The question of the proper appellate jurisdiction over vice-admiralty courts was not as purely academic as some writers would have us believe. One writer has stated that "it was rare for a vice-admiralty judge to render an unjust or erroneous verdict." 383 With this misuse of "verdict" for "sentence," it may be that this statement was made in a philosophical rather than a legal sense, for an examination of those appeals in the Privy Council register which were heard on the merits reveals that of forty-seven such cases, thirty-four resulted in reversal in whole or in part. Most of these cases were heard after 1760, when the number of vice-admiralty court appeals to the King in Council greatly increased, although no clarification of the earlier confused jurisdictional concepts is found. Virtually all the appeals heard by the Privy Council on the merits were from the insular and newer continental possessions, but we have no reason to believe that the appeals entered from the older continental colonies remained unprosecuted because of jurisdictional convictions. As for local review of vice-admiralty court sentences the extant records reveal that little importance was attached to such a remedy. Nevertheless, a strong development of such a method of relief might have subjected the vice-admiralty courts to greater surveillance than was available by occasional appeals to England. LIMITATIONS ON THE EXERCISE OF REVIEW JURISDICTION Although insistent upon appellate jurisdiction over the plantations and other dominions of the crown outside the realm, the Privy Council declined exercise of nonappellate judicial powers. In 1701 the Board of Trade was petitioned to direct the Barbados Chancery Court to set aside a certain agreement made to petitioner's prejudice. 384 The Board of Trade, however, represented to the King in Council that it has not been usual for your Majesty or your predecessors to interpose the royal authority in judicial proceedings in the plantations otherwise than by receiving appeals to your Majesty in Council for your royal determination as to right shall appertain. 385 Upon the 1701-2 complaint of William Mead as to irregular judicial proceedings in the Leeward Islands, the Board of Trade also advocated resort to the regular appellate channels. 386 The same result is found in the related com- 383 4 Andrews, Colonial Period, 229. 384 CSP, Col, 1701, #64. 385 Ibid., #133. 386 In November, 1701, the Council referred to the Board of Trade Mead's petition complaining of some Nevis judicial proceedings concerning two plantations known as Harvey's Plantations and the petition and appeal of William Shipman et al. in the same matter (PC 2/78/283; CSP, Col, iyoi, #1089, 1090). Complaint by Mead had been anticipated by Governor Codrington of the Leeward Islands {ibid., #600). For the Board of Trade answer see ibid., #759. Mead, attending the Board of Trade, was ordered to produce affidavits in proof of the allegations in the two