Mr. Justice McReynolds
delivered the opinion of the Court.
In each of these causes the District Court, proceeding under the “Liquor Law Repeal and Enforcement Act” [221]*221of August 27, 1935 (c. 740, 49 Stat. 872, 878, Title 27 U. S. C. § 40a), mitigated the forfeiture of an automobile seized for unlawful transportation of distilled spirits upon, which the federal tax had not been paid. (One was seized December 3, 1936; the other, March 15, 1937.) The forfeiture was decreed in a proceeding based upon § 3450 R. S. (Title 26 U. S. C., § 1441). The Circuit Courts of Appeals rightly approved and their judgmehts must be affirmed.
The facts, undisputed, are essentially alike, in both causes. The points of law are the same. A statement based on Record No. 10 will suffice.
The Repeal Enforcement Act provides—
“Sec. 204. (a) Whenever, in any proceeding in court for the forfeiture, under the internal-revenue laws, of any vehicle or aircraft seized for a violation of the internal-revenue laws relating to liquors such forfeiture is decreed, the court shall have exclusive jurisdiction to remit or mitigate the forfeiture.
“(b) In any such proceeding the court shall not allow the claim of any claimant for remission or mitigation unless and until he proves (1) that he has an interest in such vehicle or aircraft, as owner or otherwise, which he acquired in good faith, (2) that he had at no time any knowledge or reason to believe that it was being or would be used in the violation of laws of the United States or of any State relating to liquor, and (3) if it appears that the interest asserted by the claimant arises out of or is in any way subject to any contract or agreement under which any person having a record or reputation for violating laws of the United States or of any State relating to liquor has a right with respect to such vehicle or aircraft, that, before such claimant acquired his interest, or such other person acquired his right under such contract or agreement, which ever occurred later, the claimant, his officer or agent, was informed in answer to his inquiry, at the [222]*222headquarters of the sheriff, chief of police, principal Federal internal-revenue officer engaged in the enforcement of the liquor laws, or other principal local or Federal law-enforcement officer of the locality in which such other person acquired his right under such contract or agreement,. of the locality in which such other person then resided, and of each locality in which the claimant has made any other inquiry as to the character or financial standing of such other person, that such other person had no such record or reputation.”
The following findings by the District Court, it is agreed, correctly set out “the facts in this case”—
The Ford automobile in question was sold-by the Greenville Auto Sales, Incorporated (the dealer) October 3, 1936, through its agent, Elrod, to Guy Walker, who in part payment exchanged an old car paid for by him, but registered in, his wife’s name. He was given terms for payment under a conditional sales contract, drawn by an agent of the dealer, in the name • of his brother, Paul Walker, who formally executed the agreement. Guy Walker had the conditional sales contract drawn and executed in the name of his brother in order to place the title' “where his wife could not reach it.” Paul Walker had -no interest in the transaction except to comply with his brother’s request. Guy Walker made the’ transaction with the dealer. He selected the car, made the agreement and handled the transaction himself. Paul Walker drove the ‘car from the dealer’s place of business. Guy Walker at the time, and for two or three weeks after the purchase, was living at his brother’s house. Only one payment was made on the conditional sales contract before the seizure, and that by Guy Walker to the dealer.
It was admitted that Guy Walker had a previous record and reputation for violating both state and federal laws relating to liquor. Paul Walker was convicted of violating the National Prohibition Act in 1929, and was duly [223]*223sentenced therefor, but his record and reputation since serving the sentence were good.
On the date when the sale was consummated the dealer submitted the contract to the Commercial Credit Company, the claimant here, who accepted by telephone, and subsequently on October 5th, in the usual course of business the dealer assigned the contract'to the claimant and received a check therefor.
The claimant before accepting assignment of the sales contraet made an investigation of Paul Walker by inquiring at the headquarters of the Sheriff of Greenville County, and at the headquarters of the Chief of Police of Greenville, the County and City where the interest was acquired and the locality where Paul Walker resided, as to his record and reputation for violation of the liquor law. Information was received from these offices that he had no such record or reputation. Information was given, however, from the Sheriff’s office that Guy Walker had both record and reputation as violator of state and federal laws relating to liquor. No inquiry or investigation was made at the headquarters of the principal federal internal-revenue officer engaged in the enforcement of the liquor laws in that locality, or at the headquarters of any other principal local or federal law enforcement officer of the locality as to Paul' Walker, and no inquiry or investigation whatsoever was made of Guy Walker, the admitted real owner and purchaser of the automobile.
