APPENDIX OP CASES. 
197 
B. 
Eote to Friendly Societies Act, 1875, s. 13; Indus 
trial and Provident Societies Act, 1876, s. 9. 
By this section it is provided that no amendment of a 
Tule shall he valid until it has been registered. This is in 
conformity with the law as previously declared. 
In Battey v. Townrow, 4 Camp. 5, it was held that an 
action could not be maintained by the trustees of a friendly 
■society elected under new regulations agreed to by the 
members, but not confirmed according to the statute. Per 
Lord Ellenborough (Easter Term, 53 Geo. 3):—“The 
plaintiffs have no right to stand here, except by the Act of 
Parliament, and the Act of Parliament gives them no such 
right, unless they be lawfully elected to the office they fill; 
but it appears they were elected contrary to law. The 
section (33 Geo. 3, c. 54, s. 3) which permits an alteration 
of rules provides that such alteration shall be subject to 
the review of the justices, and shall have no force or effect 
until confirmed by them. I cannot look, therefore, at the 
rule altering the mode of electing the stewards. It is ad 
mitted that the plaintiffs were not elected according to the 
original rule; therefore they are not the legal trustees of 
the society for the time being, and the effects sought to be 
recovered never vested in them.” 
In Beg. v. Godolphin, 8 A. & E. 338, it appeared that cer 
tain alterations were made in the rules of a friendly society 
■established under the 33 Geo. 3, c. 54. The altered rules, 
however, were never enrolled, and it was held that the 
rules as altered could not legally be acted upon ; and in 
giving judgment Lord Denman said it would be well if it 
were generally understood that these societies cannot depart 
Lom their established rules, or neglect to comply with the 
statute in the mode of altering or repealing them without 
•exposing their property to danger, and themselves to great 
expense, loss, and inconvenience. A doubt was also enter 
tained as to whether the original rules continued in force 
even for the purpose of holding the society legal under 
the statute, in consequence of the case of Ex parte Norrish, 
Jac. 162. 
In the case of Beg. v. Gotton, 15 Q. B. 569 ; 19 L. J. 
(n.s.) Q. B. 233, where the rules had been approved accord-