Part 1. Of the sovereignty and people of the state, and of the political rights and duties of all persons subiect to its jurisdiction. 2. Of the chief political divisions, seat of government, and legal distances of the state. 3. Of the government of the state. 4. Of the government of counties, cities and towns. 5. Of the definitions and sources of law; the common law; the publication and effect of the codes; and the express repeal of the statutes." The constituents of this section are congruous as parts of a political system. But in less comprehensive legislation, the subject or object may admit of joining only the topics in one of these subdivisions. So in legislating still more in detail, the subject may be so circumscribed that even two topics in one subdivision would render the act multifarious.42 The constitution does not enumerate the integers of statutory law, and therefore the legislature may make such divisions as it thinks proper, if it confines each act to a single subject; nor is it any objection, under this clause of the constitution, that an act does not dispose of the whole subject to which it relates.43 The supreme court of California, in a recent case, in discussing an act entitled "An act to revise the code of civil procedure of the state of California, by amending certain sections, repealing others, and adding certain new sections," expressed itself as follows upon the subject of general titles: "We cannot agree with the contention of some of respondent's counsel - apparently to some extent countenanced by a few authorities-that the provision of the constitution in question can be entirely avoided by the simple device of putting into the title of an act words which denote a subject 'broad' enough to cover everything. Under that view 'An act concerning the laws of the state' would be good, and the convention and people who framed and adopted the constitution would be convicted of the folly of elaborately constructing a grave constitutional limitation of legislative power upon a most important subject, 42 Grover v. Trustees, etc., 45 N. J. L. 399. 43 Davis v. State, 7 Md. 158. which the legislature could at once circumvent by a mere verbal trick. The word 'subject' is used in the constitution in its ordinary sense; and when it says that an act shall embrace but 'one subject' it necessarily implies what everybody knows that there are numerous subjects of legislation, and that only one of these subjects shall be embraced in any one act. All subjects cannot be joined into one subject by the mere magic of a word in the title. Nearly all of our general laws are arranged, for convenience, under four main headings, or names, to wit: the Civil Code, the Code of Civil Procedure, the Penal Code, and the Political Code, but no one of these codes is complete in itself; legislation under either code is inseparably interwoven with legislation under the others; and legislation upon any imaginable subject would not be held invalid because found in any particular code. . . . How, then, can it be rightly said that a mere reference in the title of an act to the Code of Civil Procedure - or to any other code-expresses any subject? If so, what subject? If the reference had been merely to 'civil procedure'— if it had been 'An act concerning civil procedure,' — it is doubtful if it would have been in accordance with the clear intent of the constitution as to one subject. There is no definition in our laws of 'procedure,' nor can any satisfactory definition of it be found in the general authorities. .. But,. as before stated, the title merely refers to one of our codes, and, considering the multifarious character of the codes, it expresses no subject whatever." On the other hand the supreme court of Minnesota, in affirming the validity of an act entitled "An act to establish a probate code," which contained twenty-one chapters and three hundred and twenty-six sections, and embraced wills, descent of real and personal property, administration of estates of deceased persons, and all the various matters. usually cognizable in probate courts, says: "Again, while 44 Lewis v. Dunne, 134 Cal. 291, 66 Pac. 478, 86 Am. St. Rep. 257, 55 L. R. A. 833. And see Trumble v. this provision is mandatory, yet it is to be given a liberal and not a strict construction. It is not intended nor should it be so construed as to embarrass legislation by making laws unnecessarily restrictive in their scope and operation, or by multiplying their number, or by preventing the legislature from embracing in one act all matters properly connected with one general subject. The term 'subject,' as used in the constitution, is to be given a broad and extended meaning, so as to allow the legislature full scope to include in one act all matters having a logical or natural connection. Any construction of this provision of the constitution that would interfere with the very commendable policy of incorporating the entire body of statutory law upon one general subject in a single act, instead of dividing it into a number of separate acts, would not only be contrary to its spirit, but also seriously embarrassing to honest legislation. All that is required is that the act should not include legislation so incongruous that it could not, by any fair intendment, be considered germane to one general subject. The subject may be as comprehensive as the legislature chooses to make it, provided it constitutes, in the constitutional sense, a single subject, and not several. The connection or relationship of several matters, such as will render them germane to one subject and to each other, can