The claimant had Paul Walker investigated.in August, 1936, by the Business Service Bureau of Greenville, South Carolina, in connection with the purchase of a 'refrigerator. No investigation at that time was made as to his reputation or record for violating the liquor laws; the investigation did disclose that he had a good reputation in the community where he lived, and this was the reputation given him by his employer at that time.
The claimant purchased the, conditional .sales contract in good faith, believing thát Paúl Walker was the pur[224]*224chaser and owner of the automobile. It had no knowledge, information or suspicion of the true facts until after the automobile had been seized by federal officers.
Petitioner challenges the judgment below because of claimant’s failure, to establish compliance with' the conditions imposed by sub-section (b) § 204. Especially because claimant failed to' show that it had no reason to believe the automobile was being used or would be used to violate the liquor laws; also because it made no adequate inquiry concerning the' record and reputation of the real purchaser — Guy Walker.
Respondent’s interest in the automobile is not questioned. It “purchased the conditional sales contract in good faith, believing that Paul Walker was the purchaser and owner of the automobile. It had no knowledge, information or suspicion of the true facts until after the automobile had been seized.” This is enough to show compliance with sub-section • (b) (1). There was an interest acquired in good faith.
After investigation of the record and reputation of Paul Walker, followed by favorable reports, and believing him to be purchaser and owner of the automobile, claimant in good faith acquired the sales contract. It had no knowledge, information or suspicion that Paul Walker was only a “straw” purchaser.
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Mr. Justice McReynolds
delivered the opinion of the Court.
In each of these causes the District Court, proceeding under the “Liquor Law Repeal and Enforcement Act” [221]*221of August 27, 1935 (c. 740, 49 Stat. 872, 878, Title 27 U. S. C. § 40a), mitigated the forfeiture of an automobile seized for unlawful transportation of distilled spirits upon, which the federal tax had not been paid. (One was seized December 3, 1936; the other, March 15, 1937.) The forfeiture was decreed in a proceeding based upon § 3450 R. S. (Title 26 U. S. C., § 1441). The Circuit Courts of Appeals rightly approved and their judgmehts must be affirmed.
The facts, undisputed, are essentially alike, in both causes. The points of law are the same. A statement based on Record No. 10 will suffice.
The Repeal Enforcement Act provides—
“Sec. 204. (a) Whenever, in any proceeding in court for the forfeiture, under the internal-revenue laws, of any vehicle or aircraft seized for a violation of the internal-revenue laws relating to liquors such forfeiture is decreed, the court shall have exclusive jurisdiction to remit or mitigate the forfeiture.
“(b) In any such proceeding the court shall not allow the claim of any claimant for remission or mitigation unless and until he proves (1) that he has an interest in such vehicle or aircraft, as owner or otherwise, which he acquired in good faith, (2) that he had at no time any knowledge or reason to believe that it was being or would be used in the violation of laws of the United States or of any State relating to liquor, and (3) if it appears that the interest asserted by the claimant arises out of or is in any way subject to any contract or agreement under which any person having a record or reputation for violating laws of the United States or of any State relating to liquor has a right with respect to such vehicle or aircraft, that, before such claimant acquired his interest, or such other person acquired his right under such contract or agreement, which ever occurred later, the claimant, his officer or agent, was informed in answer to his inquiry, at the [222]*222headquarters of the sheriff, chief of police, principal Federal internal-revenue officer engaged in the enforcement of the liquor laws, or other principal local or Federal law-enforcement officer of the locality in which such other person acquired his right under such contract or agreement,. of the locality in which such other person then resided, and of each locality in which the claimant has made any other inquiry as to the character or financial standing of such other person, that such other person had no such record or reputation.”
