LEGAL POWERS IN ENGLAND 317 



specifically mentions milk, while in the 1899 Act the peculiar 

 needs of milk as regards standards of chemical composition 

 are clearly outlined and given definite expression in the Milk 

 Eegulations of 1901. 



The fact that milk is a special food, with peculiar liabilities 

 to contamination, and needing special regulations for its pro- 

 tection and preservation in a state of purity, is legislatively 

 conceded by the issue of the Dairies, Cowsheds, and Milkshops 

 Order of 1885. Article 9 of this Order clearly admits the 

 conception that milk may be a vehicle for spreading infectious 

 diseases, a view which receives further legislative endorsement 

 by the Order of 1899, by Section 4 of the Prevention Act, 

 1890, and by the sections quoted above from the Public 

 Health Acts Amendment Act, 190*7. 



It will be seen that, broadly speaking, the laws affecting 

 milk are framed with three objects : 



(1) To regulate the quality of milk as a food and its 



chemical content. 



(2) To preserve the purity of milk as a food. 



(3) To prevent milk acting as a vehicle for the spread of 



disease, particularly infectious disease. 



The introduction of the Milk and Dairies Bill, 1909, of 

 Mr. John Burns is an admission that the present laws are 

 inadequate to effect these three objects. 



The relationship between milk and infectious disease is 

 one of growing legal importance. From this point of view 

 the case of Frost v. The Aylesbury Dairy Company is one 

 of great significance ; the facts are therefore briefly appended. 



Frost v. The Aylesbury Dairy Company. This case was 

 ultimately decided by the Court of Appeal. The Aylesbury 

 Dairy Company supplied the plaintiff, Mr. Ealph Frost, with 

 milk during the summer of 1903. According to the plaintiff 

 the milk in question was infected with the germs of typhoid 

 fever, with the result that the plaintiff's wife contracted 

 typhoid fever and died from it. It was ascertained that a 

 son of the woman who kept the utensils clean at the farm 

 from which the milk came had a severe attack of typhoid 

 fever and died. Twenty-three cases of this disease occurred 

 in Ealing, where the milk from this farm was supplied. The 

 scientific evidence was not completely conclusive that the 



