standard of highness chosen, so will it be said that fishes have advanced or retrograded in organisation. To attempt to compare members of distinct types in the scale of highness seems hopeless; who will decide whether a cuttle-fish be higher than a bee — that insect which the great Von Baer believed to be “in fact more highly organised than a fish, although upon another type?” In the complex struggle for life it is quite credible that crustaceans, not very high in their own class, might beat cephalopods, the highest molluscs; and such crustaceans, though not highly developed, would stand very high in the scale of invertebrate animals, if judged by the most decisive of all trials — the law of battle.

Beside these inherent difficulties in deciding which forms are the most advanced in organisation,