Poor-laws. Charity, like Christianity, had its origin, or earliest development, in the East. Among the primitive nations of the world almsgiving was inculcated as a religious observance, and is prescribed as such in their sacred records. Among the European nations of antiquity we find a provision for the poor adopted as a matter of state policy. In early times Athens could boast of having no citizen in want; 'nor did any disgrace the nation by begging.' But war at length brought poverty in its train, and the Athenian people decreed the maintenance of those who were mutilated in battle, and, at a later period, of the children of those who fell. Plutarch mentions Pisistratus as the originator of the first decree, though others derive it from Solon. By the latter decree the state provided for the orphans of its soldiers up to their eighteenth year, and then sent them into the world with a new suit of armour. The bounty given to the disabled is mentioned by Lysias, Harpocraton, Aristotle, Isocrates, and others; it is variously stated at one, two, and three oboli a day, and it seems to have been increased with the increased cost of subsistence. There were also societies for the relief of distress among the democratic states of Greece, called eranoi—a sort of friendly societies, in which the members relieved were expected to pay back the money advanced to them when they had raised themselves to better circumstances. But it must be remembered that these so-called democratic states were in reality slave-holding aristocracies.
Among the Romans the Agrarian Law of Licinius Stolo (367 B.C.) was framed in order to prevent the extremes of riches and poverty in the state. It limited the extent of property in public land to be held by each citizen, and directed that all such land above the allotted portion should be taken away from the holders, and given to those who had none. The distribution of grain at reduced prices, which at length became gratuitous, was introduced by Caius Gracchus, and lasted till the fall of the Roman empire. Augustus in vain tried to suppress it. In his time 200,000 citizens were thus fed. Cicero makes mention of this provision as in great favour with the Roman people, because it furnished them with an abundant subsistence without labour; other Roman writers describe its results as disastrous both to agriculture and to manners, creating a nation of mendicants, and causing the land to fall out of cultivation.
In the middle ages the great body of the labouring classes were in a state of serfdom, and looked to their feudal lords for maintenance. The obligation to provide for their slaves, or serfs, seems to have been fully recognised, so that many, encountering in a state of freedom the miseries of want, went back to bondage as a refuge from destitution. The villeins in Saxon England were attached to the soil, and received from their lord a portion of land for the support of themselves and their families. But the Church of Rome constituted herself the great receiver and dispenser of alms. The rich monasteries and abbeys distributed doles to the poor, as is still done at the mosques under the Mohammedan system.
In most states of continental Europe the church remains to a larger or smaller extent the public almoner, the state only stepping in to supplement the offerings of the church and voluntary charity when they become deficient. The disseverance from the church is hardly anywhere so complete as in England. The laws of different countries vary as to the degree of want entitling a panper to relief, the extent to which the right to relief is matter of positive right, the conditions which give rise to a claim of relief, the incidence of taxation, and the obligation on relatives to aliment.
It is only in Prussia, Denmark, and Sweden that there is any legislative declaration of the right to relief; and only in Britain and Denmark is any special tax imposed for this purpose. On the continent of Europe, generally speaking, the administration of relief falls on the parish or commune, but the responsibility of supervision undertaken by central departments varies greatly; no work-house test is applied; and the statistics are not reliable. In northern Europe there has been a more decisive severance of poor-law functions from the church. In Denmark the old law was altered in 1867-68 to one of elective unions in rural districts, the burgomaster and town-council becoming the poor-law authority in each considerable town. The overseers are amateurs, and medical aid is universal. In Sweden the law formerly rested on the Church Ordinance of 1571, but the statutes of 1871 (translated by Nassan Jocelyn and criticised by Lammers) have made great changes, the relief of the able-bodied being prohibited, a direct liability being placed on the larger employers of labour, and a system of poll-taxation introduced. In Norway (where the system of out-quartering still subsists) the poor-law of 1845 was altered in 1863 in the direction of greater strictness, relief being restricted in theory to orphans and persons of unsound mind, and a maximum assessment fixed. Among other sources of income there is an excise duty on beer. In north Germany the old law of 1577 was gradually enlarged—e.g. by the Convention of Gotha and Agreement of Eisenach, dealing with the matter of settlement. In 1867 a law of free settlement was passed, and in 1870 by a general law the period of two years was fixed for pauper domicile. In Prussia this is further developed by a statute of 1871, which connects the Bezirksregierung, or local government, with the parish poor-law authority. The peculiar system of Leipzig (founded on that of Hamburg) is carried on by an Armendirectorium, amateurs of good social position, who make very strict inquiries by means of a Fragebogen, or question-paper.
