expect to find allegations of improper judicial conduct below which might not be capable of factual support. In Mingham v. Martin, Mingham petitioned for a rehearing of a Jamaica Vice-Admiralty Court sentence, but the Jamaican officials against whom he had complained regarded his petition as false and scandalous and secured judgments locally in defamation actions against the petitioner for presentation of such petition. 172 Consequently appellant was under the necessity of petitioning against the second sentences. An appeal was admitted upon giving security, and the whole matter was referred to the Committee to consider and report. Upon their report all the sentences complained of were reversed. 173 In Bland v. Codd the Council of Virginia complained unavailingly that it was libeled by allegations in various of appellant's petitions. 174 In Hanson v. Rex an appeal taken from one executive act precipitated more executive action from which in turn it was necessary to appeal. 175 These instances evidence the stubborn attitude frequently exhibited by colonial officials toward any attempts to curb their activities by appeal or complaint to England. One form of this recalcitrance was the denial of appeals, although denial might not in every case be unjustified. 176 The mere procurement of a favorable Order in Council directed against a colonial governor was not equivalent to the achievement of justice —the sanction behind an Order in Council might appear ineffectual to a resolute official located far from the purlieus of Whitehall. 177 At times the Lords Committee Cooke v. St. Loe (PC 2/71/330); Scott v. Dyer (PC 2/71/389); Knight v. Hallett (PC 2/72/ 666; CSP, Col., 1689-92, #430, 507); Elletson v. Daniell (PC 2/74/274); White v. de Castillo (PC 2/75/253); Brenton v. Lawson (2 APC, Col., #480); Brenton v. Wilkinson (ibid.); cf. Billop v. West (CO 391/5/235)- 172 Sir Henry Morgan, Deputy Governor and sole Admiralty Court judge at the complained of condemnation, received damages to the extent of £2,000; Thomas Martin, the Receiver General, was awarded .£s°° damages (CSP, Col., 1677-80, #1304, 1379. 1398). 173 An unsuccessful attempt appears to have been made by the Board to have a preliminary hearing to determine whether an appeal should be allowed in the defamation cases (PC 2/68/ 28). The course of the case can be traced in PC 2/68/45, 243, 257, 267. The defamation actions were regarded as a contempt of the Council's authority. "*CSP, Col., 1681-85, #1769- 176 See ibid., #1167. 178 In Lane v. Stede the debts for which appellant was imprisoned amounted to only £146/13/4, whereas it appeared to the Committee that in Barbados appeals were not usually allowed in personal actions under £300. Nevertheless, the Lords Committee advised that Lane be allowed to prosecute an appeal (CO 391/8/90). But at the time this appeal was first denied, the Lieutenant-Governor was justified in refusing such appeal under his instructions; see 1 Labaree, Royal Instructions, #443. In Witham v. Rex Gov. Dutton claimed that according to his instructions he was directed to allow no appeals in criminal causes (CSP, Col, 1685-88, #293); cf. the attitude of the Committee, ibid., #439- For the instructional language as to criminal appeals see 1 Labaree, Royal Instructions, #443- 177 The petition for leave to appeal of Ralph Lane was first considered by the Privy Council on July n, 1689 (PC 2/73/177). The appeal was admitted in December, 1692 (PC zhs/ 50). A year later it was necessary to petition for enforcement of this admitting order (PC