2. The records of the court of Star Chamber at The National Archives and elsewhere*

Daniel Gosling

The records of the court of Star Chamber are incomplete. The separation of material in the early seventeenth century means that today, the records preserved at The National Archives represent approximately half of the original Star Chamber archive. This chapter describes the current arrangement and content of these records, with reference to material held elsewhere, and explains how they survived when others were lost. It is not the first to do so, though it is a topic that often needs renewing. When Cora Scofield published her thesis on the surviving records of Star Chamber in 1900, the only records at the Public Record Office (as it was then known) outside of the dedicated series of Star Chamber proceedings were ‘a few estreats of fines’.1 In the twentieth century, Thomas G. Barnes and John Guy provided more detailed surveys of the Star Chamber collections, which identified related records to help piece together what was lost.2 Since the publication of these works much has changed. The Public Record Office was moved from its former home on Chancery Lane, London, to Kew and merged with the Historical Manuscripts Commission to form The National Archives of the UK.3 Three new Star Chamber series were added to the main collection, created from unsorted miscellanea.4 The paper catalogue moved online, incorporating descriptions of records held at more than 2500 archives across the United Kingdom. Most recently, The National Archives has embarked upon a project – the Star Chamber Archive – comprising catalogue improvements, the sorting of miscellanea and increased data connectivity, to draw together virtually Star Chamber material spread across record series and repositories.

The exact origins of a definable court of Star Chamber are uncertain. The 1641 act that abolished the court claimed it was created by Henry VII’s 1487 statute against liveries and retaining, which empowered the lord chancellor, lord treasurer and keeper of the privy seal to act judicially with the council.5 The 1487 parliament roll seems initially to support this. The act is annotated, ‘Pro Camera Stellata. An acte geving the court of Starchamber aucthority to punnyshe dyvers mydemeanors’.6 However, this annotation was a later, sixteenth-century, addition.7 The starred chamber (Camera Stellata) in the Palace of Westminster, from which the court took its name, had acted as a meeting place for the council to conduct business since its construction in 1347; an inner chamber was used for state business, while the outer chamber was used to hear petitions for justice.8 In the later medieval period, enquiries were made before the king and his council in the Star Chamber, defendants were ordered to appear before them to answer charges, and matters of legal ambiguity were taken there for judgement. The formal court probably developed from this judicial business.9

The main series of Star Chamber proceedings at The National Archives suggest at least a regularization of judicial business in the starred chamber around the accession of Henry VII; the earliest series of proceedings for the court – STAC 1 – contains records dating predominantly from this reign. The accumulation of proceedings in the sixteenth century necessitated the construction of nine large presses of wainscot in 1608 in the court room itself to house these records.10 However, even this could not accommodate the whole of the Star Chamber archive, and so a separate office was created in the Holborn court of Gray’s Inn.11 This satellite repository served as an office for the clerk of the court. Those records which the clerk needed to refer to most often, the decrees and orders for the duration of the court’s existence – which recorded, among other things, the final judgement of a case – as well as Caroline court proceedings, were deposited there for easy reference. A prudent decision at the time, but one that would ultimately lead to the loss of these records.

The fate of these records and the location of those now in the care of The National Archives are detailed in a report made in 1705 by John Lowe and Peter Le Neve, deputy chamberlains of the Exchequer. The ‘bills, answers, replications, etc, of the dissolved Court of Star Chamber’ – those records of proceedings formerly kept in the court itself – were reported as being in the Chapter House at Westminster, along with several other public records. After the court of Star Chamber’s abolition, these records had been put into the care of the usher of the Exchequer, until the foundation of the Annuity Offices in the 1690s prompted their move to the Chapter House.12 Lowe and Le Neve also noted that, ‘none of the decrees of the said court are to be found … they were [last] in a house in St Bartholomew’s Close, London’.13 That the records made it to St Bart’s gives us cause for hope that they survived, as the area was extraordinarily resilient to the many fires afflicting London in the latter part of the seventeenth century.14 However, they have not yet resurfaced.