The following findings by the District Court, it is agreed, correctly set out “the facts in this case”—
The Ford automobile in question was sold-by the Greenville Auto Sales, Incorporated (the dealer) October 3, 1936, through its agent, Elrod, to Guy Walker, who in part payment exchanged an old car paid for by him, but registered in, his wife’s name. He was given terms for payment under a conditional sales contract, drawn by an agent of the dealer, in the name • of his brother, Paul Walker, who formally executed the agreement. Guy Walker had the conditional sales contract drawn and executed in the name of his brother in order to place the title' “where his wife could not reach it.” Paul Walker had -no interest in the transaction except to comply with his brother’s request. Guy Walker made the’ transaction with the dealer. He selected the car, made the agreement and handled the transaction himself. Paul Walker drove the ‘car from the dealer’s place of business. Guy Walker at the time, and for two or three weeks after the purchase, was living at his brother’s house. Only one payment was made on the conditional sales contract before the seizure, and that by Guy Walker to the dealer.
It was admitted that Guy Walker had a previous record and reputation for violating both state and federal laws relating to liquor. Paul Walker was convicted of violating the National Prohibition Act in 1929, and was duly [223]*223sentenced therefor, but his record and reputation since serving the sentence were good.
On the date when the sale was consummated the dealer submitted the contract to the Commercial Credit Company, the claimant here, who accepted by telephone, and subsequently on October 5th, in the usual course of business the dealer assigned the contract'to the claimant and received a check therefor.
The claimant before accepting assignment of the sales contraet made an investigation of Paul Walker by inquiring at the headquarters of the Sheriff of Greenville County, and at the headquarters of the Chief of Police of Greenville, the County and City where the interest was acquired and the locality where Paul Walker resided, as to his record and reputation for violation of the liquor law. Information was received from these offices that he had no such record or reputation. Information was given, however, from the Sheriff’s office that Guy Walker had both record and reputation as violator of state and federal laws relating to liquor. No inquiry or investigation was made at the headquarters of the principal federal internal-revenue officer engaged in the enforcement of the liquor laws in that locality, or at the headquarters of any other principal local or federal law enforcement officer of the locality as to Paul' Walker, and no inquiry or investigation whatsoever was made of Guy Walker, the admitted real owner and purchaser of the automobile.
The claimant had Paul Walker investigated.in August, 1936, by the Business Service Bureau of Greenville, South Carolina, in connection with the purchase of a 'refrigerator. No investigation at that time was made as to his reputation or record for violating the liquor laws; the investigation did disclose that he had a good reputation in the community where he lived, and this was the reputation given him by his employer at that time.
The claimant purchased the, conditional .sales contract in good faith, believing thát Paúl Walker was the pur[224]*224chaser and owner of the automobile. It had no knowledge, information or suspicion of the true facts until after the automobile had been seized by federal officers.
Petitioner challenges the judgment below because of claimant’s failure, to establish compliance with' the conditions imposed by sub-section (b) § 204. Especially because claimant failed to' show that it had no reason to believe the automobile was being used or would be used to violate the liquor laws; also because it made no adequate inquiry concerning the' record and reputation of the real purchaser — Guy Walker.
Respondent’s interest in the automobile is not questioned. It “purchased the conditional sales contract in good faith, believing that Paul Walker was the purchaser and owner of the automobile. It had no knowledge, information or suspicion of the true facts until after the automobile had been seized.” This is enough to show compliance with sub-section • (b) (1). There was an interest acquired in good faith.
After investigation of the record and reputation of Paul Walker, followed by favorable reports, and believing him to be purchaser and owner of the automobile, claimant in good faith acquired the sales contract. It had no knowledge, information or suspicion that Paul Walker was only a “straw” purchaser. This is enough to show compliance with sub-section (b) (2). The suggestion that since respondent knew automobiles were frequently used for violation of liquor laws it therefore had reason to believe that the one in question would be so used is not well founded. The findings positively affirm that it entertained no such belief or suspicion.
The difficult phrasing of sub-section (b) (3) has produced divergent views concerning its meaning.
In Federal Motor Finance v. United States, 88 F. 2d 90, 93, the Circuit Court of Appeals Eighth Circuit said—
“We think the fair intendment of the language of subsection (3) concerning remission of forfeiture is that the [225]*225appellant could not rely entirely upon a course of business whereby it acquired an interest in the car so nearly approximating the total value thereof, without taking care to ascertain who the real owner was in possession of and using the car.”