In the Hanse towns there was introduced in 1788 a system of voluntary contributions aided by fixed subsidies from the government. This at length resulted in government supplying all deficiencies, which in the last few years have been 80 per cent. of the cost of the general poor relief. At the treaty of Versailles (1870) Bavaria preferred to remain under her own law of 1816, amended in 1869. In Belgium, known as the classic land of pauperism, there is no poor-rate, but large parochial endowments exist. As in France, there are hospices civils for indoor relief, and bureaux de bienfaisance for outdoor relief. The law may be enforced on communes by the Deputation Permanente of each province. One-third of the Belgian proletariat are inscribed on the poor-lists (see Laurent, Le Pauvérisme et les Associations de Prévoyance). In Russia the poor-law has been modified by the communal system of land-tenure and the large amount of unoccupied crown-land. Down to 1864 the landowner was bound to feed the serf, and there were also provincial charitable societies receiving state aid. The administration of the poor-law, however, was in that year handed over to the new Zemstvos, or local representative assemblies, who tax real property for this purpose. There is in St Petersburg a Grand Philanthropic Society with numerous branches; and many of the provincial offices of charity were endowed in the time of Catharine II. with the property of the monasteries. In Italy there is a remarkable absence of compulsory provision, except for lunatics and foundlings, but the charitable foundations amount to more than thirty millions sterling. The law of 1862, however, requires each charitable corporation to submit to the supervision of the representative provincial assembly. In Rome the Commissione de Carità has many peculiar features. Holland has no law of settlement.
In Austria each commune is charged with the relief of its poor. All who have legal domicile, or who, being unable to prove their domicile, are resident in the commune, are entitled to relief out of the general assessment. There is no special rate, and the administration is strictly municipal. In many provinces private charity is associated with public assistance, administered by the priest, a few chosen inhabitants, who are called 'Fathers of the Poor,' and an officer accountable to the commune. This system is called the 'Pfarrarmen Institute,' and their funds are principally derived from private sources; but they receive a third part of the property of ecclesiastics who die intestate, and certain fines, &c. The 'einziger system,' or boarding-out system, obtains to a large extent as regards both old and young paupers.
In France the law of 1798 distinctly negatived the right to relief. The present system rests mainly on the legislation of 1850-51, amended in 1872. The law of 1867 secured the intervention of the prefect. The relief of the poor is not compulsory, in as far as its distributors may, after making inquiry, refuse relief, except in the case of foundlings and lunatics. The minister of the Interior has a general superintendence of the machinery of relief, as well as the immediate administration of many large hospitals and refuges. The departmental funds are called upon for compulsory relief, but the commune is the main source of public assistance. It encourages and stimulates voluntary charities, and receives gifts for the benefit of the poor. The administration of the hospitals, and of the relief given at the homes of the poor (secours à domicile) is under the separate management of unpaid commissions, who co-operate with the communal authorities. The dépôt de mendicité is a penal establishment for the repression of vagrancy, and like the crèche is departmental. The work of the public dispensary is largely done by sisters of charity at a small salary and with unsatisfactory results, as at Boulogne.
In Holland pauper colonies have been supported by government for the last sixty years. Vagrants, after a short imprisonment, are sent to one of these, under a rigorous system of discipline. Paupers of good character are sent to maintain themselves and their families by agricultural labour in free colonies. The working of the system is pronounced costly and unsatisfactory. A description of the chief voluntary experiments in dealing with the poor in Europe will be found in The Charities of Europe, by John de Liefde (1865).