It is remarkable that the remainder of the Star Chamber collection survives. In 1701, prior to their report on the contents of the Chapter House, Lowe and Le Neve wrote to Christopher Wren to complain that the glazing there needed urgent repair, because the ‘raine beats in & endamageth’ the records.15 An up-to-date report on the records of the Chapter House was made in 1719 by Dudley Downes and John Lawton, then deputy chamberlains. This report remarked that the Star Chamber records had ‘lain many years in a very great heap, undigested, without any covering from dust, or security from rats and mice’.16 Thankfully, since then the records have been better kept, and The National Archives now holds a substantial collection of Star Chamber material, drawn predominantly from this Chapter House collection.

There are four main types of record relating to Star Chamber. The first, original records of proceedings, makes up the bulk of the collection at The National Archives. Proceedings began with a bill of complaint.17 The bill was in English and outlined the matter at issue, including certain fictions alleging riot or other force that brought the matter within the court’s jurisdiction. These bills were often addressed to the monarch or lord chancellor and concluded with a request that the defendant appear to answer their complaint.

If the plea was accepted, a writ of subpoena was issued to summon the defendant.18 Before 1500, a precis of the order, or the prescribed date for appearance, was entered at the foot of the bill itself. If the defendant appeared, they provided a written answer, stating that the plaintiff’s complaint was false. If the defendant presented a demurrer – a denial of the court’s suitability to hear the matter – proceedings were stayed until it could be confirmed, usually by a common-law judge, that the matter should rightly be heard in Star Chamber.19 Defendants who submitted a failed demurrer were liable to pay costs and ordered to answer the plaintiff’s original bill.20 If the defendant did not appear, a writ of attachment was sent to the sheriff of the county where the defendant was ‘most resident’ to apprehend them. If the defendant could still not be found, the clerk of the court of Star Chamber could award a commission of rebellion to seven or eight named persons, authorizing them to apprehend and imprison the defendant.21 After the answer, the plaintiff made their replication, restating their complaint; this could be countered by a rejoinder from the defendant, again requesting dismissal. Even then the pleadings were not necessarily complete, as plaintiffs and defendants could respond with surreplications and surrejoinders.22

After the pleadings came the proofs, whereby the court tried to ascertain the truth of the matter. First, a set of interrogatories was drawn up by the plaintiff’s counsel and put to the defendant (by impartial examiners), dealing with each grievance in the bill of complaint. Following this, each side was allowed to draft interrogatories to put to witnesses.23 These pleadings and proofs make up the bulk of the records held at The National Archives in STAC 1–9. The third stage of proceedings was the trial hearing. If the defendant was found innocent of the charges laid against them, the judges dismissed the case (with fines put to the plaintiff). If they were found guilty, punishment could vary from a fine, to imprisonment, banishment or even corporal punishment.24 Throughout this process, and at the end of the case, the court created entry books for orders and decrees. The decree recorded the final judgement of a case; the orders recorded any court decisions made throughout proceedings.25 It is these entry books, along with the majority of the Caroline proceedings, which have not been seen since before 1705.

Original records of proceedings are arranged by reign in the series STAC 1–9. It is estimated that these records account for approximately half of the former Star Chamber archive, the remainder comprising the lost decree and order books.26 Some misfiling has occurred, and records relating to earlier and later reigns can be found among the proceedings for specific monarchs.27 The survival of each stage of proceedings varies. In some cases, particularly those that were settled out of court, only a single stage survives; others have preserved almost every part of the case.28 Pleadings, written on parchment, have a better rate of survival than the proofs, written on paper. In the nineteenth century, the majority of this collection was re-sorted, drawing together several elements of the pleadings and proofs into an alphabetical arrangement of files. However, STAC 5 and parts of STAC 8 retain their original eighteenth-century arrangement where different stages of pleadings were filed according to the first letter of the plaintiff’s surname. The proofs were gathered together, with separate sequences for examinations taken by the officers of the court and for depositions. Where documents have been preserved as a case file, it should be read in reverse. Thus, the bill will usually appear at the back of the file, with other pleadings and proofs arranged in reverse chronological order.29

