Published online by Cambridge University Press: 18 August 2010
Over thirty years ago Douglas Hay began his influential essay, “Property, Authority and the Criminal Law,” with the unsettling claim that “the rulers of eighteenth-century England cherished the death sentence.” He went on to offer a major reinterpretation of eighteenth-century justice, one with wide-ranging implications for how we understand English society in that period. The gallows, Hay argues, was meant to inspire terror. The passage of a large number of capital statutes spoke of the resolve of the ruling class to defend its property with the most extreme of measures. Yet the ultimate sanction was used sparingly. Hay's most important insight was to note the role of discretion in the operation of eighteenth-century justice. The choice not to impose death was as important as the occasions when offenders died. The elite deftly exploited these opportunities. The mercy dispensed by the Crown not only presented a more benign image of authority, it also taught the lessons of patronage and deference that instructed the lower orders in the proper attitude to take toward their social superiors. Thus justice worked more powerfully than religion to create legitimacy for the existing order.
1. Hay, Douglas, “Property, Authority and the Criminal Law,” in Hay, et al., Albion's Fatal Tree: Crime and Society in Eighteenth-Century England (New York: Pantheon Books, 1975), 17, 62–63,Google Scholarand more generally, 17–63.
2. King, Peter, Crime, Justice and Discretion in England 1740–1820 (Oxford: Oxford University Press, 2000)Google Scholar;Beattie, John, Crime and the Courts in England, 1660–1800 (Princeton: Princeton University Press, 1986), esp. chap. 8Google Scholar;Green, Thomas, Verdict According to Conscience (Chicago: University of Chicago Press, 1985), chapter 7Google Scholar;An Ungovernable People: The English and Their Law in the Seventeenth and Eighteenth Centuries, ed. Brewer, John and Styles, John (New Brunswick, N.J.: Rutgers University Press, 1980), 20.Google ScholarFor a review of the arguments between scholars and a judicious summary,see Innes, Joanna and Styles, John, “The Crime Wave: Recent Writing on Crime and Criminal Justice in Eighteenth- Century England,” in Rethinking Social History, ed. Wilson, Adrian (Manchester: Manchester University Press, 1993), 201–65Google Scholar.
3. King, Peter, “Decision-Makers and Decision-Making in the English Criminal Law, 1750–1800,” The Historical Journal 27 (1984): 25–27.Google ScholarFor the fullest investigation of the meaning of the gallows,see Gatrell, V. A. C., The Hanging Tree (Oxford: Oxford University Press, 1994)Google Scholar.
5. For a discussion of the coining networks who rapidly turned their attention to the forgery of Bank of England notes, see John Styles, “‘Our Traitorous Money Makers’: The Yorkshire Coiners and the Law, 1760–83,” in Ungovernable People, 172–249;Morgan, Gwenda and Rushton, Peter, Rogues, Thieves and the Rule of Law (London: UCL Press, 1998), 82–84Google Scholar.
6. The precise status of the Bank of England in relation to the government was a subject of much controversy throughout the period. Every commentator granted that the Bank occupied a unique place in the economic life of the country. There was much disagreement over whether its influence was entirely beneficial. Some authors worried that the government interferred too much in its operation, while others expressed concern that the Bank had an excessive voice in shaping public policy. Throughout the suspension period there was the widely expressed suspicion that the corporation was profiting unfairly from the circulation of its paper. The Bank sometimes appears to have believed that it was a more reliable protector of the national interest than the government. Pitt's relationship with the corporation was particularly fraught. He felt compelled to remind the Commons that “it was also a private joint-stock commercial organization trading and seeking profit on its own capital resources.” This division between its public responsibilities and private governance explains why the officers of the Bank could appeal to its unique obligations in justifying the severe measures it adopted for dealing with forgery, while at the same time insisting upon the corporation's privileges and need to control the prosecution and punishment of offenders.Bowen, H. V., “The Bank of England during the Long Eighteenth Century, 1694–1820,” in The Bank of England: Money, Power, and Influence, 1694–1994, ed. Roberts, Richard and Kynaston, David (Oxford: Clarendon Press, 1995), 11, and more generally, 1–18;Google ScholarHilton, Boyd, Corn, Cash, Commerce (Oxford: Oxford University Press, 1977)Google Scholar;Fetter, Frank, Development of British Monetary Orthodoxy (Cambridge: Harvard University Press, 1965)Google Scholar.