In the causes now before us (93 F. 2d 771, 773; 99 F. 2d 498, 500), the Circuit Court of Appeals accepted the view that—
“The involved language of subsection (b) (3) of the act does permit the possible interpretation that the lienor is charged with the duty of making inquiry as to every one, bearing a bad reputation or record, who may have a right under the contract of sale,- whether or not it appears on the face of the instrument. See Federal Motor Finance v. United States, 8 Cir., 88 F. 2d 90. But in our view Congress did not intend to impose upon the lienor the obligation to ascertain at his peril the identity of every person having an interest in the property and to make inquiry of the law enforcement officers as to the previous record and reputation of every such person, unless from the documents themselves or other surrounding circumstances the lienor possesses information which would lead a reasonably prudent and law-abiding person to- make a further investigation.”
See also C. I. T. Corporation v. United States, (Fourth Circuit) 86 F. 2d 311, and United States v. C. I. T. Corporation, (Second Circuit) 93 F. 2d 469.
Counsel for petitioner now maintain: “That under the language of the statute [(b) (3)] the claimant is required to investigate the real .purchaser at its peril and that if it fails to do so, as between it and the Government, the claimant assumes the risk of fraud perpetrated upon it by the dealer and the bootlegger. In any event, the claimant should have been required to show that it at least made a reasonable effort to ascertain who the real [226]*226purchaser and user of the car was so that he could be investigated as required by the statute.”
Manifestly, § 204 is a remedial measure. It empowers the courts, exercising sound discretion, to afford relief to innocent parties having interests in condemned property where the claim is reasonable and just. Its primary purpose is not to protect the revenues; but this is proper matter for consideration whenever remission is sought. The section must be liberally construed to carry out the objective. The point to be sought is the intent of the lawmaking powers. Forfeitures are not favored; they should be enforced only when within both letter and spirit of the law. Farmers’ & M. National Bank v. Dearing, 91 U. S. 29, 33-35. If any claimant has been negligent or in good conscience ought not be relieved, the court should deny his application.
Consideration of the statutory provisions relative to remissions prior to § 204 and the circumstances of its adoption will enlighten the purpose entertained by Congress.
Sections' 3450 and 3453 Revised Statutes (Title 26 U. S. C. §§ 1441, 1620-1621) — derived from Acts June 30, 1864 and July 13, 1866 — provide that whenever any commodity in respect of which a tax is imposed, is removed with intent to defraud the United States,, it shall be forfeited “and every vessel, boat, cart, carriage, or other conveyance whatsoever, and all horses or other animals, and all things used in the removal or for the deposit or concealment thereof, respectively, shall be forfeited.” “The proceedings to enforce such forfeitures shall be in the nature of a proceeding in rem in the circuit court or district court of the United States for the district where such seizure is made.”1
[227]*227Sections,3460 and 3461 (Title 26 U. S. C. § 1624) derived from Acts July 13, 1866 and June 6, 1872 — provide that when goods, wares, or merchandise seized as subjects of forfeiture, do not exceed $500 in value, they may be restored to the claimant upon the execution of a bond and this shall be delivered to the District Attor[228]*228ney for proper proceedings; if no bond, the articles shall be sold and the proceeds paid into the Treasury. Within a year any claimant may apply to the Secretary for remission which may be granted “upon satisfactory proof, to be furnished in such manner as he shall prescribe: Provided, That it shall be satisfactorily shown . . . that the said forfeiture was incurred without willful negligence or any intention of fraud on the part of the owner of said property.” 2
Where the value exceeds $500 or bond is given, forfeiture must be sought in court through a libel in rem. [229]*229United States v. Two Bay Mules, Etc., 36 F. 84; United States v. Mincey, 254 F. 287; Logan v. United States, 260 F. 746; United States v. One Bay Horse, 270 F. 590.
Section 3229 Revised Statutes (Act July 20, 1868, c. 186, § 102, 15 Stat. 125, 166 ; 26 U. S. C. § 1661) provides—
“The Commissioner of Internal Revenue, with the advice and consent of the Secretary of the Treasury, may [230]*230compromise any civil or criminal case arising under the internal-revenue laws instead of commencing suit thereon; and, with the advice and consent of the said Secretary and the recommendation of the Attorney-General, he may compromise any such case after a suit thereon has been commenced. Whenever a compromise is made in any case there shall be placed on filé in the office of the Commissioner the opinion of the Solicitor of Internal Revenue, or of the officer acting as such, with his reasons therefor, with a statement of the amount of tax assessed, the amount of additional tax or penalty imposed by law in consequence of the neglect or delinquency of the person against whom the tax is assessed, and the amount actually paid in accordance with the terms of the compromise.”