STAC 1 is formed of the surviving records of equity proceedings heard before Henry VII’s council, comprising 135 items across two bound volumes. As there was not yet a clear distinction between Star Chamber and council proceedings, the records can only be ascribed to proceedings before the council during that reign, ‘which are analogous to Star Chamber proceedings, [and] may probably be accepted as such’.30 For this reason, material otherwise identical to that in STAC 1 can be found in other series relating to the judicial business of the council.31 The series also contains records of proceedings heard and determined by other conciliar courts, such as the court of Requests.32

During Henry VIII’s reign, particularly under the chancellorship of Thomas Wolsey (1515–29), the business of Star Chamber increased. STAC 2 – which collects Star Chamber proceedings for the reign of Henry VIII – contains over 6500 items across thirty-five pieces. A piece – often the archival level at which a reference becomes orderable – in STAC 2 can refer to either a bound volume or box of loose files. Despite bills alleging riot (to justify bringing the case before Star Chamber), the majority of actions related to disputed titles to property. STAC 2 contains some records from the reigns of Henry VI through to James I, caused in part by the generic address in a bill of complaint to the (unspecified) king. In several cases, further details in the body of the bill are required to date a document. One such record sees James Amore addressing ‘the king our sovereign lord’ in the bill; it is only from his citing his presence on the ‘fields of Barnet and Tewkesbury’ in the body of the bill that it can be dated to Edward IV’s second reign.33

Worthy, but incomplete, attempts to arrange STAC 2 in the nineteenth century mean that the first sixteen pieces (STAC 2/1–16) are bound volumes, broadly alphabetized by plaintiff. This sorting is not consistent across the whole series and other ‘A’ plaintiffs can be found among the remaining nineteen bundles (STAC 2/17–35), arranged as loose parchment bundles in boxes.34 Files relating to the same plaintiff, too, can be spread across several pieces.35 Royal officers are alphabetized by their office rather than surname; actions brought by the king’s almoner, most often concerning the goods of suicides, are therefore sorted as ‘Almoner’.36 As with STAC 1, documents relating to Star Chamber proceedings from Henry VIII’s reign can be found in other equity series.37 Since 2019, some catalogue descriptions for items in STAC 2 have been improved to include more accurate dates and a note recording document type (bills, answers, etc).38

STAC 3, Star Chamber proceedings for Edward VI, contains just over 1000 items across nine pieces. Despite his minority, most of the bills are still addressed to the king, though some are addressed to Protector Somerset.39 Business still mainly concerned civil proceedings, and files include actions of breach of contract, debt, fraud and tithe disputes. The impact of the Reformation can be seen from disputes over ecclesiastical jurisdictions and questions of title concerning ex-monastic land (commonly heard before the court of Augmentations). STAC 4, Marian Star Chamber proceedings, contains a little over 750 items across eleven boxed pieces. Proceedings from Mary’s reign, particularly after her marriage to Philip, are easier to identify and date because of the double address to the king and queen. Additionally, after 1556 the chancellor Nicholas Heath provided that all bills of complaint be endorsed with the exact date of filing.40

During Elizabeth’s reign, Star Chamber’s jurisdiction transformed from largely civil – as it had been under Henry VIII – to almost exclusively criminal.41 STAC 5, which forms the bulk of the Elizabethan Star Chamber proceedings, is by far the largest STAC series, comprising over 35,000 items across 982 pieces. It is also the only STAC series that retains much of its original eighteenth-century sorting. This is represented on the catalogue by a slightly different referencing system to other series. Bundles are arranged by the first letter of the lead plaintiff, and the piece number contains both this letter and a number. For example, STAC 5/G17/18 refers to the eighteenth item in the seventeenth bundle of ‘G’ plaintiffs.42 Royal officers, and certain other plaintiffs, continue to be sorted by their office. Cases relating to suicides or deodands (the object or instrument that was the cause of death, to be forfeited to the crown), within the jurisdiction of and brought by the queen’s almoner, are therefore sorted among the ‘A’ bundles.43 STAC 6 formerly contained supplementary Elizabethan proceedings, though was formally removed as a series in 1964 as its records had been absorbed into STAC 5 (a process begun in 1896).44

