ic office,
or act as a stockbroker, or sit on a jury. _Banqueroute simple_ is where
the bankrupt has been guilty of grave faults in the conduct of his
business, such as extravagance in living, hazardous speculation or
preferring creditors. _Banqueroute frauduleuse_ involves the worse
delinquency of fraud. Both _banqueroute simple_ and _banqueroute
frauduleuse_ are punishable,--the latter with penal servitude ranging from
five to twenty years.

_Germany._--Bankruptcy in Germany is governed by a code passed in 1877.
Prior to this each state had its system and the law was "wholly chaotic."
The same distinction is drawn in Germany as in France between mere
commercial failure and bankruptcy, simple or fraudulent. Simple bankruptcy
is established by such offences as gambling, dealing in "futures,"
disorderly book-keeping or extravagance in living: fraudulent bankruptcy,
by offences of a deeper dye--the concealment of property, the falsifying of
books, the manufacture of fictitious debts and the giving of illegal
preferences. Both kinds of bankruptcy are punishable, fraudulent bankruptcy
by penal servitude, or in case of mitigating circumstances, by imprisonment
for not less than three months. Accessories in fraudulent bankruptcies are
liable to penal servitude--for instance, a creditor who conspires with the
debtor to secure an advantage to the prejudice of the other debtors. The
creditors are called together within one month from the date of
adjudication, and at their meeting they may appoint a committee of their
number to advise with the trustee. It is the duty of the court to see that
the trustee performs his functions. Estates are liquidated with great
rapidity. In order that the creditors may receive dividends at the earliest
moment, it is customary to sell the assets by auction. The creditors by a
majority in number and three-fourths in value may accept a composition, but
such an arrangement must have the approval of the court. The fees are very
moderate: in an ordinary bankruptcy the attorney's fees do not, it is said,
exceed L5.

_Italy._--Bankruptcy in Italy is regulated by the Commercial Code of 1883
(Part III.). Only merchants can pass through the bankruptcy court.
Merchants are defined by the code as those who, as an habitual profession,
engage in commercial business. This definition includes merchant companies.
Bankruptcy proceedings may be taken either by the debtor or by a creditor
for a _commercial_ debt, or