by respondent on the appeal. 301 In some cases costs were levied in interlocutory 
proceedings as a penalty for laches. 302 
Award of costs in Channel Islands causes varied from the practice in appeals 
from the distant jurisdictions. In the period prior to the accession of George I, 
£2, £3, or constituted the usual awards. 303 After 1714, and 
awards predominated, although some reached as high as and others 
descended as low as 304 The awards were invariably in round figures 305 
and virtually always made in instances of affirmance on the merits or dismissal 
for nonprosecution. The proportion of appeals in which costs were awarded 
was approximately the same as in colonial appeals. Interlocutory costs were 
awarded in a few cases, 308 and Orders in Council made contingent upon payment 
of awarded costs. 307 Awards in late Isle of Man appeals varied from ,£lO 
to 308 No costs are found awarded in the scattered Minorca and Gibraltar 
appeals. 
Some royal instructions mentioned security for "damages" (interest) as 
well as "costs" upon appeal to the King in Council. 309 Certain English cases 
would admit of such award on writ of error proceedings by virtue of 3 Henry 
VII, c. io, 310 but others declared that damages were not recoverable on writ 
of error under that statute, perhaps influenced by the language of 27 Eliza- 
301 Ford v. Hodgson (PC 2/86/287, 306 
[£21/1 costs]). 
302 See Gilligan v. Ramsey (PC 2/87/89), 
appellant moving for adjournment was ordered 
to pay respondent costs of the day; Rigby v. 
Chester (PC 2/89/16), appellant was ordered 
to pay £5 for delay in prosecution; Jones v. 
Shields (PC 2/103/358), Committee agreed 
to receive a late appeal, if appellant paid £5 
costs and was ready for hearing on a certain 
date; Francia v. Hope (PC 2/105/231), respondent 
was ordered to pay £80 costs on a 
hearing in which a frivolous and vexatious 
objection was made as to want of proper 
parties; Halstead v. Needham (PC 2/85/413), 
appellant failed in his proof by not producing 
under the colony seal certain deeds, so he was 
given further time to send to Jamaica for 
them and £6 costs were awarded; Garbrand 
v. Strachan (PC 2/93/84-85), appellants were 
given leave to amend their petition and appeal, 
but were to pay £2 costs of day. 
303 See inter alia for Guernsey, Carey v. de 
Lisle, £2 (PC 2/77/54); Le Messurier v. 
Lihou, £5 (PC 2/77/362); de Garis v. Fiot, 
£5 (PC 2/80/146); Bernard v. Le Cocq, £3 
(PC 2/82/403). For Jersey see Rex v. Seal, 
£2 (PC 2/77/83); de la Garde v. Guerdain, 
£5 (PC 2/80/394); Grant v. Le Cousteur, 
£3 (PC 2/82/246); de Carteret v. Robin, £2 
(PC 2/83/185); Messervy v. Dumaresq, ,£5 
(PC 2/86/124). 
304 Carey v. Carey, £40 (PC 2/95/491); 
Parker v. Guille, /40 (PC 2/96/455); Dumaresq 
v. Pipon, ,£5O (PC 2/102/288); Le 
Marchant v. Carey, £50 (PC 2/102/249); 
Grandin v. Le Cocq, £2 (PC 2/107/120). 
305 But cf. Mackie v. Mauger, where £32 
was awarded in consideration of appellant's 
frequent voyages and constant attendance at 
tie Council Board (PC 2/85/469). 
306 Bandinel v. de Carteret, £5 (PC 2/85/ 
239); Hilgrove v. Dumaresq, £5 (PC 2/86/ 
352); Tapin v. Rex, £10 (PC 2/86/135); 
Massey v. Falla, 2 guineas (PC 2/86/436). 
307 Carey v. Carey (PC 2/90/425, 432); 
Villeneufve v. Guppy (PC 2/97/108, ir7). 
308 See Christian v. Corlett, £\0 (PC 2/113/ 
542); Bishop of Sodor and Man v. Castley, 
£100 (PC 2/128/251). 
309 1 Labaree, Royal Instructions, #445, 449. 
310 Graves v. Short (Cro. Eliz., 616); Anonymous 
Case (Cro. Car., 145); The Earl of 
Pembroke v. Bostock and Green (Cro. Car., 
173); The Bishop of London v. The Mercer's 
Company (2 Strange, 925). Cf. Bodily v. 
Bellamy (2 Burr., 1094).