Part of The National Archives’ Star Chamber Archive project will incorporate new case references to Star Chamber proceedings. These do not appear on the records themselves but were created to make it easier to reassemble virtually separate parts of a suit. STAC 5, which provides the largest dataset of Star Chamber material in a single series, is the first collection to receive these case references, which will allow users to connect files relating to the same case spread across multiple pieces (and, when the project is complete, series and repositories).45 These case references and improved catalogue descriptions incorporate and supersede both the original four-volume catalogue created in the 1740s and indices created in the 1960s.46

STAC 7, comprising thirty-one pieces of around 1300 items, also contains Elizabethan proceedings. These differ from STAC 5 in that they went through the nineteenth-century re-sorting process that the majority of the Star Chamber collection underwent.47 Though they are not in their original letter bundles, they have been arranged in alphabetical sequence. The example of suicide and deodand cases brought by the queen’s almoner again illustrates this point.48 STAC 7 is arranged into three sequences, each commencing with the beginning of the alphabet. These are STAC 7/1–9, 10–16 and 17–31.49 For STAC 7/17 onwards, the subject is mostly listed as ‘incomplete’, denoting a file without a bill of complaint (though much information can still be gleaned from these records). At least two cases in STAC 7 indicate that the case was brought before parliament at some point, and several further cases note crown intervention.50

STAC 8, collecting Star Chamber pleadings and proofs for James I’s reign, is second in size only to STAC 5 and contains more than 8500 items across 314 pieces. This series has benefited considerably from the work of Thomas G. Barnes, most notably his three-volume list and index of these proceedings.51 During the compiling of this index, Barnes was given permission to reunite separate parts of many law suits, formerly arranged in separate files.52 Some documents in STAC 8 retain their original arrangement, whereby bills, answers and demurrers and replications and rejoinders were each filed in separate series according to the first letter of the lead plaintiff’s surname.53

In 2019, catalogue descriptions for STAC 8 were updated utilizing existing indices. The most noteworthy additions were subject categories for each case, taken from Barnes’s index. These subject categories reflect the change in jurisdiction of the court during the sixteenth century. The new subject search terms comprise: abduction, assault, attempt, compounding a felony, conspiracy/confederation, conspiracy to indict, contempt, counterfeiting, defamation, destruction of property, duelling, embezzlement, embracery, engrossing, extortion, forgery, fraud, hunting, lawyers’ offences, maintenance (including jury offences), officers’ malfeasance, offences against religion, perjury, proclamation contemned, religious differences, rescue, riot/rout/unlawful assembly, sedition, subornation, subversion, theatre, trade deceit, and vexatious litigation.54 There are several cases of note in STAC 8, including the case with the largest known composite fine for a single action, when twenty alien merchants were fined £151,500 for exporting bullion contrary to proclamation.55 The development of libel law, in line with the burgeoning print trade during this period, can be seen from the increase in ‘libel’ as a subject (‘defamation’ in the Barnes category descriptions); over 250 such cases appear in STAC 8.56 As the (alleged) libellous writings had to be included as evidence in the proceedings, this means that STAC 8 also contains several examples of early modern poems and songs.57

STAC 9 contains Star Chamber proceedings for the reign of Charles. However, this series is incomplete, only containing thirty items across two pieces. The bulk of the proceedings for Charles I’s reign were kept as ‘current’ proceedings with the decree and order books, and as such are missing. Those records that make up STAC 9 were originally sorted with Elizabethan material, hence their survival. In 1976, four items identified as Jacobean were re-sorted into STAC 8, to be reunited with their case files.58 At the same time, six pieces were moved to the unlisted miscellanea of the court of Requests (REQ 3), and some Caroline suits were added from the Star Chamber miscellanea in STAC 10. This miscellaneous Star Chamber series contains a further selection of Star Chamber proceedings. There are eighteen extant pieces in STAC 10, but at present only three – STAC 10/1, 2 and 4 – have item descriptions.59 From this small sample, it is clear that STAC 10 contains records from across the court’s existence.60

