Historical Development of Legal Systems

8/12/2019 Historical Development of Legal Systems

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UNIVERSITY OF THE WEST INDIES

FACULTY OF LAW

Law and Legal Systems

Wors!eet No "

T!e H#stor#$al De%elo&ment o' Commonwealt! Car#((ean Legal Systems

Case Notes

D) Note: Colonies are classified either as i)settled or ii) conquered or ceded. The extent towhich the territory had already been civilised atthe time of takeover will determine theclassification. If there was no oulation or noform of !overnment considered civilised and

reco!ni"ed in international law# ossession isconsidered to be by settlement. $here therewas an or!anised society to which internationalersonality is attributable# acquisition isconsidered to be by conquest or cession % see&alsburys 'aws of (n!land thed.# vol. * ara+,,.

T!e e*tens#on o' Engl#s! law to t!e $olon#es

Settled terr#tory

Rex v Samuel Vaughan -//. 01234onday 05th6ov. 75*1)

In the course of 8ud!ment in this case# the court

considered whether an (n!lish statute or thecommon law of (n!land alied to 9amaica inthe circumstances of the case. 'ord 4ansfieldsaid 3at . 02,,):

The ar!ument is stron!# that these statutes donot extend to 9amaica; thou!h they wereenacted lon! before that island belon!ed to theCrown of (n!land.

If 9amaica was considered as a colony# 3which itou!ht to be# the old inhabitants havin! left theisland#) then these statutes are ositivere!ulations of olice# not adated to thecircumstances of a new colony; and therefore no

art of that law of (n!land which every colony#from necessity# is suosed to carry with themat their first lantation.

6o


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rincile# all land in the Cayman Islandsbelon!ed to the ?overnment sub8ect only tosuch estates as mi!ht have been !ranted toersons subsequent to its settlement as acolony. Gwnershi by the ?overnment was thenatural consequence of the introduction of thecommon law of (n!land by the first settlers ofthe Islands.

DUFFUS+ Ag, -, said# at . *:

I am satisfied that the Cayman Islands must bere!arded as settled territory# and that theersons who settled in the Cayman Islands mustbe deemed to have taken with them to theCayman Islands the common law of (n!landwhen they first settled here in the early 75 th

century. H.Gwnershi of land is vested in the?overnment of the Cayman Islands sub8ect onlyto such estates as may have been !ranted toany erson or ersons subsequent to thesettlement of that colony. It is my view that theaellants in this case failed# as I stated before#

to show any title whatever to the land# thesub8ect of this aeal. The title# therefore# isvested in the ?overnment.>

Blades v Jaggard371*7) $I/ 0,5

=er @toby C.9. 3at .07,D070):

@uch# then# was the state of the law in (n!landwhen the settlers arrived in -arbados in 7*02.$hat law did they brin! with them The law isstated thus in 7F &alsburys 'aws 3Frd (dn)# 7*:

The introduction of (n!lish 'aw into acolony does not carry with it (n!lish

(cclesiastical 'aw.

The followin! assa!e occurs in 2 &alsburys'aws 3Frd (dn)# *15:

The common law of (n!land and thestatute law existin! at the date of theformation of the colony aly to coloniesacquired by settlement# but statutessubsequently enacted do not aly unlessthey are exressly alied. This rincileis# however# sub8ect to this restriction#that so much only of the law of (n!land iscarried with them by the colonists as isalicable to their situation and thecondition of an infant colony. Thus# while

the !eneral laws of inheritance and ofrotection from ersonal in8uries areintroduced# it is not so with enactmentsrelatin! to the roerty of a !reat andcommercial nation# to olice and revenue#the (stablished Church# ecclesiasticalcourts# and similar sub8ects# which areinalicable to the colonial circumstances.

Gn the other hand# the Birst (dition of this work#Jol 77# +*# contains this assa!e:

$here a new and uninhabited country isdiscovered by sub8ects of the Ain!# theycarry their laws with them# includin! such#if any# of the ecclesiastical laws as arebindin! on them# and# in the absence ofany exress rovision# any church thenand there constituted by them is primafacie resumed to be or!anised on thebasis of those laws# so far as they arealicable in the articular case.

