upon appeal. 178 There is a related question as to the procedure employed when 
reports of the legal advisers were received at the Council Table. Was there 
automatic approbation of the report, followed by the issuance of a conciliar 
letter enclosing or embodying the report? It is indicated that in some cases 
the report was debated at the Board. 179 The legal advisers sometimes reserved 
policy considerations for the decision of the Council; 180 they likewise evidenced 
a tendency to leave disputed questions of fact to the decision of that 
body. ISI Where there had been a tedious cause replete with numerous orders 
and references, the Board might in desperation finally decide to hold a full 
hearing of the matter before itself. 182 
The personnel of the legal adviser group underwent a change during these 
reigns. Under James the bulk of the references were directed to the Attorney 
General and the Solicitor General. 183 These officers frequently were still 
referees during the reign of Charles, 184 but there are numerous examples also 
of recourse to the King's Advocate. 185 Sometimes references were also made 
178 Unfortunately, in many cases the only entry 
in the Council register for an appeal is the 
conciliar letter determining the appeal. None 
of the earlier steps in the appellate course is 
recorded. But cf. the reference of a certificate 
of commissioners in a Guernsey dispute to the 
Attorney General and the Solicitor General, 
the Council "fynding the same to be verie long 
and to consist of many particulars" (ibid,, 
1623-2;, 189). 
179 De Beauvoir v. Priaulx (PC 2/46/32). 
Upon debate on the Solicitor General's report, 
the Lords were not satisfied as to the scope of 
re-examination in the cause and ordered the 
reporting officer to explain in writing. But in 
this cause an order seems to have been issued 
previously without objection (PC 2/46/9). A 
later report of the Solicitor General is in the 
same terms as the one previously questioned. 
(PC 2/46/48). 
180 PC 2/40/86. 
181 In the attempts of Clement Masson to compel 
Hugh le Manquais to perform a contract 
of marriage with Masson's daughter, the King's 
Advocate examined the sentence of the Ecclesiastical 
Court in Jersey complained of by le 
Manquais and found no evidence of the alleged 
contract. The King's Advocate left it to the 
Board to decide whether the information now 
given was true or whether directions should 
be given for the Royal Court to examine the 
truth of the allegations and free le Manquais 
if unsubstantiated. The Board pursued the 
latter course (PC 2/40/86). See also the report 
of the Earl of Danby and the Attorney 
General upon a complaint as to the allowance 
of interest in a sentence of the Guernsey Royal 
Court, that "being matter in fact we do not 
take upon us to control the same" (PC 
2/40/188). 
182 See PC 2/42/92, 327. 
183 Specimen references are to the Solicitor 
General (APC, Dom., 1621-23, 494); to tne 
Attorney General (ibid., 1621-23, 424); to the 
Attorney General and the Solicitor General 
(ibid., 1623-2s, 78, 189); to Bird, Prerogative 
Court judge, and Marten, High Court of Admiralty 
judge (ibid., 1623-2;, 261); to Lord 
Zouch, Lord Carew, and the Attorney General 
(ibid., 1618-ig, 335); to "his Majesty's councell 
learned" (ibid., 1618—ig, 274); to Lord 
Carew, the King's Sergeant, and the Solicitor 
General (ibid., 161;—16, 178); to Lord Carew, 
Secretary Calvert, and the Master of the Rolls 
(ibid., 1623-2;, 304). These cases in which 
councilors were joined with legal advisers represent 
a transitional step in the development of 
a committee system. 
184 Out of eighty-seven references that have 
been noted for the reigns of the first two 
Stuarts, the Attorney General was named in 
twenty-five, the Solicitor General in twentythree. 
In eleven of these cases the Attorney 
General acted alone; in eight the Solicitor 
General acted alone. In seven references both 
the Attorney General and the Solicitor General 
were named. 
185 The King's Advocate was named in at least 
thirty-one instances. In twenty-two of these 
cases he was named alone; in four with the 
Solicitor General; once with the Attorney and 
Solicitor Generals and the Vice-Chamberlain