IDG BILLS OF EXCHANGE.

or to A. B. or bearer, or to drawer’s own order, or to bearergenerally.

.. The sum for which hills are drawn should he clearly ex-pressed in words at length in the body ; and as previouslyobserved, it is also usual to write it in figures at the head.The first caution may prevent forgery, and the second maysupply a defect in the former; and in an indictment forforgery, an omission in the bill lias been aided by its super-scription. 11 If the sum in the superscription he differentfrom that mentioned in the body, that specified in the bodywill be taken prima facie to he the sum payable.' 1 As itrespects foreign hills, there is no restriction as to amount.But inland hills are different, as are drafts, which' are for-bidden by law, for any sum under twenty shillings, undera penalty of £:20. Vide 15 Geo. III. cap. 51.

As to value received for a Bill. — In France , it appearsit was not only necessary to the validity of a hill, that it shouldexpress whether or not value had been received, hut like-wise the nature of the consideration constituting that value ; 13but in this country it is otherwise, as value received is im-plied in every hill and indorsement, as much as if expressedin totidem verbis.'* * *• And although there are some old cases ,son the question, whether indebitatus assumpsit would lie ona bill of exchange, in which it appears there was a distinc-tion made between a hill importing to have been given for valuereceived, and one not containing those words; and it washolden that in the first case the drawer was chargeable atcommon law, but in the latter on the custom only; 16 yet it isnow settled that there is no such distinction, and tlmt a hillneed not contain those words. 16

To entitle the holder of an inland bill or note for .£20,or upwards, to recover interest and damages against drawerand indorser in default of acceptance or payment, it shouldcontain the words “ Value received.” 17 If a hill or notecontain those words, an action of debt may he sustained bythe payee against the maker of each. 13 These distinctions

** 2 Past. PI. Cr. 951.

** Bcawes, pi. 193. Mar. 2d edit. 138, 9. 2 East PI. Cr. 951.

■3 Poth. pJ. 8. 34.

Claxton v, Switt, 2 Show. 496. White v. Ledwick, B. R. H. 25 Geo. III.Bay!. 13. n. a. Ld. Raymond 1481. Fort. 282. 8 Mod. 267. 1 Barnard, 88.

Lutw. 889. 1 Mod. 310, acc . 3 Will. 212- 2 Stra. 1212, semb . contra. 2 Black.Com. 468.

*s Beawes, pi. 233. Show. 5. Vin. Abr. tit. Bills of Exchange.

*• Same cases as in note 14.

*7 9 & 10 Wm. III. c. 17. 3 & 4 Ann. c. 9. sec. 4. Kjd, 148, 9. Bayl. 75.*» 2B.&P. 78. 81.