200 JOURNAL OF THE PLYMOUTH INSTITVTION. 
1. Because of their higher organization. 
2. From the existence of numerous differences which supply 
generally obvious and well-defined characters for their systematic 
classification. 
3. From their appearance in strata of comparatively recent age, 
which are better known than Paleeozoic deposits. 
He discusses the position geologically of the three great groups— 
Apetale, Monopetale, and Polypetale—and finds that the lower 
group is not to be found where, by the theory of Evolution, it 
ought to be found, and would be found if it formed part of the 
then existing vegetation; while in higher strata—the Upper 
Cretaceous for example—representatives of the three groups are 
found together in the deposit, and these ‘‘ divisions are represented 
not by generalized types, but by differentiated forms, which, 
during the intervening epochs, have not developed even into higher 
generic groups.” 
Moreover these groups, since Dicotyledons first appeared, have 
continued through all the intervening periods, and still hold their 
place among existing forms of vegetation. As an instance of this, 
Mr. Carruthers takes the willow (Salix polaris), found in the 
lowest pre-Glacial beds at Cromer, and in deposits of the same age 
at Bovey Tracey, a plant still living in the Arctic regions. 
Of this plant he says that—‘ The earliest Dicotyledon takes us 
not a step further back in the phylogenetic history of Salix than 
that supplied by existing vegetation. All beyond the testimony of 
our living willows is pure imagination, unsupported by a single 
fact . . . the evidence is against Evolution, and there is‘none in 
favour of it.’’ He concludes therefore, that ‘‘the whole evidence 
supplied by fossil plants is opposed to the hypothesis of genetic 
Evolution.” 
From Fossil Plants we turn to Fossil Animals, and here also we 
are able to appeal to a witness, whose ability and familiarity with 
his subject are beyond all question. 
Mr. Thomas Davidson, F.R.s., F.¢.8., has contributed three articles 
in the Geological Magazine of the current year, in answer to the 
question, ‘‘ What is a Brachiopod?” He tells us that he has 
devoted the best portion of his life to the study of the Brachiopoda. 
The Brachiopod is a bivalve, with the shell “ varying generally 
from a quarter of an inch to about four inches in size, in certain 
species reaching to nearly a foot in length by something less in 
