in England of enforcing liability under a guarantee is by action in the High Court or a County Court. It is also permissible for the creditor to obtain redress by means of a set-off or counterclaim, in an action brought against him by the surety. On the other hand, the surety may now, in any court in which the action on the guarantee is pending, avail himself of any set-off which may exist between the principal debtor and the creditor. Moreover, if one of several sureties for the same debt is sued by the creditor or his guarantee, he can, by means of a third-party complaint, claim contribution from his co-sureties towards the common liability. Independent proof of the surety's liability under his guarantee must always be given at the trial. The creditor cannot rely on admissions made by or a judgment or award against the principal debtor. A person liable as a surety for another under a guarantee possesses rights against the person to whom the guarantee was given. As regards the surety's rights against the principal debtor, where the guarantee was made with the debtors consent but not otherwise, after he has made default, be compelled by the surety to exonerate him from liability by payment of the guaranteed debt. If the surety has paid any portion of the guaranteed debt, the surety is entitled to rank as a creditor for the amount paid and to compel repayment. In the event of the principal debtor's bankruptcy, the surety can in England act against the bankrupt's estate, not only in respect of payments made before the bankruptcy of the principal debtor, but also, it seems, in respect of the contingent liability to pay under the guarantee. If the creditor has already acted, the surety who has paid the guaranteed debt has a right to all dividends received by the creditor from the bankrupt in respect to the guaranteed debt, and to stand in the creditor's place as to future dividends. The rights of the surety against the creditor are in England exercisable even by one who in the first instance was a principal debtor, but has since become a surety, by arrangement with his creditor. Rights of surety against the creditor The surety's principal right against the creditor entitles him, after payment of the guaranteed debt, to the benefit of all securities which the creditor held against the principal