7. Morning Chronicle, March 12, 1798Google Scholar;Old Bailey Sessions Papers (hereafter OBP) (www.oldbaileyonline.org), William Stinson, April 18, 1798, case t17980418–2.
9. OBP, Elizabeth Brown, April 18, 1798, case t17980418–1.
10. OBP, Charles Linsey, June 19, 1799, case t17990619–20.
11. Bank of England, Roehampton, box F420. On the difficulties faced in these prosecutions,see McGowen, Randall, “Forgery Discovered, or the Perils of Circulation in Eighteenth-Century England,” Angelaki 1 (1993–1994): 113–29;Google Scholar“Knowing the Hand: Forgery and the Proof of Writing in Eighteenth-Century England,” Historical Reflections 24 (1998): 385–414Google Scholar.
12. OBP, Edmond Lovell, February 14, 1798, case t17980214–3.
13. OBP, John Aikin, April 18, 1798, case t17980418–7.
14. Bank of England, Roehampton, box F14.
15. Bank of England, Roehampton, box F12.
16. Bank of England, Roehampton, box F6.
17. Bank of England, Roehampton, box F22.
18. Bank of England, Roehampton, box F17.
19. The Bank took the unusual step of paying the bill of £78 12s. 6d. The sum included £10 for conveying the condemned to the place of execution, £2 17s. for the iron-work of the drop, £10 for eight javelin men, and £2 2s. as the executioner's fee. Freshfield's own charges included a visit to choose the site for the platform, a trip to the Earl of Aylesbury to secure the presence of a troop of yeomanry as a guard against an expected rescue attempt, and costs associated with his trip to Warwick to accompany the prisoners to Birmingham. Bank of England, Roehampton, box F257. On the aftermath of the execution,see Cook, Peter, “William Spurrier and the Forgery Laws,” Holdsworth Law Review 17 (1995): 44–55Google Scholar.
20. Morning Chronicle, March 29, 1798.Google ScholarComplaints about the quality of the bank note were a regular feature of the press coverage of suspension. While a few improvements were made in the first years of the period, with a temporary impact on the level of forgery, the Bank resisted the call to radically redesign its notes.
21. Bank of England, F2/162.
22. Bank of England, Roehampton, box F12.
23. Committee for Law Suits, M5/307, May 7, 1805.
24. Parliamentary Papers 1818 (297), xvi, 171.Google ScholarThe directors concluded that the expenses charged by the solicitors were not unreasonable, “when they consider the immense number of prosecutions that have been carried on, the various parts of the country to which it has been necessary to travel, the great labour and fatigue undergone by the solicitors, themselves and their confidential clerks, by night, as well as by day, the arduous and painful situations in which they have been placed, from the delicate nature of the momentous concerns entrusted to their care; and that all this business cannot have been transacted without employing an extra number of clerks, and those retained and paid in an extraordinary manner.” Minutes of the Court of Directors, Ba, 212–13, June 10, 1802.
25. Eighteenth-century legislation had punished capitally both the making of a forged instrument and the act of uttering or putting off the note. Since there were seldom witnesses to the fabrication of the note, most convictions were for uttering. The Bank was creating a new offense with this measure. Nonetheless, the vast majority of those whom it prosecuted had been detected in putting off forged notes.
26. 41 Geo. III c. 39; Bank of England, F8/49.
28. Bank of England, Roehampton, box F16. In recognition of the challenges that lay ahead, the Bank made one other significant change, this one in its institutional structure. In July 1802, it created a Committee for Law Suits, composed of several directors, along with the governor and deputy-governor of the corporation. The solicitors continued the day-to-day police operations, but the final decision about who to prosecute, what charge to press, and how to respond to petitions rested with the committee. While the board normally accepted the recommendations offered by the solicitors, this structure made clear that final responsibility belonged to the corporation. This arrangement was particularly important in capital cases. When Randle Jackson challenged the directors, at a meeting of the proprietors of the Bank, to explain whether one person was responsible for decisions in criminal cases, the answer he received was that the entire board decided.The Bury and Norwich Post, September 23, 1818Google Scholar.
