523 to use their new style in the present and for the future, but applied it to the past with such vigour that in Serjeant Hawkins's edition of the Statutes at Large (1735) the 1225 reissue of Magna Carta appears as Stat. 9 Henry III, cc. i-xxxvii. So, at some uncertain date, probably not earlier than Eliza- beth's reign, some lawyer or clerk attempted to bring the rolls of parliament up to date by inserting in the margin titles which the acts had not but presumably ought to have. The marginal headings from 1483 to the end of the century are in a late sixteenth-cent ury hand, and so are those for the acts of 1 and 3 Henry VIII. But those for 19 Henry VII and 5 (if not 4) Henry VIII appear to be contemporary, and this may be the evidence for Francis Bacon's statement that chapter headings begin in 5 Henry VIII. These are, however, the annotations of a clerk and no part of the act of parliament. No great harm was done as a rule by this posterior annotation, provided that we remember that these later titles have not only no legal, but no contemporary historical or philo- logical value. 1 But occasionally harm was done, and the marginal annotator of 3 Henry VII, c. 1, misled posterity so seriously that we must investigate at least the date of the annotation. Palaeo- graphers are cautious, and do not quite agree whether the shorter Latin or Ipnger English title is the earlier ; but neither is much earlier than 1550, and both may be considerably later. No printed edition, it may be remarked, has either of the two annotations before Pulton's edition of 1606, where one first appears in the margin, and his edition of 1618, where the other first appears as a heading. The spellings ' aucthority ' and ' star ' chamber and the use of ' Courte ' point in the same direction. Caxton has ' auctorite ' and ' auctoryte ', which were the regular forms till about 1550. Then an ' h ' is added, and by 1600 the ' c ' begins to drop out ; 2 the final ' e ' or ' ie ' gave place to ' y ' about the same time. ' Star ' is equally rare before 1 550 : ' sterret ' appears in 1454 ; 'sterred chamber ' 3 is the usual form in Henry VIII's reign, though ' sterre ' and ' starre ' are also found. ' My demeanors ' for ' misdemeanours ' I cannot evaluate. We find, therefore, that, so far as the text of 3 Henry VII, c. 1, is concerned, its reference to the star chamber dates from the latter half of the sixteenth century. The same conclusion is reached from a study of later legislation and of political writers. 1 Thus in the New Eng. Diet, this late sixteenth-century marginal note is cited under 1487, giving for that year the spelling ' authority ' used by the eighteenth-century editor of the Rolls of Parliament. Fortunately this eighteenth-century spelling of ' authority ' is not cited for 1487 s. v. ' authority ', but s. v. ' misdemeanour '. 2 Crompton in 1594 has ' L'Authoritie des Courts ', but he was writing in law French, and not in English. 3 This is the proper English for camera stellata, and is really conclusive against the fanciful Hebrew derivation. Chambers were generally known by their decoration, e. g. painted chamber, white chamber, green chamber all occur frequently in the records.
