The recent case of Ralston v. Ralston presents the question: What kind of conduct on the part of the husband will be construed as a tort to the wife's separate property so as to entitle her to sue her husband? In that case the parties were living apart under a deed of separation, executed in 1899. The alleged defamatory words, the action being libel, were contained in an inscription (referring to another woman) on a tombstone, erected by the defendant husband, which read: "In loving memory of Jennie, the dearly beloved wife of W. R. C. Ralston . . . . Died May 20th, 1916." Held, that even though the inscription was capable of a defamatory meaning, as intimating that the plaintiff was not the defendant's lawful wife, the wife could not sue her husband under the Married Women's Property Act, since the action was for a personal tort, and not for the protection and security of her separate property.