1724/5, but adjourned subsequent hearing until the twenty-ninth. On that date it was objected by the council for the defendant in error that the Statute of Frauds was of force in their island and consequently the paper writing said to be the will of the said Edward Harris was not sufficient to pass his lands and tenements, but the council on the other side urged that the statute was not in force here, and had been adjudged so by her late Majesty in Council in the case of Orby and Long in relation to Sir William Beeston's will. And having fully heard what they had further to offer all persons were ordered to withdraw and the question was put whether the two judgments so given in the court below should stand confirmed or reversed, and there being an equally of voices it was ordered by the court that the said causes should be confirmed. 48 No appeal was ever prosecuted in the cause. 49 Before censuring the Jamaica Court of Errors for not following Orby v. Long, we must further pursue the problem of the effect of Orders in Council as precedents in the colony directly touched by a conciliar ruling. It should not be overlooked that Committee reports were not properly judgments, but as we have remarked, they were in the nature of advisory opinions tendered to the King in Council. A patent distinction between Committee reports and judicial decisions is the absence of dissenting reports in the former, presumably upon the basis that dissenting advice would merely confuse the sovereign. so A practical difficulty is found in the nature of the Committee report embodied in the Order in Council. As we have seen, most reports merely incorporated the petitionary allegations of the appellant and added the Committee advice on the appeal—the grounds of the advice usually did not appear on the face of the Committee report. Furthermore, Orders in Council enjoyed little notoriety—the Privy Council registers were not open to public inspection, 51 and 48 1 ibid., sub January 27 and 29, 1724/5. The judgment might be justified by "long usage and general acquiescence" under a May 18, 1724, opinion of the crown law officers; see 1 Chalmers, Opinions, 220. 49 Some confusion exists as to the appellate course of the cause. On May 13, 1727, petitions and appeals were presented to the Council in what appears to have been the same two causes, but the date of the Court of Errors judgment was given as Oct. 5, 1726 (PC 2/89/357). Neither was further prosecuted. On July 5 a petition and appeal was presented by Thomas Barrett in behalf of Peter Miller, minor, heir at law of the deceased Edward Harris, from a Jan. 29, 1724/5, judgment of the Court of Errors in favor of Barrow Harris. It was prayed that the appeal be received late, as delay was caused by the deadi of Barrow Harris and ignorance of the identity of his heir. It was also prayed that the widow and the eldest son of said Barrow Harris be summoned to appear and defend the appeal and that a short day be appointed for a hearing (PC 2/90/37). No further entry on the appeal is found. 50 In the February 20, 1627/8, conciliar regulations it was laid down that "when the business is carried according to most voices, no publication is afterwards to be made how the particular voices and opinions went" (Selborne, Judicial Procedure in the Privy Council, 66; I Clarendon, State Papers, 36). 51 2 Knapp, Appendix XII. For the neglect and inaccessability of the earlier conciliar records see Knox, Extra Official State Papers (1789), 15-16.