part taken by the Board in deciding appeals upon hearings held before it. 160 These hearings were not confined to the adversarial arguments; in addition to hearing the parties, their representatives, and counsel, the Board in formulating its judgment might rely upon information about local law supplied by the island judiciary. 161 Sometimes the Council might act ex parte, reversing upon petition of the appellant for failure of respondent to appear, 162 or upon respondent's petition, dismissing an appeal for failure to prosecute. 163 The Council also made interlocutory disposition of causes without consultation with any other body. These dispositions were made for various reasons and in different ways. Upon application of appellants, causes were referred back to the islands for rehearing or review. 164 Where the sole issue was one of fact, the Board ordered Jersey commissioners to examine witnesses and to return a certificate on the disputed point so that further action could be taken. 165 Or where a cause could not be fitly examined in Council, it might be referred back to the island judiciary. 166 A similar reference might be made be better prepared to advise the King. Matters ecclesiastical were referred to the Archbishop of Canterbury and the Bishop of Winchester (ibid., 1618-19, 84)- 160 See Hue v. Lempriere (ibid., 1616-17, 128); Messervy v. Mattingly (ibid., 1618-19, 230); Rex v. Baillehache (ibid., 1619-21, 265); Langlois v. Messervy (ibid., 1621-23, 241); Oliver v. Jacquett (ibid., 1623-2s, 192); cf. ibid., 1613-14, 604, 621, where original jurisdiction in a dispute as to the office of bailiff in Jersey was assumed, but upon hearing it was ordered that the matter be brought before the Chief Justice. 161 Langlois v. Messervy (ibid., 1621-23, 241), where the Council stated that it was evident from letters from the greater number of the Royal Court that plaintiff-respondent by the law and custom of Jersey could not be put to his oath in this case, as claimed by appellant. 162 Rex v. Dumaresq (ibid., 1619-21, 280); de Rues v. Langlois (ibid., 1621-23, 319). 163 Rex v. Fiot, ibid., 1623-2s, 196 (appeal declared void upon respondent's allegation that it was not prosecuted within three months and no cause shown for delay). 164 Herault v. Auley, ibid., i6is-i6, 290 (allegation that the cause was heard by too few jurats, ordered reheard in the presence of all or most of the Royal Court); Kellett v. Dumaresq, ibid., 1619-21, 323 (allegation that respondent "takeinge advantage of an imperfect verdict, contrary to equitie, and before the whole legall separacion of the premisses was tryed, caused the said verdict to be approved in a waste paper by the bailiff and some jurates there, to the great hurt and losse of him the said appellant," ordered a review made by twenty-four impartial persons chosen by both parties). Cf. the action upon the petition of Elias Dumaresq ordering Elias de Carteret et al. to call before them the petitioner, and one Duhamell, and to re-examine upon interrogatories the witnesses formerly produced in an assault suit. If these commissioners found that Duhamell had injured the petitioner, they were to cause him to make satisfaction, or otherwise to report to the Board the true state tiiereof with their opinion (PC 2/46/81). 165 In Hue v. Renouf (APC, Dotn., 1621-23, 42) it was stated that "appealant produceth a certificate under the handes of 4 witnesses by which he endeavoureth to prove the sentence to be erroneous and the defendant hath the handes of divers of the jurattes which he hath gotten since the appeale certifieing the contrary." Thereupon, commissioners were ordered to call before them the above four witnesses and any others the parties produced and by interrogatories in writing take examinations on oath as to two stated issues. 166 In Messervy v. Godfrey (ibid., 1621-23, 144) the sentence appealed from concerned the full performance of a contract between the parties. This contract "consistedi of many particulars which cannot fitly be examined here, the same requiring a personall view and judgement." So the Royal Court by consent