bills of credit, and many others. The judicial activity of the Council in relation 
to statutes of this type was primarily a matter of interpretation, and is on the 
whole of very little interest. For example, in Denn v. Herbert, a 1760 appeal 
from the Nevis Vice-Admiralty Court, it was necessary to determine what 
constituted an "importation" under the Navigation Acts. The respondent 
contended that the mere dropping anchor in port was sufficient, but in advising 
reversal, the determining factor was that bulk was not broken. 124 Again, 
in the 1762 appeal of Chollett v. Mackay from the same island the issue presented 
was whether foreign gold and silver coins constituted "goods and 
merchandise" under the Navigation Acts. In advising reversal the Committee 
accepted the contention that the coins were not goods or merchandise because 
they were not bullion, but money. 125 
Although the problems of interpretation upon appeal were usually of the 
humdrum sort just mentioned, there was one occasion, which occurred after 
the Seven Years' War, when the Council settled a rule of great constitutional 
importance with respect to the Acts of Trade. The island of Dominica, which 
had been neutralized under the Treaty of Aix-la-Chapelle (1748), was captured 
by the British in 1761, 126 and their possession was confirmed by the 
Treaty of Paris. Whether or not the island had been involved in the contraband 
trade which flourished during the period of Spanish neutrality, it was charged 
with the coming of peace that an "avowed constant Open Market and Fair" 
was there kept. 127 In January, 1764, Captain Thomas Knowler of H.M.S. 
Milford seized certain sugars in a warehouse on shore and on board several 
vessels lying in the harbor of Roseau. Ships and sugar were taken to Antigua, 
where Knowler exhibited informations in the Court of Vice-Admiralty for 
breach of 7 and 8 William 111, c. 22, and 6 George 11, c. 13 (Molasses Act), 
alleging landing at Dominica before the entry and that the sugars were landed 
without warrant signed by a collector. The sugars were the several properties 
of Anthony Columbier, merchant of London, Joseph and Henry Guignand, 
also of London, Victor McNelly, merchant of. Cork, and William Woodbridge, 
late of Guadaloupe. In June and July, 1764, sentences of condemnation 
were pronounced and appeals were taken in all four cases to the King in Council 
128 
In the case of the Guignands and McNelly it was averred that the sugars 
were in payment of cargoes shipped and sold to British merchants in Dominica. 
In the case of Woodbridge the sugar was alleged to have been im- 
124 PC 2/107/189, 435, 444. For the "cases" 
of the parties see Add. MS, 36,218/78-81. 
125 PC 2/108/185; PC 2/109/125, 167. For 
the "cases" of the parties see Add. MS, 
126 2 Corbett, England in the Seven Years War 
(1918), 177-78. 
127 MS notes in Add. MS, 36,220/93. 
128 See the Cases of Appellants in Add. MS., 
36,218/133-37. 
36,220/80 et seq.