Parvin

The main question argued in this case, and the one upon which we think the decision must turn, is whether the act of 1880, entitled “An act to amend section 3481 of the Political Code,” is in violation of section 24 of article 4 of the constitution, which provides that “Every act shall embrace but one subject, which subject shall be expressed in its title.....” It is not contended that the act embraced more than one subject. The objection is that no subject is expressed; and the argument is that a section of the Political Code is not a subject, but is a mere reference to where the subject may be found.

The reason of the requirement that the subject shall be expressed is to prevent legislators being entrapped by false titles: Kurtz v. People, 33 Mich. 282 ; Boyd v. State, 53 Ala. 605 ; Hannibal v. Marion, 69 Mo. 575 ; Robinson v. Skipworth, 23 Ind. 317 ; Commissioners of Marion v. Commissioners of Harvey, 26 Kan. 197 ; Howell v. State, 71 Ga. 227 , 51 Am. Rep. 259 . This reason does not require the title to give the substance of the bill. To give the substance of the bill would be to make the title almost as cumbrous as the bill itself, which would tend to defeat rather than to…