gave the vice-admiralty courts concurrent jurisdiction with the common law courts in all Navigation Acts cases, where formerly jurisdiction was confined to the common law courts. Dudley Ryder, to whom the bill was submitted, altered it to give the vice-admiralty courts sole jurisdiction in all cases arising under the Navigation Acts. Ryder also added a clause that appeals should lie from all sentences given in the vice-admiralty courts in such matters to the King in Council under such regulations as governed conciliar appeals from the courts of the respective colonies. 313 Ryder explained that he made this addition "to prevent all doubts about appeals to the Admiralty here; I made it declaratory, as it is agreable to the present practices in those causes where the jurisdiction is given, by the acts relating to Navigation, to the Admiralty courts in the plantations." 314 The bill, however, failed of enactment. Following this abortive attempt at legislative resolution of the jurisdictional doubts, we find continuation of the earlier confusion. In July, 1748, the South Carolina Vice-Admiralty Court refused appeals to the King in Council in Hopton qui tarn v. Vrouw Dorothea and Goolde qui tarn v. Vrouw Dorothea on the basis of reservation of an appeal to the High Court of Admiralty in the judge's commission. 3ls But in 1751 civilian lawyer Samuel Seddon, in discuss- 313 Adm. 7/298/88-96. The bill was entitled: "A Bill for removing; and obviating some doubts and disputes touching the authority and jurisdiction of the Admiralty Courts in the British Plantations in America with respect to the matters therein mentioned; and for ascertaining, establishing, and enlarging the authority and jurisdiction of the said courts with respect to the said matters." The exact wording of the Ryder amendment was as follows: "And it is further declared and enacted by the authority aforesaid that appeals shall lye from any sentence or judgment to be given in any of the said Admiralty or Vice- Admiralty courts in or concerning any of the matters aforesaid to His Majesty, his heirs and successors in Council subject to such rules, regulations, and limitations and restrictions as appeals to his Majesty in Council from the courts of the respective plantations and colonys where such sentence or judgment shall be given are and shall from time to time be subject to, and no appeals from such sentences or judgments shall lye to any other court or jurisdiction whatsoever" (ibid., 95-96). 314 Ibid., 86-87. Compare the view of Andrews (1 Cambridge History of the British Empire [1929], 297) that appeals were uniformly made to the High Court of Admiralty. For some appeals to the King in Council during this period see Everleigh v. Brook (PC 2/90/ 340, 345); Cranston v. Jekyll (PC 2/89/92, 103); In re The Fisher (PC 2/90/374, 408, 431); Worsley v. Daverse (PC 2/91/52); Dußois v. Toller (PC 2/92/4, 19); Dunbar v. Lory (PC 2/96/240, 262); Dunbar v. Webb (PC 2/96/142, 156). sio When in Hopton qui tarn v. Vrouw Dorothea an appeal to the King was prayed for, the judge declared that such appeal "ought not to be admitted according to the stile and practice of the Court which being a Vice Admiralty Court and subordinate to the High Court of Admiralty of England and the judge or president of the same cannot lawfully admit this appeal per saltum to any other jurisdiction without derogating from the authority of the said High Court of Admiralty contrary to the duty and respect which is justly due to it from this Court and expressly contrary to his Majesty's most gracious intentions concerning this matter signified to me by my commission whereby amongst other things causes on seizures for breaches of the Acts of Trade arc to be heard, discussed, and finally determined in this Court, saving nevertheless the right of appealing to the High Court of Admiralty of England or to the judge or president of the same for the time being, and saving always the right of the said High Court of Admiralty and also of the judge and register of the same from whom or either of them His