unsettled state. Matrimonial obligations and the rights of succession in cases of intestacy had fallen into hopeless confusion, and the adjudication of disputes in relation thereto was effected by certain elders of the community, who had neither the knowledge and help of fixed principles to guide their judgments, nor any authority to enforce their decisions. The case of Ardesir Cursetjee v. Peeroxebai, which came up on appeal before the privy council in England, brought to light the strange fact that even the supreme court of Bombay had no jurisdiction over matrimonial and ecclesiastical disputes among Parsees. This state of lawlessness was recognized by that community as intolerable, and the agitation which ensued thereupon led to the appointment of a commission, of which the distinguished jurist, Sir Joseph Arnould, was the president and Framjee Patel the chief Parsee member. The Parsee Law Association, under the guidance of Patel and Sorabjee Bengallee, rendered invaluable help to the commission, and their joint efforts resulted in the passing by the government of India of the Parsee Marriage and Divorce Act and the Parsee Intestate Succession Act (15 and 21 of 1865). These acts form the charter of matrimonial and ecclesiastical status for the Parsees. At the time of his death in 1894, at the ripe age of nearly ninety years, Framjee Patel was the most revered and best beloved of the distinguished natives of India, having during an eventful public life extending over sixty years worked in co-operation with three generations of the most prominent of his compatriots to better the condition of their country. His family surname refers to the title of Patel, that is, "mayor," of Bombay, conferred on its founder for services rendered to the English in 1692. References 1804 births 1894 deaths Parsi people from Mumbai Businesspeople from Mumbai