The annals of the poor in England are neither short nor simple. Severe enactments for the repression of vagabondage and mendicity date from a very early period. In ancient Saxon times the householder was bound to provide for the labourer, and men who had no master were, by the Folkmote, assigned to some householder; but when freedom began to prevail this state of things naturally came to an end. No master was bound to provide for the freeman, and when he failed to provide for himself, by honest labour, he generally took to vagrant begging, often to violence. The statute of Winchester (13th Ed. I., 1285) shows the poor utterly uncared for, and the roads infested by vagrant robbers. Up to the reign of Richard II. the sole idea of English rulers was to treat pauperism as a crime, and repress it by punishment, and by the most unjust and absurd restrictions on the freedom of labour. The 23d Ed. III. forbids giving alms to vagrants, on pain of imprisonment; then also the laws of settlement had their origin in the attempt to chain the free labourer to the land. The 12th Richard II. (1388), chap. 7, is the first statute that makes provision for the impotent poor. The statutes of Henry VII. endeavour to carry out, by the severest measures, the system of repression. The 27th Henry VIII., chap. 25 (1536), introduced the principle of compulsory assistance. Each parish was ordered to receive and provide for the impotent, and set the able-bodied to work. Alms were to be collected into a general fund, and indiscriminate almsgiving was forbidden, on pain of forfeiture of ten times the value given. The sturdy beggar was to be whipped when first caught, next to have his ears cropped, and for a third offence to suffer death as a felon and enemy to the commonwealth. In 1547 the following penalties were substituted—viz. branding, on first conviction, with a V on the shoulder, and being adjudged a slave for two years, to be claimed by any one, fed on bread and water, and caused to work by beating, &c. Running away from this tender treatment was punishable with S branded on the face, and slavery for life to the town or parish, on the roads of which the incorrigible vagrant was to work in chains. A little urging was now found necessary to obtain funds for the maintenance of the poor. The collectors were gently to ask every man and woman at church what they would give; but if one could not be persuaded the bishop was to send for the recusant, and use 'charitable ways and means.' At length the 5th Elizabeth, chap. 3 (1563), provided that he who obstinately refused to give should be handed over to the justices, who were empowered to tax him at their discretion, and send him to jail for default. Ten years later the power of compulsory assessment is given to the justices, and abiding-places are ordered to be provided for the aged and infirm. These statutes culminated in the 43d Elizabeth, chap. 2 (1601), which has formed the basis of the poor-law system of England up to the present time. It taxed every inhabitant of every parish for the relief of the poor. It directed the justices in every county to appoint three or four substantial householders in each parish to be overseers of the poor, along with the churchwardens. It ordered the relief of the impotent, and the apprenticing of children, and the providing of work for the able by means of 'a convenient stock of flax, hemp, wool, thread, iron, and other necessary ware and stuff.'
The great Act of Elizabeth came but slowly into operation. Up to the reign of Charles I. there were many parishes in which no rate was assessed, and which turned away their poor; but the great evils had been remedied, and there is little legislation on the subject for the next hundred years. The 3d William and Mary, chap. 2 (1691), provides that the persons to be relieved be registered and examined by the vestry, because evils had arisen out of the unlimited power of the churchwardens and overseers giving relief 'for their own private ends,' by which the charge on the parish was greatly increased, contrary to the true intent of the statute of Elizabeth. This act also gave power to the justices to order relief in cases of emergency, a provision which afterwards became a fruitful source of difficulty. The evils henceforth complained of were that many had thrown themselves on the rates who ought to have been supporting themselves independently of such aid; that pauper labour was found interfering with and displacing industrial labour; that the overseers were acting with unchecked dishonesty; and justices, with un- restrained liberality, ordering the money of the industrious and prudent to be spent upon the idle and improvident. Efforts were made to remedy these abuses throughout the reigns of the first three Georges, by making the justices act with the overseers, by rendering the overseers accountable to the parishioners by means of returns and the power of inspection, and by the offer of the workhouse to all applicants for relief. This last provision, made in the reign of George I. (1723), substituted what is called indoor relief for the allowance made to the poor at their own homes, and introduced the workhouse system. The workhouse established on Locke's suggestion by Carey at Bristol was one of the earliest. All who refused to be lodged in the house were to be struck off the poor's-roll and refused relief. A great increase in the number of workhouses took place; guardians were appointed to guard the pauper children from neglect and improper conduct, and other attempts to improve their administration made. Workhouse Unions were also introduced by Gilbert's Act, 1782, and a succession of acts passed for the protection of parish apprentices. Towards the close of the 18th century a great relaxation took place in the treatment of the poor. The famous Speenhamland Act of 1793 meant the establishment by justices of a minimum rate of wages. The 36th Geo. III., chap. 10 and 23 (1796), increased the amount, and extended the application for relief. It repealed the workhouse test, and allowed relief to be given in aid of wages. Henceforth outdoor relief became the rule under a variety of systems, which practically turned the poor-laws into a mode of paying wages. In 1801 the amount of the rates was reckoned at £4,000,000. In 1820 it had risen to £7,330,254, the justices being now the 'rating' as well as the 'relieving' authority.