The catalogue descriptions for STAC 1–9 allow researchers to search for records by plaintiff and defendant surnames, subject, place and county. There are, however, caveats to this. Surnames, for instance, have usually not been standardized. If the bill does not survive, or is separated from its case file, it may be unclear who the plaintiff is, and if only an answer survives we do not always know how many defendants were named in the bill. Additionally, in some cases only the lead plaintiff and defendant are named; to discover the names of secondary defendants or plaintiffs, the original record needs to be consulted. Place names suffer the same spelling variants as surnames, and sometimes the only way to identify the correct place where an offence occurred is through searching the county. The county descriptions in STAC have made it possible for a number of local studies into the court of Star Chamber to be conducted, though researchers using the catalogue should be wary that in some instances abbreviations are used (e.g. Oxon or Oxford for Oxfordshire, Salop for Shropshire, etc).61 Apart from STAC 8, which adopts the subject terminology proposed by Barnes, item descriptions vary in subject matter. For instance, not all cases of piracy are described as such. Searching for ‘piracy’ in the catalogue would not identify the bill of complaint brought by Peter Alves of Portugal, who complained that his ship, the Santa Maria de Sae, was seized en route to Barnstaple in Devon. The accused then sailed his vessel to Ireland to sell to the mayor of Cork.62 Instead, one would have to do a broader search for the word ‘ship’. Catalogue improvement work aims to rectify many of these issues, creating standardized short titles and including details such as document type in item descriptions.

The similarity in jurisdiction and procedure between the different courts of equity means that Star Chamber proceedings can be found outside of the dedicated STAC series. E 111 – miscellaneous equity proceedings – encompasses all the main courts of equity at Westminster, including Star Chamber. Actions pertaining to Star Chamber can be found in this series by searching for actions brought before the council. In some cases, these records can be cross-referenced against the main series of Star Chamber proceedings. For example, a set of depositions in E 111, describing mortgaged lands in Mitcham, Surrey, relates to proceedings found in STAC 1 and STAC 2.63 The cross-referencing on the catalogue, however, is incomplete; as catalogue descriptions improve and miscellaneous series are sorted, further Star Chamber proceedings may be identified in E 111.

Another series of note is REQ 3, containing court of Requests miscellanea. The series currently comprises forty-four boxes, each holding between 200 and 300 items.64 At present, this series is unsorted, though a preliminary listing compiled by John Guy around 1970 identified some Star Chamber content. For example, a document in REQ 3/8 contains Star Chamber proceedings between John Bradway and Gyles Blyke.65 Now that parts of STAC 10 have been listed on the catalogue, it is possible to connect this record to a bill addressed to Wolsey from John Bradwey, a chantry priest, who complained that master Giles Blyke, lately imprisoned by the Star Chamber for words against the king, had ever since his release threatened to kill the complainant.66 As descriptions for both REQ 3 and STAC 10 improve, we can only hope that similar connections can be made. A more recent analysis of REQ 3 by Laura Flannigan has posited that there could be several thousand Henrician documents relating to Requests and the other conciliar courts in these unlisted boxes, which would undoubtedly link to cases in STAC 2 and identify previously unknown Star Chamber actions.67

Copies of Star Chamber proceedings also survive in private papers collected among the State Papers (SP 46). These private collections were often seized by the state as part of legal charges against the owners of these papers. One particularly complete set of proceedings is the matter of George Ireland versus John Daniell, heard in Star Chamber (and elsewhere) at the end of the sixteenth century, collected in Daniell’s papers (SP 46/50–56). A copy of the 1592 bill of complaint brought by Ireland lays out the grievance at issue. Addressed to ‘the quenes most excellent maiesty’, Ireland’s bill states that though he is entitled to the tithes of corn and grain in the lordship of Daresbury in Cheshire they were (illegally) granted to John Daniell.68 The same volume collects Daniell’s demurrer and answer, Ireland’s replication and Daniell’s rejoinder.69 Both Daniell’s depositions to Ireland’s interrogatories, and the subsequent depositions of William and Brian Palmer to Daniell’s interrogatories, are also preserved.70 Copies of orders of the court, made by William Mill, clerk of the council in Star Chamber, describe how Daniell was unable to proceed in this action because of a prior prohibition pending in the court of Queen’s Bench, while a second order appointed commissioners to hear witness statements.71 Proceedings between the two continued throughout the 1590s.72 This case also provides The National Archives with one of its surviving copies of Elizabeth I’s second great seal. The tag attached to the seal indicates it belongs to a dedimus potestatem addressed to Sir William Brereton and Thomas Smith in the matter between Daniell and Ireland.73 That this was related to the Star Chamber action is confirmed by the signature ‘Cotton’ on the tag. Throughout the reigns of Elizabeth I and James I, three generations of the Cotton family held the office of clerk of the process of Star Chamber, responsible for writing all of the writs issuing from the court under the great seal.74