29. Bank of England, F2/155.
30. The notion that this measure was intended to deal specifically with the emergency created by suspension gains support from the fact that the corporation stopped prosecuting for possession in 1821 and only revived the charge briefly when it again issued small denomination notes in 1826 (4 cases) and 1829 (1 case). In 1830, in looking back over the preceding decades, the solicitors wrote that the policy had been adopted in cooperation with the judges and counsel. All agreed, they wrote, on “the expediency of avoiding so many public trials.” Bank of England, F8/26.
31. Committee for Lawsuits, M5/307, July 7, 1802. This was the first meeting of the committee.
32. Beattie, , Crime, 336–37, 346–47, 365–66, 446–47;Google ScholarFisher, George, “The Birth of the Prison Retold,” Yale Law Journal 104 (1995): 1275–76;Google ScholarLangbein, John, The Origins of Adversary Criminal Trial (Oxford: Oxford University Press, 2003), 219–21;Google ScholarLangbein, John, “Understanding the Short History of Plea Bargaining,” Law and Society Review 13 (1979): 261–70;Google ScholarKing, , Crime, 225–26.Google ScholarThis occasion was scarcely the first instance of a capital statute being used as a form of coercion to aid in the detection and prosecution of elusive offenders. John Beattie suggests that this was the motive behind the Shoplifting Act of 1713, which aimed less at the servants explicitly targeted by the act than at the receivers who were supposed to have encouraged them.“London Crime and the Making of the ‘Bloody Code,’ 1689–1718,” in Stilling the Grumbling Hive, ed. Davison, L. et al. (New York: St. Martin's Press, 1992), 67–69Google Scholar.
33. Bank of England, Roehampton, box F352. In an undated memo, written after the suspension period, the Bank once again denied exercising an “undue influence” in getting offenders to plead guilty. Bank of England, F8/26.
34. The French visitor, Charles Cottu, was struck by the operation of this procedure. He interpreted it as an instance of the humanity of English justice. “In this situation, when the accused is standing at the bar, in order to take his trial, the counsel for the bank asks the counsel for the prisoner if his client be willing to plead guilty to the second indictment, which only involves transportation; promising him that in that case the bank will relinquish the prosecution of the first, which is a capital crime. If the accused acquiesce in this proposition, he is immediately found guilty on the second indictment, on his own confession; and with regard to the first, the counsel for the bank informs the jury that he does not intend to bring forward his witnesses, and they consequently return a verdict of not guilty, for want of evidence. Nor does this sort of transaction take place secretly, or in a corner, but, incredible as it may appear, in open court, in the face of the public, the jury, and the judge.” What impressed him, when he described the case of a woman who declined the Bank's offer, was the gentle persuasion exerted by all those around the prisoner urging her to save her life, rather than what might have struck an English person, the tremendous pressure applied to make her forego a jury trial. “M. Cottu on the Criminal Code of England,” Pamphleteer, 1820, 52–53, 56.Google Scholar
35. Bank of England, Roehampton, box 352. Perhaps the clearest evidence of the Bank's caution around this topic is that, despite compiling thorough statistics on those it prosecuted and the outcome of trials, it refrained from keeping any records of those actually executed. I have been unable to find such statistics in the Bank's voluminous archives. This refusal, actually offered to Parliament, points directly to the Bank's desire to avoid lending any substance to the charge that it determined the fate of those who were capitally convicted.
36. Committee for Law Suits, M5/307, July 28, 1802. William Stocker (OBP, t18020428– 126) and Edward Walsh (OBP, t18020428–127) were the first offenders permitted to plead guilty at the Old Bailey, April 28, 1802.
37. Bank of England, Roehampton, box F183. In 1817, in the midst of a rapid rise in the number of forgery cases, the Bank permitted some of those prosecuted capitally to plead guilty on the understanding that they would be transported for life. Committee for Law Suits, M5/318.
38. Henry Brougham, in 1830, told Parliament that “the Directors of that Company only brought forward cases in which they felt confident that they could obtain convictions. Their conduct had been unpopular in this respect, and they would now even withdraw after having commenced proceedings if they saw the least chance of being defeated.”Parliamentary Debates, n.s. 1830, 1058Google Scholar.
39. Bank of England, Roehampton, box F29. While anyone who had taken a forged Bank of England note might have prosecuted the person who had uttered it, the cost of such a prosecution represented a powerful disincentive to taking action independent of the corporation's directions.