HH< further inference to be drawn from theNatalcase 337+*2)# F 4oo =CC6@ 772# 2 6ew/e 57# 70 'T 7++# 77 9ur 6@ F2F# 7F $/ 21#7* (/ F# =C# 77 Ki!est 3/el) 2+) is thatwhere there is an (stablished Church#ecclesiastical 8urisdiction is acquired; and in asettled colony ecclesiastical law will flow. @omesuort for this view will be found in the

8ud!ment of ?oddard# 'C9# inTerrell v Secretaryof State for the Colonies3712FE 0


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Con./ered terr#tory

Campell v !all0755) 7 CG$=. 0,.

This was an action that was brou!ht in ?renadaby the laintiff 9ames Cambell to recover fromthe defendant# $illiam &all# a duty of four and ahalf er cent. uon all !oods and su!ars whichCambell had exorted from the island of?renada# and which &all# as the collector of &is4a8estys taxes# had collected from him.Cambell claimed that the money was aid to&all without any consideration since the dutyhad been imosed by lawful or sufficientauthority.

The island of ?renada was taken by the -ritish

arms# in oen war# from the Brench Ain!. nderthe

-y =roclamation under the ?reat @eal dated the5thof Gctober# 75*F# &is 4a8esty !ave ower tothe !overnor of ?renada# with the consent ofthe Ain!s councils# and the reresentatives ofthe eole summoned in !eneral assemblies# tomake# constitute# and ordain laws# statutes# andGrdinances# for the ublic eace# welfare# and!ood !overnment of ?renada and theinhabitants thereof# as near as may bea!reeable to the laws of (n!land# and under

such re!ulations and restrictions# as are used inhis 4a8estys colonies.

&owever# before the arrival of the ?overnor in?renada and before the summonin! of theassemblies# his 4a8esty issued letters atentunder the ?reat @eal# dated the 0, th9uly# 75*#which# after recitin! that# in -arbados# and in allthe -ritish 'eeward Islands# there was a duty offour and an half er cent uon all su!ars# Lc.exorted; and that it was reasonable andexedient# and of imortance to his ma8estysother su!ar islands# that the like duty shouldtake lace in ?renada# roceeded as follows:

$e have thou!ht fit# and our /oyal will

and leasure is# and we do hereby# byvirtue of our rero!ative /oyal# order#direct# and aoint# that from and afterthe 01th day of @etember next ensuin!the date of these resents# a duty orimost of four and a half er cent. insecie# shall be raised and aid to us# ourheirs and successors# uon all deadcommodities# the !rowth and roduce ofour said island of ?renada# that shall beshied off from the same# in lieu of all

customs and imort duties# hithertocollected uon !oods imorted andexorted into and out of the said island#under the authority of &is 4ost Christian4a8esty.>

The question was whether the letters atentunder the ?reat @eal was !ood and valid to

abolish the reDexistin! Brench duties and in lieuthereof to imose the four and half er centduty.'ord 4ansfield held that since under theroclamation of 5thGctober 75*F the Ain! hadvested le!islative ower in the assemblies withthe consent of the !overnor and council# he haddivested himself of the ower to make law for?renada with the result that the letters atentestablishin! the four and a half er cent dutywas invalid and void.

'ord 4ansfields reasons aear in the followin!ara!rahs 3at .0,+D07F):

< country conquered by the -ritish armsbecomes a dominion of the Ain! in the ri!ht ofhis Crown; and# therefore# necessarily sub8ect tothe 'e!islature# the =arliament of ?reat -ritain.

The 0d is# that the conquered inhabitants oncereceived under the Ain!s rotection# becomesub8ects# and are to be universally considered inthat li!ht# not as enemies or aliens.

The Fd# that the articles of caitulation uonwhich the country is surrendered# and thearticles of eace by which it is ceded# are sacredand inviolable accordin! to their true intent andmeanin!.

The th

# that the law and le!islative !overnmentof every dominion# equally affects all ersonsand all roerty within the limits thereof; and isthe rule of decision for all questions which arisethere. $hoever urchases# lives# or sues there#uts himself under the law of the lace.


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that articular dominion; as for instance# fromthe laws of trade# or from the ower of=arliament# or !ive him rivile!e exclusive of hisother sub8ectsHH.