(Amended, Acts February 26, 1926, c. 27, § 1201, 44 Stat. 9, 126; May 10, 1934, c. 277, § 512 (b), 48 Stat. 680, 759; May 28, 1938, c. 289, § 815, 52 Stat. 447, 578.)
Wilson Motor Co. v. United States, (Ninth Circuit) 84 F. 2d 630, 632, states — “The government’s brief advises that prior to the Act of August 27, 1935, the procedure . of the government to afford relief to these innocent owners was under the provisions of compromise powers given the Attorney General and the Treasury under section 1661, 26 U. S. C. A.”
In connection with the sections referred to above the United States Code Annotated points to their origin and history..
The National Prohibition Act (October 28, 1919, c. 85, Title II, § 26, 41 Stat. 305, 315, Title 27 U. S. C. § 40) provided that “whenever intoxicating liquors transported or possessed illegally shall be seized by an officer he shall take possession of the vehicle and team or automobile, boat, air or water craft, or any other conveyance, and shall arrest any person in charge thereof.” The person [231]*231arrested shall be proceeded against but the vehicle or conveyance shall be returned upon execution of a bond. Upon his conviction the court shall order the liquor destroyed “and unless good cause to the contrary is shown by the owner, shall order a sale by public auction of the property seized.” 3 See Richbourg Motor Co. v. United States, 281 U. S. 528. This was repealed by The Repeal and Enforcement Act, supra.
[232]*232The Act of September 21, 1922, (c. 356, § 618, 42 Stat. 858, 987) provides—
‘Whenever any person interested in any vessel, vehicle, merchandise, or baggage seized under the provisions of this Act, or who has incurred, or is alléged to have incurred, any fine or penalty thereunder, files with the Secretary of the Treasury if under the customs laws, and witfi the Secretary of Commerce if under the navigation laws, before the sale of such vessel, vehicle, merchandise, or baggage a petition for the remission or mitigation of such fine, penalty, or forfeiture, the Secretary of the Treasury, or the Secretary of Commerce, if he finds that such fine, penalty, or forfeiture was incurred without willful negligence or without any intention on the part of the petitioner to defraud the revenue or to violate the law, or finds the existence of such mitigating, circumstances as to justify the remission or mitigation of such fine, penalty, or forfeiture, may remit or mitigate the same upon such terms and conditions as he deems reasonable and just, or order discontinuance of any prosecution relating thereto.” ■
[Reenacted by Act July 17, 1930, c. 497, § 618, 46 Stat. 590, 757; 19 U. S. C. § 1618.]
The Act May 29, 1928 (c. 852; § 709, 45 Stat. 791, 882, 26 U. S. C. § 1626) extended “the provisions' of law applicable to the remission or mitigation by the Secretary of the Treasury of forfeitures under the customs laws ... to forfeitures incurred or alleged to have been incurred, before or after the enactment of this Act, under .the internal-revenue laws.”
In' the situation disclosed by the foregoing summary, Congress came to .consider the Act of August 27, 1935. The Judiciary Committees of Senate and House made reports (Senate Report No. 1330, House Report No. 160Í, [233]*23374th Cong., 1st Session). In each the paragraphs relative to § 204 (a) and (b) are the same in substance.4
[234]*234A representative of the Treasury Department made a statement to the Senate Judiciary Committee. An extract from this appears in the margin.5
A rearrangement of the words of sub-section (b) (3) will enlighten its 'meaning—
“The court shall not allow the [request] — claim—of any claimant for remission or mitigation, if it appears that [235]*235the interest asserted by [him] — the claimant — arises out of or is in any way subject to any contract or agreement under which any person having a record or reputation for violating laws of the United States or of any State relating to liquor has a right with respect to such vehicle or aircraft, unless and until he [the claimant] proves that before [he] — such claimant — acquired his 'interest, or such other person acquired his right under such contract- or agreement, whichever occurred later, [he] — thé claimant — his officer or agent, was informed in answer to his inquiry, at [certain headquarters specified in the alternative] as to the character or financial standing of such other person, that such other person had no such record or reputation.”
