522 STAR CHAM BEE UNDER THE TUDORS October chamber. Where and how, then, did the misleading marginal titles ' pro camera stellata ' and ' an acte geving the Courte of Star-chamber aucthority to punnyshe dyvers mydemeanors ', &c., come to be on the parliament roll ? This problem should probably not be studied in isolation. A long line of legal writers, Nathaniel Bacon, Blackstone, Dwarris, Hardcastle, Craies, have discussed the question when it became the practice to give a distinct title to each chapter or act in a statute ; 1 and they have most of them assigned different dates varying from 11 Henry VII to 5 Henry VIII. Not one is really correct because the question is not properly stated. There were no contemporary chapter headings made on the parliament roll before the sixteenth century and none of any date on the statute roll. But as soon as the printing of statutes begins we find brief headings supplied to each printed act, though without any enumeration. Caxton gives them, consisting generally of one word only, for all the acts he prints of the parliaments of 1485-9 ; and they gradually become more elaborate under the hands of successive king's printers, though remaining absent from the enrolments in chancery from which the statutes were printed. 2 These authorita- tive editions, printed by the king's printer from a copy supplied by the lord chancellor, and paid for by the Crown, became in time the texts which even lawyers and lawgivers cited in place of the rolls. Gradually the convenience of citation led to acts being not merely entitled but enumerated and cited by their numbers instead of merely by the place at which they were passed. 3 For the statute of Westminster II we get 13 Edward I, stat. 1, divided into fifty chapters, for the statute of Winchester we get 13 Edward I, stat. 2, and for the statute of Merchants 13 Edward I, stat. 3, while the writ circumspecte agatis is made into 13 Edward I, stat. 4. Some at least of Edward I's statutes were ' made ' in the sixteenth century. For, as always happens, men were not content 1 In Caxton each act begins simply with ' item ' and is an item in the statute ; sometimes the beginning is not even marked by a new paragraph, and it never is on the Statute Roll. Francis Bacon, Heading upon the Statute of Uses, 1642, p. 26, gives 5 Henry VIII as the date. 2 Letters and Papers of Henry VIII, new ed., i. i. 485 [4] : ' Warrant to the arch- bishop of Canterbury, Chancellor, to deliver to Richard Pynson, the king's printer, a true copy of the statutes lately passed in Parliament, that he may print them.' Cf. ibid. xiv. i. 1227, where John Husee writes on 7 July 1539 that the king's printer has delivered 1,500 copies of the statutes passed in the parliament of that year to the lord chancellor. There are frequent entries in the Letters and Papers of royal payments for printing statutes, proclamations, &c. Its control of the printing press was as useful to the Crown as its control of artillery, and both arose from the same cause : the Crown alone could afford to finance the earliest presses. 3 The regular holding of parliaments at Westminster had increased the incon- venience of merely place-names for statutes, and the Piggott MS. written about 1500 begins to describe medieval acts in the modern form with 1 Edward III. In Henry VIII's reign parliament itself begins regularly to refer to earlier statutes by regnal years, but chapter references to acts do not begin until a later period.