It is left by the constitution to the Ain!sauthority to !rant or refuse a caitulation : if herefuses# and uts the inhabitants to the sword or

exterminates them# all the lands belon! to him.If he receives the inhabitants under hisrotection and !rants them their roerty# hehas a ower to fix such terms and conditions ashe thinks roer. &e is intrusted with makin!the treaty of eace: he may yield u theconquest# or retain it uon what terms heleases. These owers no man every disuted#neither has it hitherto been controverted thatthe Ain! mi!ht chan!e art or the whole of thelaw or olitical form of !overnment of aconquered dominionHH..

6o question was ever started before# but thatthe Ain! has a ri!ht to a le!islative authority

over a conquered country; it was never deniedin $estminsterD&all; it never was questioned in=arliament. Cokes reort of the ar!uments andresolutions of the 9ud!es in Calvins case# lays itdown as clear. If a Ain! 3says the book) comesto a kin!dom by conquest# he may chan!e andalter the laws of that kin!dom; but if he comesto it by title and descent# he cannot chan!e thelaws of himself without the consent of=arliament.

-ut HH.. after full consideration we are ofoinion# that before the letters atent of the 0, th

9uly# 75*# the Ain! had recluded himself fromthe exercise of a le!islative authority over theisland of ?renada.

The first and material instrument is theroclamation of the 5thGctober# 75*F. @ee whatit is that the Ain! there says# with what view#and how he en!a!es himself and led!es hiswordHH

Mou observe# there is no reservation in theroclamation of any le!islature to be exercisedby the Ain!# or by the !overnor and councilunder his authority in any manner# until theassembly should meet H..

$e therefore think# that by the tworoclamations and the commission to ?overnor4elville# the Ain! had immediately and

irrecoverably !ranted to all who were or shouldbecome inhabitants# or who had# or shouldacquire roerty in the island of ?renada# ormore !enerally to all whom it mi!ht concern#that the subordinate le!islation over the islandsshould be exercised by an assembly with theconsent of the !overnor and council# in likemanner as the other islands belon!in! to theAin!.>

D) Note: $hat this case decides is that the

Ain!# havin! romised to the inhabitants a localle!islature# and havin! by his commission to the!overnor authorised the convocation of anassembly# could not afterwards imose a tax onthe island# or exercise any le!islative authorityover it.Shillingford v A"#" of $omini%a 371*5) 70$I/ 25

'ike ?renada# Kominica was taken from theBrench by the -ritish. Kominica was also thesub8ect# alon! with ?renada# of the /oyal=roclamation of 5 Gctober 75*F by which owerwas !iven to the ?overnor to summon a !eneralassembly and with the consent of the counciland the assembly to make laws for the ubliceace and welfare of the Colony. -efore theassembly could meet and before any laws weremade locally# the 6ullum Temus


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!rown out of local circumstances in ?reat-ritain# were intended to have a local oerationonly. 3@eeA-G v Stewart337+75)# 0 4er 7F#F2 (/ +12)# in which the effect of thisroclamation to ?renada was discussed.)

Thou!h Kominica was sub8ect to the control of=arliament# statutes assed after the

romul!ation of the roclamation would not# inmy oinion# extend to Kominica without exresswords showin! the intention of =arliament thatthey should.>

=er ?ordon 9.


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< writer of considerable authority on theconstitutions of Commonwealth and Colonialterritories exresses a view in conformity withthat stated in 2 &alsburys 'aws 3supra).


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by virtue of a =roclamation almostcontemoraneous with that alicable to Ceylonbut which omitted any reference to Oolice#OOinstitutionsO or Oministerial officers.O What hesaid( ho'ever( 'ould in their Lordships)vie' apply also to Ceylon to arogate anyrule of la' previously in for%e there underthe government of the *nited +rovin%es if

it 'as in%ompatile 'ith the British%on%ept of the exer%ise of sovereignauthority y the Cro'n" It is thereforenecessary to consider first whether the existenceof a relationshi which ossessed any of thele!al characteristics of a contract between theCrown and a erson aointed by the ?overnorin Ceylon to serve in the civil administration ofthe territory would have offended a!ainst thefundamental concet of the ri!hts andimmunities of the soverei!n at the close of theei!hteenth century.