40. Committee for Law Suits, M5/307, January 3, 1805.
41. Committee for Law Suits, M5/307, August 20, 1805.
42. Committee for Law Suits, M5/316, February 22, 1816.
43. Committee for Law Suits, M5/321, October 23, 1818, October 30, 1818.
44. Committee for Law Suits, M5/324, January 17, 1821.
46. Committee for Law Suits, M5/313, May 12, 1813, May 26, 1813, July 28, 1813. In fact, Dale did not plead guilty at the July sessions at the Old Bailey. Instead he was tried and convicted of possession and sentenced to fourteen years transportation. OBP, Henry Dale, July 14, 1813, case t18130714–53. He petitioned the Bank to support his application to take his wife and children with him, but the directors rejected the request.
47. Bank of England, Roehampton, box F183.
48. Committee for Law Suits, M5/317, October 24, 1816. When he asked that he be spared prosecution entirely, his appeal was rejected (April 3, 1817). After his trial he wrote pleading for further mitigation, as he feared for his life among the convicts at Botany Bay. The request was rejected. M5/319, May 29, 1817.
49. Committee for Law Suits, M5/319, June 26, 1817, July 3, 1817.
50. Bank of England, Roehampton, box F23.
51. Bank of England, Roehampton, box F19. They did, however, send him two or three guineas for the offer.
52. Bank of England, Roehampton, box F21.
53. Bank of England, Roehampton, box F22. The Bank officials often lectured magistrates and constables on aspects of practical policing. In 1804, a Bristol alderman wrote to say that a man awaiting death had given him the name of a note manufacturer. The solicitors responded that nothing he could say would help as “knowing who fabricates notes without being able to take them is not much help.”
54. Bank of England, Roehampton, box F27.
55. Bank of England, F8/26.
56. Committee for Law Suits, M5/317, August 1, 1816. After his conviction, he again petitioned the Bank, asking for its intercession with the prince regent. The directors refused to act on his behalf.
57. Committee for Law Suits, M5/315, March 9, 1815, March 16, 1815.
58. Committee for Law Suits, M5/314, September 9, 1813, October 6, 1813.
59. Committee for Law Suits, M5/307, March 19, 1805.
60. Committee for Law Suits, M5/313, July 7, 1813, August 18, 1813; OBP, William Hughes, July 14, 1813, case t18130714–61.
61. Committee for Law Suits, M5/314, February 23, 1814, May 24, 1814.
63. Committee for Law Suits, M5/325, April 18, 1821. The Bank could be equally relentless with respect to those who appeared to escape its justice. Mary Robinson, alias Singleton, after declining the usual offer, had been tried at the Old Bailey in December 1820 and was acquitted of uttering. In 1821, the Bank once again proceeded against her for another instance of the crime. She was offered the liberty to plead guilty. This time she accepted the invitation and was transported for fourteen years. OBP, Mary Singleton, December 6, 1820, case t18201206–50, April 11, 1821, case t18210411–15; Committee for Law Suits, M5/325, March 23, 1821.
64. Committee for Law Suits, M5/308, March 23, 1809, May 4, 1809; Bank of England, Roehampton, box F30. For the fullest account of the Home Office procedures for handling appeals,see Devereaux, Simon, “The Criminal Branch of the Home Office, 1782–1830,” in Criminal Justice in the Old World and the New, ed. Smith, Greg et al. (Toronto: Centre of Criminology, 1998), 270–308Google Scholar.
65. Bank of England, Roehampton, box F26; Committee for Law Suits, M5/308, April 6, 1808.
66. Committee for Law Suits, M5/309, May 1, 1810. In 1816, Philip and Charles Froud, awaiting transportation, sent in a petition asking permission to take their wives and children with them. They reported making application to the secretary of state, “who signified that the Bank's consent must first be obtained.” In this instance, the Bank lent its support. Committee for Law Suits, M5/317, November 21, 1816. The Bank exercised the utmost vigilance over the final disposition of every case that touched its interests. In 1808, the committee considered the petitions of John Robinson at Bristol and Samuel Hulbert at Monmouth, each of whom asked that instead of transportation, he be permitted to enlist in the navy. Both pleas were rejected. As he did on several occasions, Kaye applied to the secretary of state to ensure that the convicts were transported to New South Wales as soon as possible. Committee for Law Suits, M5/308, June 23, 1808; see also M5/317, May 9, 1816.