Supplementing these records are documents mentioning Star Chamber proceedings, usually as part of other court cases. Exchequer depositions can refer to bills exhibited in the Star Chamber, or proceedings running concurrently with those in the court of the Exchequer.75 So, too, do some Chancery actions refer to related Star Chamber cases.76 Further proceedings are mentioned in PRO 30/27/16, containing records of Star Chamber and Chancery, and several other Star Chamber actions are referred to in the State Papers.77

The records created by the court – decrees and orders, writs and bonds – form the second key type of Star Chamber record. Although the entry books have been lost, some original drafts and copies of decrees and orders survive. In STAC 10, a draft order of Thomas More and other councillors in the Star Chamber on 21 November 1530 gives a sense of the sort of punishments the court doled out. The barber Thomas Barley was banished from Sudbury in Suffolk after losing a case against his fellow inhabitants, instructed to leave the town and live over seven miles away by Christmas 1531. If he was found within Sudbury after that, the mayor could place him in the stocks until ‘he be content to obey and observe and fulfyll this said decree and ordre in every poynte’.78 A later original order describes how Star Chamber interacted with other courts. The order deferred a court of Wards case until the next term, because the attorney for the court was sick.79 Based on these examples from the listed pieces, it is probable that further evidence of decrees and orders is contained within the unlisted material in STAC 10.

Chancery certifications also provide evidence of Star Chamber orders and proceedings that are now lost. A 1630 Star Chamber decree concerning the case between the Woodmongers Company and the Wharfingers and Carmen has no surviving original pleadings, but is described in the certified copies in Chancery.80 Mentions of decrees and orders can also be found in the State Papers, either as copies brought in with private papers, or collected with conciliar material.81

The majority of the original records of Star Chamber process are preserved in STAC 11, the filed writs for the court, and STAC 13, containing bonds. The earliest writs in STAC 11 date from Mary’s reign, though earlier writs survive attached to the proceedings for the cases they relate to in other STAC series.82 STAC 11 contains twenty-six pieces, amounting to several hundred individual writs, largely arranged by law term within each regnal year. Writs of subpoena ad respondendum began the court process, requiring the appearance of the defendant on a certain day under a ‘pain’, a penalty for non-compliance. These writs were issued out of Chancery under the great seal, returnable before the court sitting in Star Chamber. The wording of the writs (in Latin) required those named to appear before the council at Westminster, rather than naming the court of Star Chamber itself. This alludes to when the judicial court of Star Chamber and executive Privy Council were indistinguishable from each other. If these writs failed to summon the defendant, a writ of attachment was issued into the county in which they resided. The writs in STAC 11 often contain endorsements or notes by sheriffs, explaining that they had either served them or been unable to deliver them.