In 1817 a commission of the House of Commons stated their opinion, that, unless checked, the assessment would swallow up the profits of the land. Though the two Vestry Acts, which resulted from the commission appointed in 1817, seem to have done something to remedy the evils complained of, a new commission to inquire into the operation of the poor-laws was found necessary, and appointed in February 1832. The evidence brought before this commission, with which the names of Bishop Blomfield, Sturges-Bowme, Edwin Chadwick, and Nassau Senior are always connected, revealed a disastrous state of things. The independence, integrity, industry, and domestic virtue of the lower classes were in some places nearly extinct. The great source of the evil was shown to be the relief afforded to the able-bodied in aid of wages. This aid at first reduced the expenditure in wages, and found favour with farmers and magistrates, who framed scales of relief in accordance with the wants of the people. Five modes of outdoor relief were found in operation: (1) Relief without labour; (2) allowance given, in aid of wages, according to the number of the labourer's family; (3) the Roundman system, the labourers being let out by the parish, among the employers round; (4) parish work, generally on the roads; (5) the labour-rate, the ratepayers preferring to divide among them the pauper labour, and to pay for it, however valueless, instead of raising a rate. Diminished industry ate away the very root of capital. Farmers turned off their men, or refused to employ them at fair wages, thereby causing a surplus of unemployed labour; they then took them back from the parish at reduced wages, paid out of the rates. From parish after parish came the reply to the queries of the commissioners: 'All our able-bodied labourers receive allowance.' No poor man in such parishes could save; if it was known that he had a fund of savings 'he would be refused work till the savings were gone,' and he had come down to the pauper level. In many places panperism swallowed up three-fourths of the rent. Nor was the maladministration confined to the rural districts; it extended all over the country, and into the manufacturing towns, where outdoor relief was a source of constant imposture. The administration of indoor relief was also full of abuses, from want of classification, discipline, and employment. Better food and lodging were provided for idle paupers than working-people could procure—better, even, than could be afforded by many of the ratepayers.
In 1834 the commissioners reported that they found the administration 'opposed to the letter and spirit of the law, and destructive of the welfare of the community.' The commissioners laid down the principle that the condition of the pauper ought to be below the lowest condition of the independent labourer, because every penny bestowed in rendering his condition more eligible is a bonny on indolence and vice, and recommended (1) the cessation of outdoor relief; (2) a central authority to control the administration; (3) unions for the better management of workhouses, and the classification of their inmates; and (4) a complete and clear system of accounts. The bill embodying these recommendations was brought in, March 17, 1834, passed its second reading in the House of Commons with only twenty dissenting votes, and became law on the 14th August as the 4th and 5th Will. IV. chap. 76. This act was not a change of law, but of administration. The orders of the new board restricted overseers, on the formation of a union, to the collection of rates; appointed paid relieving-officers to dispense relief under the directions of the unpaid Boards of Guardians; required the gradual withdrawal of outdoor relief; and enforced classification and discipline in the workhouses. A rapid formation of unions took place under the new board. In the first eight months 112 were formed including 2066 parishes. The pauperised districts experienced a great and immediate relief, numbers of