Opinions vary widely as to the results, ranging from unqualified praise to equally vigorous denunciation. The Association Against the Prohibition Amendment (Lenox Building, Washington, D.C.) has published a series of pamphlets presenting results of favour able field studies of all the various forms of liquor control in the Canadian provinces. Reginald E. Hose in Prohibition or Control, Canada's Experience with the Liquor Problem., 1921-27, Ray mond B. Fosdick and Albert L. Scott in Toward Liquor Control (See app. II), give a comprehensive survey with favourable esti mate of results. Several other investigations, notably those of the Christian Science Monitor (a series of articles condensed and reprinted by the Christian Science Publishing Society, Bos ton, 1927, under the title : "Quebec Liquor Control System Proves Failure"), W. R. Plewman in the Outlook, May 19, 1926, entitled: "Canada's Experiments in Liquor Control," and Ben H. Spence of the Canadian Prohibition Bureau of Toronto (quoted by Prof. Irving Fisher and H. Brougham in Prohibition Still at its Worst, 1928) reach quite different conclusions.
Australia.—The licensing laws of Australia have generally followed the British model but have been less repressive. Queens land under the provisions of the Liquor Amendment Act of 192o has a triennial State poll under which a vote is taken on three issues, State control, State prohibition and continuance of ing. New South Wales and South Australia had a limited form of veto before the war, applying only to new licences, and a pro vision for the optional reduction of licences. Existing legislation in all six Australian states provides for local option concerning licence, in some cases applying to renewals, in others only to granting of new licences, and in all for or against a no-licence policy. All provide for a statewide poll every 5 to 8 years on prohibition, reduction in number of licences, or continuance, and in some states local option rights are practically modified by rea son of state-wide referendums which in recent years have gone against prohibition by small majorities and favoured continuance and reduction in number of licences.
New Zealand.—New Zealand had a licensing system with local option under the Alcoholic Liquor Sale Control Act of 1893 with a local vote on continuance of licence, reduction, and no licence, until 1910, then until 1918 on only two questions, con tinuance and no licence. Two special polls in 1919 voted continu ance, though prohibition received a plurality in one of them but not a majority, and to abolish local option. Since 1919 three statewide referendums have been held on prohibition without compensation, state purchase, and continuance. Prohibition had a plurality in two but continuance won by slender margin in all three.
1922 defeated a local option bill by seven votes. The high com missioner of South Africa has prohibited the importation of spirituous liquors into Swaziland except with the written per mission of the resident commissioner. A new licence act went into effect in 1928 and gave some local option and many special restrictions for special classes of natives.
The greatest variety of liquor legislation, based on diverse principles, and including every known type of legislative control, has existed in the United States. Licensing was the prevailing system before national prohibition went into effect but the other chief types of experiment, State prohibition, local option—a corn bination of licence and prohibition, and disinterested management of the liquor traffic under public dispensaries or State monopoly are well illustrated in the history of American liquor legislation. The Federal regulation of the liquor traffic in interstate com merce, Federal Territory, and by Federal tax laws, has played an important role. The thousands of statutes, State and Federal, and local ordinances, impossible of classification and summary within the limits of a single article, constitute an extensive and illuminat ing legislative experiment in social control that probably has no equal elsewhere.
State Prohibition.—In 1910 State-wide prohibition dating from 1846 in Maine was in force in nine States. Large areas of local territory in other States were dry under local option. It was difficult to protect this dry territory from violation through illicit trade aided and promoted in adjacent wet areas. Texas in 1910 passed a law making the sale of liquors in no-licence territory a felony punishable by from three to five years imprisonment. All the prohibition States tried in various ways to check the flow of liquor protected in interstate commerce over which the Federal authority had exclusive jurisdiction and with which no State had any constitutional right to interfere. Congress sought to aid this effort in the Wilson Act of 1890 to divest intoxicating liquors of their interstate character by providing that "Liquors transported into a state . . . shall . . . upon arrival in such state . . . be subject to the operation and effect of the laws of such state en acted in the exercise of its police powers, to the same extent . . . as though such . . . liquors had been produced in such state." Although the Wilson Act presented grave constitutional diffi culties it was sustained by the Supreme Court in In re Rahrer in 1898 (140 U.S. 545), but the rule of the decision interpreted the phrase "upon arrival in such State" to mean that State control and regulation operated only "after the shipment had reached its point of destination and had actually been delivered to the con signee." This was not sufficient to stop the flow of liquor from wet areas outside the State. A Missouri statute imposing an in spection fee on all liquors shipped from other States into Missouri and offered for sale was upheld in 1905 (r90 U.S. 17), by the Supreme Court and in Delameter v. South Dakota (205 U.S. 93), decided March 11, 1907, a South Dakota statute was upheld which put an annual licence charge upon the business of soliciting orders to be filled from liquors at the time without the State.