The case of Rex v. Almon 1 was a minor incident in the epic struggle between the courts and the press which occupied the middle of the i8th century, and Sir John Fox's studies of its history happily coincide with the bicentenary of Wilkes' birth.2 His criticisms are already well known: the case was duly argued before Wilmot, J., and his fellows, the court was about to give judgment when it was found that the rule had been erroneously entitled Rex v. Wilkes instead of Rex v. Almon, and in consequence the proceedings were dropped. That was in i765. In i802 the papers of the late judge were published by his son, and among them is a draft of the judgment he had proposed to give if the case had got that far. It is this document which had the singular fate of becoming a leading case on attachment for criminal contempt. Wilmot there asserted that the issuing of attachments for contempts out of court stands upon the same immemorial usage as supports the whole fabric of the common law, and to this clear issue of historical fact Sir John Fox has directed his studies. Although the draft-judgment was not published until i802, the doctrine was very soon laid before the public by Blackstone, who is known to have consulted with Wilmot on some points and may have done so here, if one may judge from verbal similarities. Hotly disputed by the pamphleteers and occasionally criticised from the bench, this procedure was finally accepted in the i9th century on the strength of Wilmot's historical arguments. The author searchingly examines the history of the various elements in the situation -contempt, attachment, and examination -in order to test this alleged antiquity. Naturally, libel on a judge or court is essentially a press offence and it is needless to seek medieval precedents; the nearest seem to be cases where parties to litigation abused process-servers, the classical device being to make them eat their writ -parchment, wax, and all.3 The author adduces abundant evidence for the proposition that the medieval courts on occasion would summarily commit strangers for contempts in the presence of the court, and officers and parties for contempts in or out of court, although there are also cases where jury trial was employed. But the most laborious search has failed to produce a case where a stranger was summarily dealt with for a contempt out of court. As for attachment, the word has been curiously twisted during its history. At first it meant only process to secure appearance in court, and might be by gage and pledge or by the body; but once the party was in court, attachment did not prejudice in any way the mode of trial. Only in modern times did the word imply that the trial would be by examination and not by jury. The history of trial by examination is therefore involved, and here Sir John Fox has matter of particular interest. Interrogatories were employed by the council from the early x4th century onwards, and by the I6th century were characteristic of the chancery and star chamber. It appears that the common law judges were often present in the council and took part in these examinations and occasionally imported this procedure into their own courts, particularly in cases where an official was charged with forgery or deceit connected with the court and its machinery. When, under the Tudors and early Stuarts, attacks were made on the court of high commission for using the oath ex officio, they retorted that they were not unique in using trial by examination, for the common law courts also used examination instead of juries in several instances. To show that this contention had no foundation in