paupers going off when they found that relief involved adequate work or the strictly-disciplined workhouse; wages rose, and the expenditure was reduced on an average 20 per cent. At the accession of George I. in 1714 the poor-rates amounted, as nearly as can be estimated, to £950,000, equal to 3s. 3d. per head on the population of 5,750,000. At the accession of George III. in 1760 the population had increased to 7,000,000, the poor-rates to £1,250,000—an average of 3s. 6d.; while in 1834 the population, estimated from the last census, was 14,372,000, and the money expended in relief £6,317,255—equal to 8s. 9d. per head. In three years the operation of the Amendment Act had reduced the expenditure one-third—viz. to £4,044,741. In 1848 the commissioners were exchanged for a public board, which became one of the government departments, with a president, in whom was vested the power of the commissioners, and who held office as one of the ministers of the crown. Finally, in 1871, the Poor-law Board was abolished, and its powers transferred (with various other powers) to a new body, the Local Government Board (q.v.), which accordingly became the central authority for England and Wales in regard to poor-law administration. The commissioners were unable to withdraw outdoor relief, which continues to be in England the most important item. With the aged, the sick, and orphans the guardians deal at their discretion; but stringent rules for the relief of the able-bodied are in operation under the board, whose orders have the force of laws. In the rural districts guardians are prohibited from giving relief to the able-bodied out of the house, unless under a supplemental order in emergency. For other places the general rule forbids relief to be given in aid of wages, and requires work to be supplied. Exceptions are made by the board on the application of the unions when necessity arises. The expenditure is strictly guarded and examined by public auditors. A district medical officer, of whom one or more are appointed for each union, attends to all cases of sickness among the poor.
The fundamental rule adopted as to the relief of the poor was that each parish in England and Wales is bound to maintain its own poor. Overseers are required to be appointed in each parish every year; and these (till 1894, along with the churchwardens, till then ex officio overseers) have to provide the requisite funds. This is done by means of a poor-rate, which the churchwardens and overseers may levy on all the occupiers of land in the parish, after such rate has been confirmed by the justices. The rate specifies a certain sum in the pound which is to be levied, and the annual value of the various lands is then specified. The rate is thus a local tax on the occupier of the land, and not on the owner, unless he himself is also occupier. Owing to the mischiefs arising from the officials of each parish distributing the funds at their discretion, without uniformity of plan, authority was given to combine various parishes into one poor-law union, and a central controlling power was created in 1834 in the shape of the Poor-law Board, now the Local Government Board. When a union is formed the control of the expenditure is chiefly vested in the guardians of this union, who are elected by each parish, and who supervise the management of the union workhouse. They order the overseers of each parish to raise their due proportion of funds by a contribution order issued to such overseers, who are thereon bound to levy the amount by including it in the next poor-rate. The guardians are bound to contract for the provisions, clothing, fuel, &c. supplied to the workhouse, by means of sealed tenders, unless the quantity is less than a stated amount. The guardians profess only to relieve destitution already existing, and not to enable persons to keep off impending destitution. Hence they only supply the bare necessities of life. They cannot, for example, advance or lend money to set up a poor person in trade.