When these writs were successfully delivered, the defendant entered into a bond of (usually) £20 to answer their contempt of the original summons. Upon completion of a case, these bonds were usually returned to the party; those that were not returned survive in STAC 13. Their standard form bound the named defendant on pain of forfeit until the proceedings in Star Chamber were complete. The words of obligation are written in Latin and the conditions in English, either below the obligation or on the dorse. The bonds in STAC 13 almost all date from the second half of the reign of Elizabeth I, and most are countersigned by the clerk of the council in Star Chamber (and the body of text written in his hand), at this time William Mill. To save time, batches of blank bonds were created, the details of which were filled in at a later date. This meant that in some instances the date of the bond had to be amended when it was eventually used.83 The bonds were originally filed on a string or parchment thong, though only two pieces retain this arrangement. STAC 13/7 has a contemporary label describing its contents, which reads ‘Anno 38. Bondes taken and not redelivered the whole yeare bound together’ and ‘M 38,39’, and it contains bonds taken for the thirty-eighth year of Elizabeth I’s reign, including the Michaelmas term leading into the thirty-ninth year (November 1595 to November 1596). This bundle also includes a list of over a hundred ‘such persons as entred bond Anno 38 and the bonds not redelivered back’.84 Similarly, a note on STAC 13/18, ‘P’ 44o’, identifies the bundle as containing bonds for Easter (Pasche) from the forty-fourth year of Elizabeth’s reign (1601/02).85 A further twenty-two bonds for the same year are contained in Exchequer miscellanea.86

Financial accounts and original registers providing evidence of court business, personnel and the daily operation of the court make up the third type of record relating to Star Chamber. These records are particularly useful as they can be used to piece together information otherwise lost with the decree and order entry books. Records of fines imposed by the court can identify the outcome of some Star Chamber cases. The levying of fines was the responsibility of the Exchequer, and estreats were recorded on the king’s remembrancer memoranda rolls.87 Using these records, Barnes identified 122 estreats of Star Chamber fines for the period 1596–1641 and posited that enrolment of these fines occurred from at least as early as the beginning of Elizabeth’s reign.88 Fines and punishments of the court are also referred to in early modern deeds.89 It is likely, too, that some Star Chamber exhibits are preserved in deeds series, though the associated Star Chamber action is unlikely to be marked on the record.90 STAC 10 also contains records detailing the business of Star Chamber, including a list of active cases in Star Chamber for Hilary term 1526. Annotations note where causes were riots, how many people were involved and also whether bills had been answered, replied or examined.91

PRO 30/38, a set of fee books for writs issuing from Star Chamber for the period 1580 to 1633, provides further information about plaintiffs and defendants appearing in the court for the period, plus details about the court process.92 These registers, arranged chronologically, provide names of the parties to Star Chamber actions and of those to whom commissions were issued. The name of the defendant is given first, with the date on which the writ was returnable, then the words ad sectam (at the suit of) and the name of the plaintiff. To enable searches of the register, Star Chamber clerks entered the first letter of the lead plaintiff’s surname in the margin. In cases where writs were issued on behalf of the crown, notes in the margin identify whether it was the attorney general or the almoner working on behalf of the crown. This is significant when trying to connect these entries to surviving proceedings, as the short title will refer to the officer acting on behalf of the crown. Similarly, writs of privilege, issued on behalf of officers of the court of Star Chamber, have the word ‘privilege’ noted in the margin. These registers highlight much of the court process behind the records of proceedings contained in STAC 1–9. For every answer, rejoinder or witness deposition for the court of Star Chamber a writ was issued and noted in the registers. Writs of attachment have marginalia identifying the county into which the writ was issued. If the defendant had been committed to prison, these writs were instead addressed to the warden of the relevant prison.

PRO 30/38 also includes miscellanea which informs our understanding of Star Chamber personnel.93 One such record is an indenture acknowledging that John Mayne, John Meautys and John Sybley were granted the office of clerk of the writs and process of Star Chamber by letter patent on 26 May 1631, with one Thomas Saunders receiving the benefit.94 There were four key offices connected with Star Chamber: the clerk of the council in Star Chamber; the clerk of the process; the usher of the court; and the attorneys of the court. Three of these offices were granted by letter patent, and so the patent rolls (C 66) and their calendars can also identify personnel of the court. Attorneys were appointed by the lord chancellor or lord keeper.95 Other items in PRO 30/38 describe the rules for Star Chamber clerks taking fees, and lists the fees for Star Chamber process.96

The commissions on fees, taken in the early seventeenth century, provide information about the various functions of the personnel of Star Chamber and the fees they were paid. From these commissions, we know that working for the clerk of the council in Star Chamber in 1620 were: two examiners; the register; the clerk of the affadavits and the register of the rules of the clerk (the ‘under-register’); the clerk of the files and warrants; the keeper of the records; and the copying clerk.97 The records of the commissions on fees at The National Archives (E 215) contain several records pertaining to Star Chamber, including lists of fines, reports on fees in the court and a table of fees for the officers of the court.98 Another account in a miscellaneous Exchequer series describes how Thomas Ailway, an underclerk for the court’s register, was paid 10s for copying forty-six sheets of decrees for a party, at the payer’s discretion.99