In their 'ordshisN view there is no suchincomatibility. In the ei!hteenth century the

rincial officers of the executive !overnment ofa colony were aointed directly by the Crown in(n!land by letters atent. This method ofaointment may well have been inconsistentwith the creation of a contractual relationshibetween the Crown and the aointee# but the=roclamation was local in its ambit and wouldnot affect the le!al relationshi between theseofficers and the Crown. It alied only tosubordinate officers in the civil administration ofthe !overnment of Ceylon who were aointedlocally by the ?overnor and removable by him.It is now well established in -ritish constitutionaltheory# at any rate as it has develoed since theei!hteenth century# that any aointment as aCrown servant# however subordinate# is

terminable at will unless it is exressly otherwiserovided by le!islation; but as ointed out by'ord


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was found not to be incomatible with (n!lishlaw# rovided that the contract between the civilservant and the -ritish Crown was terminable atwill. To that extent# existin! Kutch law wasmodified desite the terms of the =roclamationwhich aeared to continue Kutch law in forcewithout qualification.Engl#s! law re$e#%ed as a res/lt o' a lo$al

stat/tory &ro%#s#on

Jemmott v +hang371*F) * $I/ ++

=han! carried on the business of a bettin! ool.Gn the second day of the (aster race meetin! atnion =ark# 9emmott laced bets a!!re!atin!P0, on the second race at =han!s ool and inthe result won P2#2F0.2,. =han! refused to ay9emmott his winnin!s# alle!in! that he hadlaced his bet after and not before the race andin the result 9emmott the resent action torecover the money he won. In answer to9emmotts claim# =han! relied solely uon s 7+

of the nited Ain!dom ?amin!


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is unlimited both in its area and# asre!ards the individual# in its effects; and#as oosed to that# you !et statutes whichmay well be ublic because of theimortance of the sub8ects with which theydeal and their !eneral interest to thecommunity# but which are limited inresect of area%a limitation which makes

them localDor limited in resect ofindividuals or ersons%a limitation whichmakes them ersonal.

The ?amin! .=articularly so# I think# is its s 7+ the terms ofwhich I have already quoted above.

The third condition is# therefore# satisfied.There remains a fourth%that no enactment inoeration in Trinidad on 7 4arch 7++# or noneassed after that date# ne!atives or otherwiseaffects the oeration and effect of the ?amin!

$oodin! C.9. went on to find that the =oll-ettin! Grdinance did not ne!ative or affectsection 7+ of the A ?amin!


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ualifications as local circumstancesrender necessary.>

In relation to the words in italics# Kennin! '.9.said 3at . *2F):

There are# however# the rovisos to beconsidered. The first says that the common law

is only to be in force

so far as the circumstances of therotectorate and its inhabitants and thelimits of &is 4a8estys 8urisdiction ermit.>

This roviso does not oust the rero!atives ofthe Crown. It is lain that the 8urisdiction of theCrown in the rotectorate has been extended sofar as to include everythin! connected with theeace# order and !ood !overnment of the area;and the Crown rero!atives certainly comewithin that descrition. 4oreover if it wererelevant I would add that the ower to !rant afranchise of tolls comes within the very words of

the a!reement with the @ultan for it confers onthe officers of the -ritish !overnment fullowers in re!ard to the levy of tolls>.

The next roviso says# however# that thecommon law is to aly sub8ect to suchqualifications as local circumstances rendernecessary>. This wise rovision should# I think#be liberally construed. It is a reco!nition thatthe common law cannot be alied in a forei!nland without considerable qualification. 9ust aswith an (n!lish oak# so with the (n!lish commonlaw. Mou cannot translant it to the

,ean'ell v ,ean'ell717E 0 K.'./. at *22

The (n!lish =arliament had assed a statutewhich extended (n!lish law to 4anitoba. Itrovided as follows:

Bor the removal of doubts# &er 4a8esty#by and with the advice and consent of the@enate and &ouse of Commons of Canada#declares and enacts as follows:

7. @ub8ect to the rovisions of the next

followin! section which deals with interestonlyE the laws of (n!land relatin! tomatters within the 8urisdiction of the=arliament of Canada# as the same existedon the fifteenth day of 9uly# one thousandei!ht hundred and seventy# were from thesaid day and are in force in the =rovince of4anitoba# in so far as the same areappli%ale to the said +rovin%eH>3emhasis added)

In this case# the 4anitoba Court of


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1+ (./. F,+E; Cambell v &all# 'offt *221+ (./. ++E; 0 &owells @tate Trials 0+1.In the case of The

HH..

