formal function was present in the work of the Lords Committee, since many matters were referred by it in turn to subordinate bodies, particularly the Board of Trade. But barring the few cases mentioned above, appeals in chief were invariably heard before the Committee —the Board of Trade was limited to reporting on ancillary questions in the appellate field. The appellate jurisdiction of the Privy Council, following the administrative reorganization of 1696, is most conveniently studied in terms of what we conceive to have been the most salient policy developments. First, we have the initial drive to impose appellate control upon the chartered colonies. Concomitant was the task of buttressing appellate review in the royal colonies, particularly New Hampshire. Following this we shall examine later vestiges of recalcitrance in the chartered colonies. We also shall make inquiry whether administrative experience with the chartered colonies was reflected in newly issued charters. We shall then diverge to observe the initial exercise of appellate jurisdiction over other jurisdictions of the crown outside the realm—the Isle of Man, Minorca, and Gibraltar. Returning to the colonies, we shall examine the use made of the disallowance in preservation of conciliar jurisdiction, the problem presented by appeals from colonial vice-admiralty court sentences, and the self-imposed limitations upon the Council's judicial powers. Lastly, we shall consider the political assaults made upon the jurisdiction of the King in Council in the era preceding the American Revolution. THE PROBLEM OF THE CHARTERED COLONIES The keynote of the early years of the new administrative system was sounded by Governor Fletcher of New York in a statement that "it is apparent that the stronger these colonies grow in parts the weaker we are in the whole, every little Government setting up for despotic power and allowing no appeal to the Crown but valuing themselves in their own strength and on a little juggling in defeating all commands and injunctions of the King." 38 These words were singularly prophetic, and the newly reorganized administration at Whitehall was soon to savor their bitterness as first of all it came to grips with Massachusetts Bay. The clause in the 1691 charter saving appeal to the crown had failed to effect a change of heart in the refractory Puritans, who now devoted their energies to the restriction of appeals to the precise letter of the charter. This matter was initially controverted in connection with attempted enforcement of the Acts of Trade in Massachusetts Bay by Jahleel Brenton, Col- Hutchins from New York sentences were also heard by the King in Council (PC 2/79/295). Later in Bishop of Sodor and Man v. Earl of Derby appellants petitioned to be heard before the Council Board rather than the Committee (PC 2/88/263). Such hearing accordingly took place before a Council Board of seventeen, but the appeal was dismissed nevertheless on procedural grounds (PC 2/88/282). SS CSP, Col., 1696-97, #14.