent to the vendor to prove that the purchaser had made his selection before the memorandum of the contract was signed: see Wylton v. Dunn, 34 ('I,. 1). 669.

(c) Ridaway v. Wharton, 3 D. M. & G. 677. 693-7, per Cran-worth, C, who changed his mind, S.C., 6 H. L. C. 238. 256: dis-senting judgment of Williams..J., N. Stafordshirt By. v. Peek, E. B & E. 986, 1000-3.

(d)Bainbridae v. Wade, 16 Q. B. 89.

(e) Ridgway v. Wharton, 6 H. L. C. 238; Baumann v. James, L. R. 3 Ch. 508; Long v. Millar, 4 C. P. D. 450; Shardlow v. Cot-terill, 20 Ch. D. 90; Studds v. Watson, 28 Ch. D. 305; Wylson v. Dunn, 34 Ch. D. 569, 574, 575; Oliver v. Hunting, 44 Ch. D. 205; Sheers v. Thimbleby, 13 Times L.R. 451.