is either positively ascertained that the latter
performs the duties of incubation, or there are good reasons for
believing such to be the case. The most satisfactory example is that of
the Gray Phalarope (Phalaropus fulicarius), the sexes of which are alike
in winter, while in summer the female instead of the male takes on a gay
and conspicuous nuptial plumage; but the male performs the duties of
incubation, sitting upon the eggs, which are laid upon the bare ground.

In the Dotterell (Eudromias morinellus) the female is larger and more
brightly coloured than the male; and here, also, it is almost certain
that the latter sits upon the eggs. The Turnices of India also, have the
female larger and often more brightly coloured; and Mr. Jerdon states,
in his "Birds of India," that the natives report, that, during the
breeding season, the females desert their eggs and associate in flocks,
while the males are employed in hatching the eggs. In the few other
cases in which the females are more brightly coloured, the habits are
not accurately known. The case of the Ostriches and Emeus will occur to
many as a difficulty, for here the male incubates, but is not less
conspicuous than the female; but there are two reasons why the case does
not apply;--the birds are too large to derive any safety from
concealment, from enemies which would devour the eggs they can defend
themselves by force, while to escape from their personal foes they trust
to speed.

We find, therefore, that a very large mass of facts relating to the
sexual colouration and the mode of nidification of birds, including some
of the most extraordinary anomalies to be found in their natural
history, can be shown to have an interdependent relation to each other,
on the simple principle of the need of greater protection to that parent
which performs the duties of incubation. Considering the very imperfect
knowledge we possess of the habits of most extra-European birds, the
exceptions to the prevalent rule are few, and generally occur in
isolated species or in small groups; while several apparent exceptions
can be shown to be really confirmations of the law.

_Real or apparent Exceptions to the Law stated at page 240._

The only marked exceptions I have been able to discover are the
following:--

1. King crows (Dicrourus). These birds are of a glossy black colour with
long forked tails. The sexes present no difference, and they build open
nests. This apparent excep