There are two reasons for holdin! that thestatute cannot be deemed to have beentranslanted to this =rovince or to form art ofour divorce 8urisrudence. Gne is that itsmachinery would have to be 8ettisoned andother machinery rovided. < further reason isthat the substance of the enactment is one forublic oinion# and action by the cometent'e!islature# if any.>

Leong v" Lim Beng Chye7122E


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ob8ect of the statute of mortmain was whollyolitical % that it !rew out of localcircumstances# and was meant to have merely alocal oeration. It was assed to revent whatwas deemed a ublic mischief# and not tore!ulate# as between ancestor and heir# theower of devisin!# or to rescribe# as between!rantor and !rantee# the forms of alienation. It

is incidentally only# and with reference to aarticular ob8ect# that the exercise of theowners dominion over his roerty isabrid!edH..

The two (n!lish universities# and three !reat(n!lish schools or colle!es# are exemted fromits oeration. This law cannot have the likeeffect in another country as it has in (n!land.There are some (n!lish ob8ects# in favour ofwhich an (n!lish testator may devise land inmortmain. -ut there are no colonial ob8ects infavour of which a colonial testator could sodevise. If there are universities or !reat schoolsin the colony# this law would not ermit a devise

to be made to them. If the le!islature of acolony were disosed to adot a similar law#they would surely not transcribe this act# as itstands# into their statute book. They would inall robability secify some useful institution orestablishment of their own# in favour of whichthey would made such an exemtion as is madehere in favour of the two universities# and thethree schools mentioned in the statute# or ifthey did not think it fit to make an excetion infavour of their institutions# they surely would notcontinue the excetion in favour of theinstitutions of another country. If this law werein force in ?renada# the consequence would be#that a Testator could not by will !ive an acre ofland for the suort of a school in the island#

while he mi!ht !ive his whole estate to au!mentthe endowments of an (n!lish colle!eH..

-ut# framed as a mortmain act is# I think it quiteinalicable to ?renada# or to any other colony.In its causes# its ob8ects# its rovisions# itsqualifications and its excetions# it is a lawwholly (n!lish# calculated for uroses of localolicy# comlicated with local establishments#and incaable# without !reat incon!ruity in theeffect# of bein! transferred as it stands into thecode of any other country. I am of oinion#therefore# that it constitutes no art of the lawof the island of ?renada# and that the (xcetionmust consequently be allowed.>

Cooper v Stuart37++1) 7


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of that kind. If the learned author had written ata later date he would robably have added that#as the oulation# wealth# and commerce of theColony increase# many rules and rinciles of(n!lish law# which were unsuitable to itsinfancy# will !radually be attracted to it; andthat the ower of remodellin! its laws belon!salso to the colonial le!islature.

Their 'ordshis have not been referred to any

Alterat#on o' re$e#%ed law (y s/(se./entlo$al leg#slat#on

Cooper v Stuart37++1) 7


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le!islative chan!es made in the country. The=rivy Council held that this had in fact haenedand that the -ill of /i!hts had been cu!t downby subsequent le!islation which authori"edhan!in! as the method of execution. 'ord @lynnsaid 3at 7577D7570):

4r. Bit"!eraldNs overridin! submission is thatthe -ill of /i!hts 7*+1 is H. an existin! law. The

rovision in the -ill that no cruel and unusualunishment should be inflicted therefore in itselfrevents han!in! bein! adoted as the methodof execution for the reasons which he has utforward and nothin! in the Constitutioninvalidates that existin! law.

It is to be remembered# however# that the -ill of/i!hts 7*+1 does not stand alone and it isacceted that# even thou!h the -ill is aconstitutional document creatin! fundamentalri!hts# the -ill may be cut down by clearsubsequent le!islative rovisions.