Minute regulations are contained in the consolidated poor-law orders of the Board as to the classification of paupers in the workhouse, mode of admission, diet, discipline, and outdoor relief. It is provided that every able-bodied person requiring relief from any parish shall be relieved wholly in the workhouse, together with his wife and family, if any, and if not otherwise employed. But the relief may be given out of doors in cases of sudden and urgent necessity, of sickness, accident, and a few other cases. In general relief is confined to persons actually residing in some place within the union, except in case of casual destitution, or sickness and accident. Whenever outdoor relief is given to an able-bodied person half of it is to be in the form of articles of food or fuel. Relief is given only weekly where the pauper is not required to be received into the workhouse. No relief is to be given to able-bodied persons while they are employed for wages or hire by any person; and every able-bodied male person, if relieved out of the workhouse, shall be set to work by the guardians, and kept so employed while he continues to receive such relief. Wherever a person applies for parochial relief, if he or she has a father or grandfather, mother or grandmother, or child, who is able to maintain such pauper, the parish officers can obtain an order from justices to compel such relative to contribute a sum towards such maintenance. In some cases the guardians or overseers may employ the poor in public works; but this is seldom done except on occasions like the Lancashire distress. The law as to the settlement of the poor is somewhat intricate, and gives rise to much litigation. There are various grounds on which this settlement is acquired. Thus, every person has, prima facie, a settlement in the parish where he was born, until some other is proved; and there are so many other qualifications that it is seldom a birth-settlement is resorted to. By marriage a woman immediately acquires the settlement of her husband, if he has one, whether the husband be an Englishman or a foreigner. If the husband has no settlement, then the wife is thrown back on her maiden settlement. If any person shall be bound an apprentice by indenture, and reside forty days under such apprenticeship, or has resided three years in a parish, or shall rent a tenement in a parish, and actually occupy the same, and be rated to the poor for one whole year, the rent being not less than £10, and paid by the person so actually occupying the tenement, or shall acquire an estate in land, however small in value, and reside forty days in the parish, or shall buy an estate, and the consideration amount to £30 at least, he shall by any of these methods acquire a settlement. Unless a pauper has acquired a settlement in the parish or union where he receives relief, he is liable to be removed compulsorily to the parish where he last acquired a settlement. Paupers who have resided for one whole year in the parish or union in which they became destitute cannot, however, be removed. The general expense of maintaining the poor is paid out of the common fund, and not by each parish in the union. When a pauper is sought to be removed it is necessary to take him before two justices of the peace for examination; and, on proper evidence of his settlement, the justices will make the order of removal, which is an authority to the overseers to take or send the pauper to the overseers of the parish of settlement. If, however, the pauper is too ill at the time to admit of removal without danger, the justices may suspend the order of removal till he is recovered. Whenever a pauper is to be removed the removing union is bound to give notice to the union of settlement; and it is on these occasions that so many obstinate and costly litigations take place as to which is the union of settlement. The union also may appeal to the court of quarter sessions against the removal order; and the quarter sessions may state a case for the opinion of the Court of Queen's Bench, if any nice point of law should arise, as frequently happens. This evil of litigation was greatly diminished by the Union Chargeability Act of 1865. The Local Government Act of 1894 left the administration of the poor-laws of England with the guardians and overseers. But churchwardens ceased to be ex officio overseers; the parochial electors appoint the guardians, and the parish council appoints the overseers, additional ones being appointed in place of the churchwardens.
Scotland and Ireland have been legislated for separately. Their poor-laws are similar to the English in principle and practice; both are administered by a central board, which supervises the local bodies charged with relief, and in both the rate is levied on the annual value of real property. In Scotland the usual early legislation was passed against sturdy beggars and vagabonds. A system of assessment by the owners in each landward (i.e. non-urban) parish was set up in 1579 and 1663, and the general policy of the poor-laws was stated in proclamations by the Privy-council in the end of the 17th century. Until the 19th century, however, the poor in most parishes were supported out of the voluntary collections at the parish church, administered by the heritors and kirk-session. In spite of the opposition of Dr Chalmers, a new system was instituted in 1845. Relief was administered by a parochial board, appointed by the ratepayers, the burgh magistrates, and the kirk-session; and the board appointed 'inspectors of the poor' as relieving-officers. The Scots law differs from the English and Irish in allowing no relief to able-bodied adults. Claimants must be aged, infirm, or disabled. Outdoor relief is the rule. In 1845 a central board was established, called the Board of Supervision, controlling the parochial board of each parish like the Local Government Board in England, though with less extended powers—thus, although parochial boards might combine to build workhouses, there are no unions, properly so called, in Scotland. A settlement can be acquired in Scotland by residence of five years. Children follow the settlement of their parents, and wives that of their husbands; and if no other settlement be proved, then the settlement of birth is liable. In Scotland the poor-rate, except in a few cases where the local usage established in 1845 is followed, is universally imposed equally upon owners and occupiers according to the annual value of the houses, works, farms, mines, &c., by which is meant the net annual value, after allowing for repairs, insurance, and other expenses, and not the gross annual value appearing in the valuation-roll. Each parochial board, however, may exercise an important power of classifying subjects according to the use to which they are put, and giving appropriate deductions from annual value. The tendency of this system is to approach an assessment imposed upon probable income, the older assessment in Scotland having frequently been laid on means and substance. The parochial boards, originally created solely for administering the poor-laws, were gradually utilised for carrying out the law as to burial-grounds, the registration of births, deaths, and marriages, vaccination, public health, and public libraries. The Local Government (Scotland) Act of 1894 (unlike the English act) transferred the powers and responsibilities of the parochial boards to the newly constituted Parish Councils; and in Scotland the administration of the poor-laws, especially of the great act of 1845, is the most important duty of the Parish Council. At the same time the Board of Supervision is abolished, and its powers transferred to the Local Government Board for Scotland, a semi-independent body being thus superseded by a state department (in Edinburgh, as before). The Secretary for Scotland is president of the board, which through him is responsible to parliament.