be of various kinds, as, for example, of means to ends, of different subdivisions of the same subject, or that all are designed for the same purpose, or that both are designated by the same term. Neither is it necessary that the connection or relationship should be logical; it is enough that the matters are connected with and related to a single subject in popular signification. The generality of the title to an act is no objection, provided only it is sufficient to give notice of the general subject of the proposed legislation and of the interests likely to be affected. The title was never intended to be an index of the law." 45 45 Johnson v. Harrison, 47 Minn. 575, 50 N. W. 923, 28 Am. St. Rep. 382. And see City Council v. Birdsong, 126 Ala. 632, 28 So. 532. The following general titles were sustained in recent cases, the acts in each case being as comprehensive as the title would indicate: "An act to revise, amend and codify the statutes in relation to crimes and their punishment; " "An act relative to crimes and punishments and proceedings in criminal cases;"""An act to provide a system of revenue." 48 If a restrictive title is chosen the act must be kept within it.49 § 118 (85). The provisions of an act must be germane to one subject.- Whatever may be the scope of an act, it can embrace but one subject, and all its provisions must relate to that subject; they must be parts of it, incident to it or in some reasonable sense auxiliary to the object in view. That subject must be expressed in the title of the act. The constitutional requirement is addressed to the subject, not to the details of the act. The subject must be single; the provisions, to accomplish the object involved in that subject, may be multifarious.50 It is a matter of some difficulty, in many instances, to determine precisely what is the subject of an act by reason of the contrariety of its provisions and the complexity of its machinery and aims. All acts are not methodically framed; they do not always declare directly the subject or ultimate end in the enacting part, and then define its constituents and adjuvants, so that the coherence and subordination of the parts, and their relation to a subject in which they converge, can be at once perceived. In the body of an act the subject in which the operation of all the details unite, or are intended to unite, is not unfrequently left to inference. If it can be made out by construction, is 46 Cook v. Marshall County, 119 Iowa, 384, 93 N. W. 372. 47 State v. Tieman, 35 Wash. 294. The legislature may make the title as comprehensive as it sees fit. Marston v. Humes, 3 Wash. 267, 28 Pac. 520. 48 Rosenbloom v. State, 64 Neb. 342, 89 N. W. 1053. 49 Mitchell v. Colo. Milling & El. Co., 12 Colo. App. 277, 55 Pac. 736; In re Breene, 14 Colo. 401, 24 Pac. 3. 50 Block v. State, 66 Ala. 493; Ingles v. Strauss, 91 Va. 209, 21 S. E. 490. 52 single, and embraces all the provisions of the act, it is enough so far as the purview is concerned. The statement of the subject in the title when correctly and comprehensively expressed will furnish a key to the intended unity of the enacting part. The whole act can be valid only when the subject so stated includes all the provisions in the body of the act. None of the provisions of a statute will be held unconstitutional when they all relate, directly or indirectly, to the same subject, have a natural connection, and are not foreign to the subject expressed in the title.53 As very frequently expressed by the courts, any provisions that are germane to the subject expressed in the title may properly be included in the act." "The constitutional provision is to 51 State v. Tucker, 46 Ind. 355; State v. Young, 47 Ind. 150; Robison v. Miner, 68 Mich. 549, 37 N. W. 21. 52 Montgomery M. B. & L. Ass'n v. Robinson, 69 Ala. 413; Ex parte Pollard, 40 Ala. 99; Grover v. Trus tees, etc., 45 N. J. L. 399; Shivers v. Newton, 45 N. J. L. 469; Ryerson v. Utley, 16 Mich. 269; State v. Bradt, 103 Tenn. 584, 53 S. W. 942. 53 Howland Coal & Iron W. v. Brown, 13 Bush, 685; Phillips v. Bridge Co., 2 Met. (Ky.) 222; Louisville, etc. Co. v. Ballard, 2 Met. (Ky.) 168; Chiles v. Drake, 2 Met. (Ky.) 150, 74 Am. Dec. 406; Johnson v. Higgins, 3 Met. (Ky.) 566. 54 Barnhill v. Teague, 96 Ala. 207, 11 So. 444; Hawkins v. Roberts, 122 Ala. 130, 27 So. 327; Edwards v. Denver & R. G. R. R. Co., 13 Colo 59, 21 Pac. 1011; Catron v. County Com'rs, 18 Colo. 553, 33 Pac. 513; Jones v. Aspen Hardware Co., 21 Colo. 263, 40 Pac. 457, 52 Am. St. Rep. 220, 29 L. R. A. 143; County Com'rs v. Jacksonville, 36 Fla. 196, 18 So. 339; Atlanta v. Gate City St. Ry. Co., 80 Ga. 276, 4 S. E. 269; Newman v. State, 101 Ga. 534, 28 S. E. 1005; Hundall v. Hain, 172 Ill. 76, 49 N. E. 985; Rushville Gas Co. v. Rushville, 121 Ind. 206, 23 N. E. 72, 16 Am. St. Rep. 388; State v. Gerhardt, 145 Ind. 439, 44 N. E. 469; Gaines v. Williams, 146 Ill. 450, 34 N. E. 934; Pittsburgh, Cinn., Chicago & St. L. Ry. Co. v. Montgomery, 152 Ind. 1, 49 N. E. 582, 71 Am. St. Rep. 201; Rogers v. Jacob, 88 Ky. 502, 11 S. W. 513; Raubold v. Commonwealth, 21 Ky. L. R. 1125, 54 S. W. 17; County Com'rs v. Hellen, 72 Md. 603, 20 Atl. 130; Fort St. Union Depot Co. v. Morton, 83 Mich. 265, 47 N. W. 228; Sligh v. Grand Rapids, 84 Mich. 497, 47 N. W. 1093; Ripley v. Evans, 87 Mich. 217, 49 N. W. 504; McPherson v. Blacker, 92 Mich. 377, 52 N. W. 469, 31 Am. St. Rep. 587, 16 L. R. A. 475; People v. Huntley, 112 Mich. 569, 71 N. W. 178; McMorran v. Ladies of the Maccabees, 117 Mich. 398, 75 N. W. 943; Crawford v. Ross, 126 Mich. 634, 86 N. W. 132; State v. Board of Com'rs, 67 Minn. 352, 69 |