If the words of § 204 (b) (3) be taken literally, without regard to history or purpose of the enactment, they inhibit remission by the court unless one who claims an interest made actual inquiry concerning every person with1 record or reputation for violating the liquor laws who in fact (although wholly unsuspected) had acquired some right to the vehicle. There would be absolute forfeiture although the claimant acquired his interest in the utmost good faith and without suspicion of any undisclosed interest;- although- indeed, he had diligently but unsuccessfully sought information concerning all. the facts from every person connected with the transaction. Thus construed the provision would require absolute forfeiture notwithstanding the claimant could not by the utmost diligence ascertain .the true situation. No greater reason exists for saying a claimant should be relieved if he made unsuccessful inquiry of the seller concerning undisclosed matters than there is for relief when he had no cause to suspect the existence of an undisclosed interest — no cause to question appearances. A measure requiring absolute forfeiture under such circumstances probably would be expressed in language sufficiently plain to admit no reasonable doubt.
[236]*236During many years innocent claimants had a clear remedy either by appeal to the discretion of the Secretary of the Treasury or by application for compromise addressed to the Attorney General and Treasury officials (Wilson Motor Co. v. United States, supra); or under the Prohibition Act, to the court (Richbourg Motor Co. v. United States, supra). This situation was called to the attention of the Senate Committee by the representative of the Treasury. He also pointed out that before restoring a car the Secretary required that the claimant “must prove that he made an investigation as to whether or not the purchaser had a bootlegger record and found that he had none.” The Secretary “considers that the bootleg hazard is an element involved in the credit risk, and is just as much a part of the investigation by the finance company of a person as a credit risk as is his financial standing in the community.” The Committee reported in respect of. 204 (b) (3) — “This last requirement is predicated upon the recognition of the ‘bootleg hazard’ as an element to be considered in investigating a person as a credit risk.”
These facts indicate that Congress intended a reasonable inquiry concerning the bootleg risk should be made in connection with the investigation of financial responsibility. They negative the notion that a wholly innocent claimant at his peril must show inquiry concerning something unknown and of which he had no suspicion. Dealers do not investigate what they have no cause to suspect.
The forfeiture acts are exceedingly drastic. They were intended for protection of the revenues, not to punish without fault. It would require unclouded language to compel the conclusion that Congress abandoned the equitable policy, observed for a very long time, of relieving those who act in good faith and without negligence, and adopted an oppressive amendment not demanded by [237]*237the tax officials or pointed out in the reports of its committees.
Sub-section (b) (3) was intended to prevent remission to- a claimant who had failed to inquire when he should have done so, to one chargeable with willful negligence or purpose of fraud. It would be excessively harsh, unreasonable indeed, to say that one dealing in entire good faith must, at his peril, first discover and then make inquiry concerning somebody of whose existence he has no knowledge or suspicion. We cannot think Congress intended thus to burden dealing in all vehicles capable of transporting liquor.
It should be observed that the following things are possible subjects of seizure and forfeiture because of liquor law violations: “Every vessel, boat, cart, carriage, or other conveyance whatsoever, and all horses or other animals, and all things used in the removal or for the deposit or concealment, etc.” “Vehicle” is thus defined— “That in' Or on which a person or thing is or may be carried from one place to another.” A wheelbarrow, a covered wagon, a “Rolls-Royce,” .the. patient mule, a “Man of War,” and possibly a Pullman car or Ocean Liner is a vehicle.'. Goldsmith-Grant Co. v. United States, 254 U. S. 505; United States v. Two Bay Mules, supra; United States v. One Bay Horse, supra.
Sub-section (b) (3) applies not only to transactions by financial concerns like respondent but • to those of individuals and corporation's great or small. It contemplates an investigation and this presupposes some reason at least to suspect the existence of the subject of investigation. Congress took away from executive officers the power to mitigate forfeitures where the property exceeds $500 in value, and gave this to the court familiar with the circumstances; but it left-with the Secretary of the Treasury discretion to remit when" the value was below $500. The intent was to require the courts to exact [238]*238proof of inquiries like those demanded by the Treasury Department practice, and disclosed by its representative before the Senate Committee. The petitioner’s view, if adopted, would sanction one standard of remission for a vehicle worth $500, another when appraised at a dollar more.
The challenged decrees must be
Affirmed.
Mr. Justice Butler and Mr. Justice Stone took no part in the consideration or decision of these causes.