1. On Stonehenge Down in the Parish of Amesbury in the County of Wilts there are a group of stones and surrounding earthworks which are together known as Stonehenge. Stonehenge which is of very great antiquity originally formed an ancient building and place of assembly for public worship the burial of the dead deliberation on public affairs or other public purposes and since it has ceased to be so used has remained a national monument and place of resort of great public interest. 2. Until the acts of the Defendant hereinafter complained of there was and there now ought to be free access for the public to Stonehenge by means of roads running up to and through the same the sites of which roads are shown on the plan hereunto annexed and are thereon coloured green. 3. The said roads were at the time of the said acts and are public highways for all His Majesty’s liege subjects to go and return on foot and with horses and carriages at all times of the year at their free will and pleasure. 4. Stonehenge is subject to a trust created by a grant or declaration of trust which if in writing has been lost or by a Statute which has been lost for the free user by the public of Stonehenge as a place of resort and for the free access of the public thereto by means of the said roads and the site of Stonehenge has since the creation of such trust been held by the owners thereof for the time being subject to the said trust. 5. The Defendant has lately erected and maintains and threatens and intends to maintain upon Stonehenge Down aforesaid fences along the lines shown upon the said plan and thereon coloured red. The said fences obstruct the said roads or some of them at the points marked respectively A. B. C. D. and E. on the said plan and are obnoxious to and interfere with the rights and privileges of His Majesty’s liege subjects referred to in paragraphs 3 and 4 hereof. 6. The Defendant has been requested to remove the said fences but he has refused and still refuses to do so and threatens and intends to maintain the same and the obstructions hereinbefore complained of. The Plaintiffs therefore claim— 1. An order that the Defendant remove the said fences where they respectively obstruct the said roads or any of them. 2. An injunction to restrain the Defendant his servants workmen and agents from erecting upon the said lands or any part thereof any fence or other erection so as to obstruct and from in any way obstructing the said roads or any of them. 3. Costs. C. GURDON. R. B. FINLAY. * * * * * 1904. A. No. 335. In the High Court of Justice. CHANCERY DIVISION, MR. JUSTICE FARWELL.