67. Committee for Law Suits, M5/310, September 27, 1810.
68. Committee for Law Suits, M5/314, July 14, 1814, July 26, 1814.
69. Committee for Law Suits, M5/307, March 19, 1805.
70. Bank of England, Roehampton, box F31, Committee for Law Suits, M5/309, July 26, 1809.
71. Committee for Law Suits, M5/307, September 7, 1803.
72. Bank of England, Roehampton, box F46; Bank of England, F2/146. Similarly, in the case of Ann Lord, capitally convicted at Lancaster in 1817 for selling notes, the Bank was very pleased with the detailed account she provided of fabricators and dealers. The minute book records that “application was made by the Bank to the secretary of state by order of the governor on the 12th April last to respite her punishment, and afterwards on the 23rd April an application was made for a reprieve, upon condition of being transported for life.” Committee for Law Suits, M5/319, May 8, 1817.
74. Committee for Law Suits, M5/315, June 21, 1815.
75. One of the most extraordinary features of the Bank's relationship to “its” prisoners was the frequency with which the latter petitioned the former for small favors. The Bank received hundreds of requests for assistance in meeting the costs of prison and for purchasing supplies for the trip to Australia. It granted many of them, especially to women. Sarah Davis was convicted of uttering forged notes in 1811. While awaiting transportation, she was much distressed and wrote to the Bank for help. She was granted 7s. per week until she departed the country. Jane Williams, confined in Newgate in 1818, asked that the Bank “extend a little of that charity that is so kindly distributed to some of my fellow prisoners.” She received 5s. per week. Bank of England, Roehampton, box F180, 183.See Palk, Deirdre, “‘Fit Objects for Mercy’: Gender, the Bank of England and Currency Criminals, 1804–1833,” Women's Writing 11 (2004): 237–58,CrossRefGoogle Scholarand her forthcoming collection of letters from female convicts for the London Record Society.
76. Committee for Law Suits, M5/315, April 12, 1815.
77. Bank of England, Roehampton, box F23.
78. Bank of England, Roehampton, box F352.
79. Committee for Law Suits, M5/315, September 29, 1814, May 11, 1815, June 1, 1815; Bank of England, F2/78.
80. Bank of England, Roehampton, box F342, F343.
81. Hay, Douglas and Snyder, Francis, Policing and Prosecution in Britain, 1750–1850 (Oxford: Oxford University Press, 1989), 28–29.Google Scholar
82. Committee for Law Suits, M5/321, February 5, 1819.
83. Committee for Law Suits, M5/320, July 2, 1818. Randle Jackson expressed his alarm about the general perception of the Bank's activity to a meeting of proprietors. “He should constantly urge the necessity of demanding the interference of the Home Department, so that every prosecution might have the double sanction of the Bank and the Government, and might not appear, as now too many were inclined to think it, the vindictive act of [a] partial and interested body.”Bury and Norwich Post, September 23, 1818. Sir James Mackintosh made a similar charge during the debates over his proposal to remove the death penalty from forgery. “It was necessary at once,” he demanded, “to do away with that anomaly in the administration of justice, by which the prerogative of mercy was transferred from the Crown to the Bank of England.” ParliamentaryDebates, n.s. 1821, v, 1104. Sidmouth seems to have wanted to centralize decision making.Google ScholarSee Devereaux, , “Home Office,” 299–300Google Scholar.
84. One letter to the Times complained of the Bank “wresting from the hands of the Crown its most pleasing and endearing privilege—that of mercy.” “The victims,” the author concluded, “are selected in the Chambers of the Bank: where they choose who shall be saved, and whom they deem worthy to suffer death.” January 19, 1819.
85. Radzinowicz, Leon, A History of English Criminal Law (London: Macmillan, 1948–1986) 2:333–37;Google ScholarCommittee for Law Suits, M5/317, July 11, 1816.
86. Bank of England, F8/26.Handler, Phil, “Forgery and the End of the ‘Bloody Code’ in Early Nineteenth-Century England,” Historical Journal 48 (2005): 683–702;Google Scholar“Forging the Agenda: The 1819 Select Committee on the Criminal Laws Revisited,” Journal of Legal History 25 (2004): 249–68Google Scholar.
