granting powers equal to those of the Bishop of Durham within his County Palatine. 204 In that County Palatine a writ of error lay from judgments of the local chancery and of the justices of the bishop to the bishop himself; from his judgment a writ of error could be sued, returnable in King's Bench. 200 By analogy it was argued that appeals lay from the provincial courts to the proprietor, subject to further review by King's Bench. 208 Nevertheless, in practice appeals were still taken to the King in Council. 207 In an isolated instance in 1707 we also find an appeal taken from the Chancery Court to the Archbishop of Canterbury in the Arches. 208 THE NEW CHARTERS Turning now from those colonies in which charter government was long established, let us inquire whether the above-related experiences were reflected in newly issued charters. In the 1722 grant of St. Vincent and St. Lucia to the Duke of Montagu there was included a reservation of appeals to the King in Council modeled after the instructional norm. 209 But the only St. Vincent had been made against the former proprietary government. In 1701, in reply to a Board of Trade letter requiring information relating to ill conduct of proprietary governments, especially Maryland, when under that form of government, it was answered by the Maryland Council that "there were not any appeals allowed to England, but the judgment and sentence of the Governor and Council which was then stiled the Upper House of Assembly was final in all causes, and the Governor and Council, who were the only Judges of the said Appeals, were the same persons who gave judgment in the Provincial Court, the Lord Proprietary and his Council being the judges of that Court" (CSP, Col., 1701, #1039). To the same letter the House of Delegates on March 18, 1701/2, stated: "As to appeals, it is acknowledged by this House that in the time of the Proprietary Government here, appeals for England have been denyed" {ibid., 1702, #203). Cf. J. McMahon, An Historical View of the Government of Maryland (1831), 271. In some quarters King's Bench was apparently regarded as the proper appellate body, for we find fear that causes would be brought to Westminster Hall (CSP, Col., 1696-97, #79, 80). 204 3 Thorpe, Federal and State Constitutions, 1679. 205 Coke, Fourth Institute, 218; Lapsley, The County Palatine of Durham (1900), 184, 212. 208 Proceedings Maryland Court of Appeals, 7695-/729, (ed. C. T. Bond, 1933), 355. See also ibid., 425-26, 445, where appeals from the Court of Appeals to the proprietor were admitted. After the Maryland patent had passed the seals, the failure specifically to reserve the judicial supervisory power of the King was commented upon. See Barnes, Land Tenure in English Colonial Charters of the Seventeenth Century, in Essays in Colonial History Presented to Charles McLean Andrews by His Students (1931), 29. Cf. Le Case del Countie Palatine de Wexford, Davis 59, 62. 207 Bond, introduction to Proceedings Maryland Court of Appeals, 1695-1729, vi, xli. 208 Helms v. Franciscus, 2 Bland's Chan. Rep., 566-67, note. 209 The clause was as follows: "And it being necessary that all the subjects of us our heirs or successors may have liberty to appeal to the royal person or persons of us our heirs or successors in civil causes that may deserve the same, Our will and pleasure therefore is and we do hereby for us our heirs and successors declare and grant that if either party shall not rest satisfied with the judgment decree or sentence of the superiour courts of the said islands that then and in such cases it shall and may be lawfull to and for either party to appeal to us our heirs or successors in our or their Privy Council provided the matters in difference exceed the value or sum of .£3OO sterling and that such appeal be made within