essentially the same as that employed in House of Lords "cases" and was probably derived therefrom. Some abuse crept into this practice of circulating printed "cases," for in March, 1730/1, it was represented to the Council by the Committee that a practice had lately been introduced by parties to conciliar causes of printing and delivering to the Committee at the time of hearing a state of their case, unsigned by any counsel learned in the law. This practice having been represented as an irregular and improper method of proceeding, it was ordered in Council that no person deliver any printed case to any Lords of the Council or any committee thereof unless such case was signed by one or more counsel who should attend the hearing of the cause. 120 The usual appellate hearing opened with a reading of the petition and appeal by the Committee. Then counsel on both sides were called in and heard. 121 We find little mention in conciliar practice of scrutiny of the record brought up from the court below. To some extent the factual recitals in the conciliar "cases" served the purpose of the orthodox record. 122 But conciliar jurisdiction was weakened by the absence of any procedural device comparable to the writ of error in bringing up the record. In hearing a Jersey appeal in 1699 the Committee found great variance in the proceedings as produced by each side. Therefore, the bailiff was ordered to take care that in future appeals all proceedings be duly transmitted. 123 Later in a 1728 appeal the Royal Court of Jersey was directed to enter up all resolutions of the court so as to appear in the record, if desired by either party. 124 Finally, a January 22, 1730/1, conciliar letter to the Royal Court of Jersey recited that frequent disputes had arisen before the Committee in appeals from that island as to whether acts of the court and evidence, although transmitted under the insular seal, had been before the Royal Court in the proceedings below. Since the Committee had encountered great difficulties in determining which acts and evidence should be read, attention was called to the May 13, 1572, Order in Council governing 269). Cited to show that a devise created an estate tail were Webb v. Hearing (Cro. Jac. 415); Hearn v. Allen (Cro. Car. 57); Nottingham v. Jennings (1 P. Wms. 23). See also the citation of conciliar precedents, infra, p. 481. For Channel Islands "cases" see Le Febure v. Brock (Add. MS, 36,218/193-99); Gabourel v. le Maistre (Add. MS, 36,220/122-26); Pipon v. Pipon (Add. MS, 36,218/59-63); Corbet v. Dumaresq (1715), Soc. Jer. Lib. 120 3 APC, Col., #228. Compare the allegation of Pound (op. cit., 67) that "it was not required that the case be signed by counsel." 121 See Pipon v. Dumaresq (PC 2/91/561; PC 1/10 [53]). 122 But in some instances recitals in the "cases" apparently deviated from the record. See Lidderdale v. Chiswell (Case of Respondent, Add. MS, 36,217/201); Hall v. Laing (Case of Appellant, Add. MS, 36,220/163); Millward v. Lindsay (Case of Respondent, Add. MS, 36,220/213). 123 Priaulx v. de Lisle (PC 2/77/359). In the 1702 Guernsey appeal of Dobree v. Fautrart the Royal Court was ordered to take care upon rehearing that all depositions on either side were punctually set down in writing to be transmitted in case of appeal (PC 2/79/ 163). 124 Le Geyt v. Magon (PC 2/90/446-48, 460-61).