In  the  case  of  Bruce  v.  Willis,^  a  canal  company  were
enabled  by  Act  of  Parliament  to  purchase  lands,  paying
full  satisfaction ;  and  commissioners  were  appointed  to
settle  the  amount  of  satisfaction  payable  in  each  case,  and
in  certain  cases  to  summon  juries  to  assess  damages.  Judg-
ments of  the  commissioners  and  verdicts  of  the  juries  were
to  be  transmitted  to  the  clerk  of  the  peace,  and  to  be
deemed  records  of  sessions.  By  an  inquisition,  a  jury
assessed  damages  at  thirty  years'  purchase  for  certain  lands
necessary  for  making  a  cut,  &c.,  part  of  the  navigation,  and
an  annual  payment  was  awarded  for  certain  land  required
for  a  towing-path.  The  canal  company  made  a  lock,
canal,  and  towing-path  on  the  land  aforementioned,  but
no  conveyance  was  ever  executed.  The  Court  held  that
the  Act  of  Parliament  vested  the  soil  used  for  these  works
in  the  canal  company  without  a  conveyance.
There  is  no  common  law  liability  on  the  owner  of  the
bed  of  a  navigable  river  or  navigation  to  cleanse  it  or
keep  it  free  of  obstructions,  or  to  compensate  adjoining
owners  for  damage  done  by  overflow  of  the  water,  even  in
cases  where  tolls  are  taken  for  navigating  thereon.^    It


1  11  A.  &E.  463;  S.  v.  Mersey
and  Irwell  Navigation,  9  B.  &  C.  95 ;
n.  V.  Thomas,  9  B.  &  C.  114.  See
Somerset  Canal  v.  Ilarcourt,  2  De  G.
&  J.  596  ;  Seg.  v.  Archbishop  of
York,  14  Q.  B.  81;  JPatrick  v.  Seau-
fort,  6  Ex.  498 ;  Boiins  v.  Waneiclc,


2  Bing.  N.  C.  483  ;  Barlorough  v.
Shadloti),  7  M.  &  "W.  37 ;  Dimes  v.
Grand  Junction  Canal,  3  H.  L.  794  ;
Simi)son  v.  Staffordshire  Water  Co.,
4De  G.,  J.  &'S.  679.
