' Parrot v. Knickerbocker Ice Co., 46 N. Y. 361 ; Weick v. Dougherty,
28 Ky. L. Rep. 930; 3 L. R. A. (n. s.) 348.
"" ' Richmond & Danville R. R. v. Elliott, 149 U. S. 266.
* Newark Coal Co. v. Upson, 40 Oh. St. 17.
» Winslcw V. Lane, 63 Me. 161.
» Butler V. Manhattan R. R., 143 N. Y. 417; 26 L. R. A. 46; ace. Tun-
nicliffe v. Bay Cities C. R. R. Co., 102 Mich. 624; 32 L. R. A. 142.
CERTAINTY. 29

(dd) Action by a florist against owner of pipes from which gas
has escaped injuring his plants. A claim for damages through
injury to plaintiff's business reputation on account of sales of
damaged plants is conjectural and cannot be allowed.'

• Dow V. Wiimipesaukee Gas & Elec. Co., 69 N. H. 312; 42 L. R. A.
569.
CHAPTER m.
RULES OF EXCLUSION.
The whole law of damages may be stated in the form of a
single proposition : compensation must always be commensurate
with injury. Before examining the subordinate rules into which
this very general formula resolves itself when appUed in practice
to particular cases, it is necessary to notice certain rules of exclu-
sion which, together with that of Certainty, reduce the field of
actual compensation within much narrower limits than might
perhaps have been anticipated. Some of these rules are fre-
quently criticised as illustrations of the arbitrary and imperfect
character of the law, and as if they might conceivably have been
omitted altogether. It is believed, 'however, that they rest upon a
foundation of principle, and cannot be disregarded without im-
pairing two essential requirements, — certainty of proof, and uni-
formity of law.