In Ireland the Poor-law Act was passed for the first time in 1838, and numerous amending statutes have followed, the code of laws being substantially founded on the English acts. Each union has a workhouse managed by a Board of Guardians elected by the ratepayers. Every destitute person has an absolute right to relief, which is administered almost entirely in the workhouse. The Local Government Act of 1898 made no essential changes. There are special acts of parliament regulating the conditions on which paupers are removable between England, Scotland, and Ireland respectively.
In recent times a new policy has been devised, and in the German empire carried into practical effect, of providing against the evils which the poor-law is intended to alleviate. This policy is generally known as that of compulsory insurance. The German law of 13th June 1883 on sickness insurance was followed by that of 6th July 1884 on accident insurance, and that of 22d June 1889 on insurance against permanent disability and old age. Compulsory contributions are collected, to which the workman, the employer, and the state are all parties. The disability pension is given after five years' payment, the old age pension after thirty years' payment and after the age of sixty. Where the wages are below 350 marks the contribution is 14 pfennige per week. The disability pension starts from a minimum of 60 marks, to which the state adds 50 marks, the balance depending on the number of weekly contributions made. The old age pension is only 106.40 marks, or about £5, 10s. for the lowest class of salary. The grave difficulties of this scheme (which came into operation on 1st January 1891) are sufficiently obvious: (1) the workman has to keep a card-register all through life; (2) the employer has to submit to inspection, and to contribute a fixed sum for all wages under a certain figure; (3) the annual charge to the state is expected to exceed £4,000,000 sterling.
A comparison of the statistics of poor-law administration for England and Wales in 1872 and 1889 is interesting and encouraging. In 1872, the population (1871) of England and Wales being 22,712,266, there were 977,200 paupers, of whom 150,930 were able-bodied adults. The total cost of poor relief was £8,007,403, while the rateable value of property assessed was £107,398,242. In 1889, the population (1891) being 29,081,017, the corresponding figures were: paupers, 817,190, of whom 104,817 were able-bodied adults: cost, £8,232,472; property assessed, £139,636,307. The burden had diminished from 1s. 5½d. to 1s. 1¾d. per £1 (see VAGRANTS).
In Scotland in 1890, the population (1891) being 4,025,647, the paupers were 92,324; the expenditure, including buildings, was £874,389, contributed to the extent of 76.8 by assessment, and grants in aid 17.6, being at the rate of 4s. 4d. per head of population, and 1s. 6d. lower than in England. The cost of the lunatic poor rapidly increases. In Ireland, the population in 1891 being 4,706,162, the average daily number, in 1890, of paupers in the workhouses was 43,536, and on outdoor relief 62,286, together 105,822. In 1889 the total expenditure on poor relief was £853,912. It would be misleading to draw inferences from these figures with respect to the condition of the respective countries, as the practical details of poor relief vary greatly.
