2 q 6 Biological Controversy and its Laws . [April, 
the controversialist who charges his opponent with atheism 
stands in a precisely similar position. He well knows that 
although the public might not admit, totidem verbis , that 
“ whatever an atheist advances must be false,” or that 
“ every theory once pronounced atheistic must be erroneous,” 
yet it will practically aft as if such propositions were esta- 
blished. Hence by making such charges he fraudulently 
attempts to steal from the public, through an appeal to their 
passions, a verdift which he has no hope of obtaining from 
their reason. Knowing and trading on the extreme animo- 
sity with which the heretic, the sceptic, and the atheist are 
— rightly or wrongly — regarded, he seeks to deprive his op- 
ponents of a fair hearing by applying to them these dreaded 
names. A meaner, a more infamous, stratagem can scarcely 
be conceived. Yet more: it is not the man conscious of the 
goodness of his cause who fights with such weapons. He 
who knows that his views are in harmony with fafts has 
nothing to gain by foul play ; but if he feels inward mis- 
givings concerning the doftrines which he advocates, or 
doubts at least the possibility of bringing forward valid ar- 
guments in their defence, he may readily, if dishonest 
enough, seek to blacken the character of an opponent. 
We may, therefore, safely and fairly conclude that whoso- 
ever in scientific controversy introduces accusations of 
atheism is, if not knowingly and wilfully, still decidedly in 
the wrong. We are consequently fully justified in shutting 
his book, and giving judgment against him. 
But there is another consideration which here forces itself 
upon our attention. All writings calculated to bring a man 
into general “ ridicule, hatred, or contempt,” are by the law 
declared to be libellous. Now it is very questionable if, in 
England, any accusation is so much calculated to bring a 
man into “ hatred and contempt ” as a charge of atheism or 
“ materialism,” however ill-founded it may be. Surely there- 
fore such charges, whether brought diredtly or by implication, 
are libellous, and as such they are more fitted to be dealt 
with by a criminal court than by reviewers. We should like 
to see such a case decided, and we believe that the result 
would be a great improvement in the tone of scientific and 
semi-scientific controversy. 
But even if such accusations should be pronounced 
not libellous, and if those who resort to them have no 
legal penalties to dread, there is another tribunal which 
might interfere. Why should not scientific men, scientific 
societies, and scientific journals, agree that whosoever in a 
scientific controversy attempts to get rid of an opponent by 
