whether the Council Board should hear an appeal or not. 159 As another alternative, 
the principal hearing might be assumed originally by the parent 
body without any reliance upon the services of the Committee. 180 
As has been previously indicated, in a large number of cases the Privy 
Council was preliminarily petitioned that an appeal be admitted from judgments 
or decrees of colonial courts. To make this determination as to admission, 
various methods were utilized. 101 In certain cases the Privy Council 
decided ab initio without any consultation that it would admit an appeal as 
petitioned. 162 In other causes the question of the admission of an appeal was 
referred to the Committee for its opinion in the matter, the conciliar order 
admitting the appeal being based upon the report of that body. 163 Of course, 
the Committee was not limited to its own knowledge; it might consult the 
crown law officers or the judges when legal knowledge was requisite. 164 But 
159 In Sharpe v. Dun (Barb.), an appeal was 
referred to the Committee to examine and consider 
the whole matter of the appellant's petition 
and to report to the Board how they found 
the same, with their opinion what was fit to be 
done thereupon (PC 2/76/147). The Lords 
Committee considered the appeal at two meetings; 
counsel were heard, witnesses called, 
statutes read. Finally, it was agreed to move 
the King in Council diat the parties be heard 
by the Board (CO 391/8/71, 76). The report 
of the Lords Committee stated that the Board 
might hear the cause if they desired (PC 2/76/ 
164). In Bate v. Gibbs, another Barbados appeal, 
substantially the same reference was made 
by the Privy Council; the Lords Committee 
reported that the parties concerned might be 
heard if the Lords Justices should so think fit 
(PC 2/76/160, 164; CSP, Col, 1693-96, 
#1979)- 
1 60 Cooke v. St. Loe (PC 2/71/475). 
161 Since there are no cases evident where an 
appeal was refused by the Privy Council, it is 
safe to conclude that admission standards were 
extremely liberal. There is nothing in the cases 
to indicate that a denial of an appeal by the 
courts below was a condition precedent for 
application directly to the King in Council for 
leave to appeal. 
162 Wright v. Cornwall (N.Y.) (PC 2/69/634; 
apparently the appeal was admitted merely 
upon reading the petition for the allowance of 
an appeal from an October, 1682, judgment of 
the General Court of Assize; the appeal was 
referred directly to the Lords Committee to examine 
and report the state of the matter with 
their opinion thereon); Scott v. Dyer (PC 
2/71/389); In re The Swallow (PC 2/72/456); 
Knight v. Hallett (PC 2/72/666); Elletson v. 
Daniell (PC 2/74/274); Sharpe v. Dun (PC 
2/76/147); Brenton v. Lawson (2 APC, Col., 
#480); Brenton v. Wilkinson (ibid.). 
163 Bland v. Codd (Va.) (CSP, Col, 1681-85, 
#620, 623, 625; PC 2/69/541); Thayre v. 
Savage (Mass.) (PC 2/69/591). As die allegations 
of Thayre of wrongful dispossession from 
lands in Braintree involved the claim of Massachusetts 
Bay to that land, the agents for that 
colony were called upon to answer the petition 
by the Lords Committee (CSP, Col, 1681-85, 
#834, 912, 931, 935); see also Raynesford v. 
Gorges (Barb.), where although the initial 
register entry appears to be a petition and appeal 
(PC 2/71/274), there was a report and 
Order in Council thereon admitting an appeal 
(PC 2/71/280); White v. de Castillo (PC 
2/75/194. 253; CSP, Col, 1693-96, #575- 
76); Holder v. Coates (PC 2/76/92, 241). 
164 In Cooke v. St. Loe, an appeal from a 
Nevis Vice-Admiralty Court sentence, the 
Committee took the opinion of the judge of 
the High Court of Admiralty before advising 
the allowance of an appeal (PC 2/71/330). 
The same opinion was taken in Kirwan v. St. 
Loe, an appeal from an Antigua Vice-Admiralty 
Court sentence (PC 2/72/468). In Holder 
v. Coates, an appeal from a Barbados Vice- 
Admiralty Court sentence, the petition for leave 
to appeal was referred by the Committee to the 
Attorney General and the judge of the High 
Court of Admiralty for their opinion whether 
the appeal should be admitted (CSP, Col, 
1693-96, $1847, 1862). In Hanson v. Rex, 
the Lords Committee contemplated taking the 
opinion of the Attorney General whether 
Governor Dutton of Barbados had proceeded