resembled the penal systems of discipline which reached their maximum of cruelty in the nineteenth century. But there seems good reason to believe that the Church’s treatment of its prisoners remained, on the whole, mild and humane. The clergy were not hardened prison officials; their calling was spiritual rather than military. They were dealing with men belonging more or less to their own order, and were prone to class loyalty.[450] In the light of subsequent criticism and legislation,[451] it seems that even after Islip’s ordinance the Church’s convicts were much better treated than were the laymen in the common gaols. Moreover, either (or both) from a sense of humanity,[452] or because the bishops disliked having to pay for the keep of their prisoners,[453] long sentences were avoided and life sentences were inflicted as rarely as possible; the prisoners would be pardoned[454] on jubilees and special occasions, and sometimes released on their friends paying ransom (apparently of such sums as £20 or £40; _vide_ Lea, _Studies in Church History_, p. 202, and the statute 23 Hen. VIII. c. 1). The State all along appeared on the side of severity, and, from the thirteenth century, was in the habit of sending clerks to their bishop _absque purgatione_, who, in theory at least, were to be life prisoners. Indeed, if the ordinary should attempt to release such persons, he could be restrained from doing so by a writ out of the Chancery.[455] So early as 1238 a Bishop of Exeter[456] was in trouble for having sent a certain clerk to purgation. Later on an Abbot of St. Albans[457] was accused of allowing some prisoners to escape; and there are doubtless other instances. But evidently the prisoners of the bishops were continually being released, for we find a special statute[458] passed in the year 1402 forbidding that clerks found guilty of treason (of less degree than plotting against the king himself), or who were known to be common thieves, should be allowed any sort of purgation. In 1485 an Act[459] was passed by which the bishops might commit priests, clerks, and religious men to ward and prison for advowtry (_i.e._ adultery), fornication, incest, or any other fleshly incontinence, and they were not to be liable for actions for wrongful imprisonment. In 1487 a severe blow was aimed at immunity. By this Act,[460] clerks (_i.e._ such as could read, but who were not actually within orders) were to enjoy their privilege only once; and to ensure that they should no longer be “continually admitted as oft as they did offend,” it was ordained that clerks not within orders, who should hereafter be convicted of murder, should be forthwith branded[461] by the gaoler in open court with the letter M upon the brawn of the left thumb, and, if found guilty of theft,[462] with the letter T, before being handed over to the ordinary’s officer.