@ection of the Gffences a!ainst the =erson


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therein; and every reresentative'e!islature shall# in resect to the colonyunder its 8urisdiction# have# and bedeemed at all times to have had# fullower to make laws resectin! theconstitution# owers# and rocedure ofsuch 'e!islature; rovided that such lawsshall have been assed in such manner

and form as may from time to time berequired by any


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and must mean either contrary to some ositivelaw of (n!land# or to some rincile of natural

8ustice# the violation of which would induce theCourt to decline !ivin! effect even to the law ofa forei!n soverei!n state. In the former oint ofview# it is clear that the reu!nancy to (n!lishlaw which avoids a colonial


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construed in the wide sense 'ord Colerid!esu!!ested# would render any Colonial le!islationillusory alto!ether# because it is hardly ossibleto deal with the ri!hts of any -ritish sub8ect bythe local le!islature which shall not in some wayor another run counter to some rovision in thiscountry which is enacted for a different urose#havin! no secial reference to the circumstances

of the articular Colony. This statute reconcilesthe two rinciles of !ivin! local le!islation# but#nevertheless# leavin! still oen to the Imerial'e!islature by exress le!islative rovision theower to do somethin! in the Colony. @o muchfor the second oint ur!ed by 'ord Colerid!e.>

Li !ong ,i v Attorney #eneral of !ongong 710,E


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not otherwiseO in section 0 make it clear that=arliament was intendin! to deal with the wholequestion of reu!nancy. 4oreover their'ordshis doubt whether 'ord 4ansfield wasintendin! to say that what was not reu!nant to(n!lish law mi!ht yet be reu!nant tofundamental rinciles or to set u the latter asa different test from the former. $hatever may

have been the ossible ar!uments in this matterrior to the assin! of the Colonial 'aws Jalidity


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< bill assed by the 'e!islative Council of &on!Aon! is not a colonial law nor does it becomeone when resented to the ?overnor for hisassent. It becomes a law only when the?overnor has assented to it and it does as aresult of his assent. It is true that the assin! ofa bill in the terms of the roosed law is anecessary ste in the makin! of that law# since

the ?overnorNs ower of assent is restricted tolaws in the terms of bills assed by the'e!islative Council# but it is a ste which doesnot necessarily result in the makin! of any lawsince the ?overnor has a discretion to refuse hisassent.

It can be truly said about the conduct of the'e!islative Council in assin! a bill which# ifenacted by the ?overnorNs assent# would bereu!nant to an

D) Note: The above extract makes clear thatany law assed by a colonial le!islature which isreu!nant to an Imerial @tatute intended toextend to the colony is null and void and of noeffect. $hat the =rivy Council determined inaddition# however# was that the rocess ofenactin! such a law was not itself unlawful# eventhou!h the end result was of no effect.


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cause irrearable dama!e# is a sufficientfoundation 3or cause of action>) for thecomlainantNs alication to the court.>

T!e &ower o' t!e Im&er#al -arl#ament toleg#slate 'or t!e $olon#es

D) Note: The Imerial =arliament was alwayscometent to le!islate for the colonies# the onlylimitation bein! that it had to make its intentionclear in order for the colonial le!islate to bebound by its


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4.Ns detention therefore lawful# leave for suchaeal havin! been refused by the


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It has been ar!ued that the -ritish 6ationality


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6orth


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@tatute# a section which excludes from thecometence of the Kominion and =rovincial=arliaments any ower of Oreeal# amendmentor alterationO of the


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incororates as art of our law the common lawof (n!land# and since any decision of the &ouseof 'ords must be re!arded as the revailin! lawand# in so far as it interrets it# the common lawof (n!land# we must# whatever our own view#accet its 8ud!ment in Smith371*7E


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however# that his attention was drawn to 'ordKilockNs clear view exressed in Reg v (yam7152E


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exlained the reason thus 3371**)# 7, $I/ at =72):

In view of the rovisions of s F of theGffences a!ainst the =erson Grdinance andof s 70 of the @ureme Court of 9udicature; he referred to s F of the then Civil'aw of -ritish ?uiana Grdinance# Ca 0%>Thecommon law of the Colony shall be the commonlaw of (n!land#> then to 'ord =orters statementinReading v Attorney General37127E 7 3371FF)# 20 6U'/ at 225); /eed 9# statin! thatwhat was said in Russell v Russell 3710E -ut after the controversial@##v Smith371*,E F


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3Kominion) relation to the 8udicialauthority as recedents of decisions in(n!land. &itherto I have thou!ht that weou!ht to follow decisions of the &ouse of'ords# at the exense of our own oinionsand cases decided here# but havin!carefully studied Smith+s Case 3@## vSmith 71*,E F


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7,,7# 71*E F $'/ 72# 71*E 0


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Byard &osein @.C.@etember 0,77

Documents

Historical Development of Legal Systems