recognized as part of the English constitution. For about a century and a half prior to the reign of James I. the criminal jurisdiction of parliament remained in abeyance, and bills of attainder were the vogue. The practice of appointing a steward on these occasions to execute judgment upon a peer was kept up till 1477, when George, duke of Clarence, was attainted, and then dropped. Under the Stuarts the criminal jurisdiction of parliament was again resorted to, and when the proceedings against a peer were founded on indictment the appointment of a steward followed as a matter of settled practice. The proper procedure in cases of impeachment had, on the contrary, never been defined. On the impeachment of Strafford the lords themselves appointed Arundel to be high steward. In Danby's case a commission under the great seal issued in the common form adopted for the court of the steward; this was recalled, and the rule agreed to by a joint committee of both houses that a steward for trials of peers upon impeachments was unnecessary. But, as such an appointment was obviously convenient, the lords petitioned for a steward; and a fresh commission was accordingly issued in an amended form, which recited the petition, and omitted words implying that the appointment was necessary. This precedent has been treated as settling the practice of parliament with regard to impeachments. Of the proceedings against peers founded upon indictment very few trials antecedent to the revolution took place in parliament. The preference given to the steward's court was largely due to the practice, founded upon the Southampton case, of summoning only a few peers selected by the steward, a practice which made it easy for the king to secure a conviction. This arrangement has been partially abrogated by the Treason Act of William III., which in cases of treason and misprision of treason requires that all peers of parliament shall be summoned twenty days at least before every such trial. The steward's court also differed in certain other particulars from the high court of parliament. For example, it was ruled by Lord Chancellor Jeffreys, as steward at the trial of Lord Delamere, that, in trials of peers which take place during the recess of parliament in the steward's court, the steward is the judge of the court, the court is held before him, his warrant convenes the prisoner to the bar, his summons convenes the peers for the trial, and he is to determine by his sole authority all questions of law that arise in the course of the trial, but that he is to give no vote upon the issue of guilty or not guilty; during a session of parliament, on the contrary, all the peers are both triers and judges, and the steward is only as chairman of the court and gives his vote together with the other lords. Lord Delamere was tried in 1685 in the steward's court; since then all trials of peers have taken place before the lords in parliament.