In America the system is on the whole similar to the British. Every man is entitled by law to relief from the town of his settlement, the rate being assessed on whole towns, and not on parishes. The states have their own poor-laws, but paupers are removable from one state to another. Thus, in Massachusetts the unit of poor-law administration is the town or city, comprising in each case the surrounding rural district; while in New York the unit, generally speaking, is the county. These areas bear the burden of the settled poor; the unsettled poor (including Indians) are a charge upon the state. In New York one year's residence is sufficient to constitute a settlement. The policy in Massachusetts has been to encourage outdoor relief as being more economical, and for this reason to facilitate settlement. Any American becoming a pauper loses his state rights. The acts concerning Workhouses and Paupers in the Revised Code of Massachusetts may be taken to represent generally the state of the law throughout the Union. The former provides 'that any town may erect or provide a workhouse for the employment and support of all poor and indigent persons that are maintained by, or receive alms from, the town; all persons who, being able to work, and not having means to maintain themselves, refuse or neglect to work; all persons who live a dissolute vagrant life, and exercise no ordinary calling or lawful business; and all such persons as spend their time and property in public-houses, to the neglect of their proper business, or by otherwise mis- spending what they earn, to the impoverishment of themselves and their families, are likely to become chargeable to the town or the commonwealth.' The idle and the vagrant may be committed to the workhouse, and kept to labour, as in a house of correction. There are provisions for enforcing the claims of kindred and for the immediate relief of strangers. The administration is in the hands of overseers, but the counties elect superintendents, holding office for three years, who are again responsible to a Board of Supervisors. The New York State Board of Charities contracts with the counties for the housing in almshouses of certain classes of the state poor. The State Boards have large general powers of supervising the whole charitable, reformatory, and correctional system of the commonwealth, and report annually to the legislature on such questions. These boards are mainly nominated by the governor. Their functions and the results achieved are described in Mr Sanborn's Report to the Massachusetts Centennial Commission, 1st February 1876, and in the Report by Mr Henley to the Local Government Board in June 1877 (Parliamentary Papers, vol. xxxvii.), on the Poor-laws of certain of the United States, and on the combination there of private charity with official relief. The Massachusetts state workhouse and almshouse are at Bridgewater and Tewksbury respectively; the most important establishment in New York state is on Blackwell's Island. Generally the American system is marked by a high degree of classification, variety of work, special educational methods, and liberal treatment in the matter of diet. In the city of Boston, under special statutes, the authority of overseers is largely superseded by a 'Board of Directors for Public Institutions.' The former practice of levying a small poll-tax on poor immigrants was decided by the case of Henderson v. Wickham (1876) to be illegal. With reference to the efforts made by voluntary associations to assist and develop the working of the poor-law in America, Mr Henley reports that this cannot properly be done except under a well-considered regulation having the force of law, and a paid staff of officers acting under the orders of representative and responsible administrators, controlled by independent auditors.
There is no poor-law in the Australian colonies, but benevolent asylums for the infirm and destitute have become general, and hospitals are numerous in all the rising towns.
See Sir F. M. Eden, The State of the Poor (1797); Böckh's Public Economy of Athens, translated by Sir G. C. Lewis (2d ed. 1842); Sir George Nicholls, History of the Poor-laws (1854-56); Emmingham, Das Armenwesen und die Armengesetzgebung in den europäischen Staaten (Berl. 1870); Poor Relief in different parts of Europe, revised by E. B. Eastwick (1873); Fowle, The Poor-law (1882; new ed. 1890); Glen, The Poor-law Statutes (1873-79), and General Orders of the Poor-law Commissioners (10th ed. 1887); Archbold, The Poor-law (new ed. 1886); for Scotland, the Digests of Smith (1880) and Reid (1880); Mills, Poverty of the State (1887); Jessopp, Archaic (1887); Aschrott, The English Poor-law System, Past and Present (trans. 1888); Cowen, The Poor-laws of the State of New York (Albany, 1887); works on the poor-law of France by Reitzenstein (Leip. 1881), of Germany by Münsterberg (1887), and of Austria by Mischler (1890); First and Sixth Reports of the Poor-law Commission (1834 and 1839), Annual Reports of Poor-law and Local Government Boards; Reports on Poor-laws in Foreign Countries in Parliamentary Papers, 1875; the works on the poor by Mr Charles Booth (1891-97); Gertrude Lubbock, Some Poor Relief Questions (1895); W. Chance, The Better Administration of the Poor-laws (1896); and in regard to old age pensions, the majority and minority reports (1895) of the commission appointed in 1893; and G. Drage, The Problem of the Aged Poor (1896); also the articles on CHARITY, INSANITY, INSURANCE, MENDICANCY, VAGRANTS, WORKHOUSE.