87. Bank of England, F8/26.
88. In looking back at this period, the Bank solicitors concluded that jury discontent was exaggerated as a problem. In their experience, they wrote, the outcome was “more affected by the tenor of the judge's charge than by any feeling of juries.” Bank of England, F8/26. For the influence of the judges,see Beattie, , Crime, 342–46.Google ScholarThe Bank had long paid attention to the composition of the juries that tried its cases. One agent wrote to warn Freshfield, in 1820, that his counsel should object to a juryman who had stood out for a considerable period against a guilty verdict in a Bank case. “Several of my friends,” he reported, “who were upon the jury say he will not convict in any Bank case.” Bank of England, Roehampton, box F62.
89. Annual Register, 1818, 57, 182, 232–36;Google Scholarfor evidence that judges upon occasion created problems for the Bank, see F8/26.
90. Bank of England, Roehampton, box F61; Committee for Law Suits, M5/321, March 31, 1819.
91. Bank of England, Roehampton, box F70; Committee for Law Suits, M5/325, October 17, 1821; OBP, Joseph South, October 24, 1821, case t1821024–51. Hobhouse wrote for Sidmouth, the latter perhaps feeling piqued, requesting that in future briefs in capital cases in London be sent directly to him.
92. Committee for Law Suits, M5/335, July 9, 1823; Peel Papers, Add. Mss. 40299, ff241–43, 40315, ff89;Gatrell, , Hanging, 563–64;Google ScholarThe Diary of Henry Hobhouse, ed. Aspinall, Arthur (London: Home and Van Thal, 1947), 104Google Scholar;OBP, Samuel William Miles, June 25, 1823, case t18230625–62. By 1823, the Bank was no longer prosecuting for forgery of notes under five pounds, but it continued to pursue those who committed forgeries of notes of five pounds and above.
93. Peel and the Bank were in frequent communication during the debates over the reform of the criminal law with respect to forgery. There was no distance between their positions. On February 26, 1830, John Phillips wrote on Peel's behalf to the Bank, in a letter marked “strictly confidential.” “If any part of the bill,” Phillips added, “should appear to you to require revision with reference to the interests of the Bank of England, I will thank you to communicate your sentiments to me as early as possible, in order that Mr. Peel may have an opportunity of fully considering your suggestions before he submits the measure to Parliament.” Bank of England, F8/26. Freshfield was the Peel family solicitor, and he was a loyal Peelite when he served in Parliament.Slinn, Judy, A History of Freshfields (Guildford, Surrey: Biddles Limited, 1984), 44, 65.Google ScholarFor the heated debate over Peel and the gallows,see Gatrell, , Hanging, 566–85;Google ScholarHilton, Boyd, “The Gallows and Mr. Peel,” in History and Biography, ed. Blanning, T. C. W. and Cannadine, D. (Cambridge: Cambridge University Press, 1996), 88–112;Google ScholarDevereaux, Simon, “Peel, Pardon, and Punishment: The Recorder's Report Revisited,” in Penal Practice and Culture, 1500–1900, ed. Devereaux, Simon and Griffiths, Paul (Basingstoke: Palgrave, 2004), 258–84Google Scholar.
99. In debate, in 1821, Thomas Fowell Buxton charged that the prosecutor in recent forgery cases showed “no pity—a pride rather in inexorable and unbending severity.” “The very feelings of our nature, the very quality of mercy,” he concluded, “seem utterly to have been forgotten.” The nation, he warned, “rebelled against such continual slaughter”; it would not cooperate in the execution of justice. Parliamentary Debates, n.s. 1821, v, 916. In the same year, a legal advisor to the Bank wrote to the solicitors that he did not think it could “be said with truth, that the punishment of death has been found by experience to be ineffectual for the prevention of such offences.” “Conviction for crimes of this description,” he argued, “has been almost invariably followed by execution, and I firmly believe that the severity and certainty of punishment has greatly operated and does still operate to restrain the commission of those offences by those who have daily opportunities of committing them.” Bank of England, F8/25/ In 1830, Freshfield wrote with asperity of “the persevering means used by persons of morbid feeling to induce others not to do their duty as prosecutors, witnesses, and jurymen.” Such efforts “may have had some effect,” he admitted; “I have encountered my share of attacks in private and public.” “But I am convinced,” he concluded, “that in the case of forgeries upon the Bank justice has not been impeded by any supposed severity of the law.” Bank of England, F8/26.