In a pleasant popular account of the owners of Gormanston Castle and of some documents connected with them, recently published by Father Aubrey Gwynn, there is one matter upon which comment seems desirable: this is the author's restatement of the late Miss M. V. Clarke's hypothesis regarding the Irish Modus tenendi parliamentum or rather one copy of it, that exemplified in 1419. That a historian so learned and critical as Fr. Gwynn should accept this hypothesis without reserve, and indeed hold up Miss Clarke's essays as ‘ models of their kind ’, suggests that they are capable of a good deal of mischief.