With few surviving registers signifying when the court was sitting and who was present, the membership of the judges of Star Chamber must also be drawn from related accounts and registers.100 Generally, membership was similar to that of the Privy Council, with both often headed by the lord chancellor.101 The chief difference between the two groups was that the chief justices of King’s Bench and Common Pleas attended Star Chamber but not Privy Council. Some early accounts for the attendance of Star Chamber survive in the State Papers.102 A draft minute book for Trinity term 1525 in STAC 10 records the councillors present in Star Chamber on particular days and whether the king was in attendance, and notes which councillors were appointed to hear particular court proceedings.103 The most interesting surviving records detailing the membership of the court are the Star Chamber diet books, which recorded judges sitting, date of meeting and the cost of foodstuffs for the court’s meals. Many of these accounts survive from across the court’s existence.104 The earliest of these were created during Thomas Wolsey’s chancellorship.105 These Star Chamber dinners were not cheap; notes by William Cecil Lord Burghley on one of these accounts baulks at the cost of these meals.106 Later diet books for Star Chamber also mention structural work to the chamber itself.107 As with the Privy Council registers, each account noted which judges of Star Chamber were present. For example, the account for 10 October 1561 noted the presence of Nicholas Bacon, chancellor and lord privy seal, William Paulet, lord treasurer, William Cecil and others.108

The final key types of record concerning Star Chamber are the treatises and law reports written about the court and its cases, from which we know about cases and processes that are otherwise lost. Most of these records are held outside of The National Archives, with a couple of exceptions. The most complete volume at The National Archives is an early copy of William Hudson’s Treatise of the Court of Star Chamber.109 William Hudson was a trained lawyer who, during his career, served as underclerk, attorney and barrister for Star Chamber.110 His Treatise was a contemporary account of Star Chamber, completed in 1621. It considers the history of the court, its historic and current (in 1621) jurisdiction and how the court should function in future. Hudson’s Treatise is notable for citing over 500 Star Chamber cases. With the loss of the court’s decree and order books, these citations are often the only surviving record we have of these cases. The copy of Hudson’s Treatise held by The National Archives is not the author’s copy or the accepted most authentic text. The best extant version is thought to be one of the eighteen copies held at The British Library, which contains a 1635 memorandum claiming it to be in the handwriting of Hudson’s son, Christopher, and gifting the volume to Chief Justice Sir John Finch.111 The National Archives’ copy has some corrections in a second hand, and annotations on the flyleaves suggest it was acquired by purchase, possibly for the Tower Record Office.

Two less substantial treatises on the court of Star Chamber are collected in Exchequer miscellanea series.112 The first, a short collection of notes concerning Star Chamber, contains a copy of William Lambarde’s description of the court and its jurisdiction taken from his Archeion, as well as detailed descriptions of Star Chamber process and the fees incurred by plaintiffs and defendants.113 The second, a legal precedent book concerning various courts of equity, describes land law and practice in the courts of Requests and Star Chamber.114

The British Library holds several legal collections describing Star Chamber cases.115 One volume, containing notes on over 1000 items, records cases from the reign of Henry VIII and is particularly complete for the period 1552 to 1596.116 The folio reference to each order and decree book is noted against each item, which allows for a rough reconstruction of the size of the decree and order entry books for the period 1552 to 1596; eleven volumes, each containing between 250 and 500 folios.117 The details of cases in these volumes can also be used to improve descriptions for corresponding proceedings in The National Archives’ catalogue. A pilot project completed by Katie Bridger in 2020 utilized data from these law reports and cases and connected it to records in STAC.118

William Mill, who as clerk of the council put his signature to so many surviving records of Star Chamber at The National Archives, produced a similar set of notes on precedents and proceedings of the court at the behest of Lord Ellesmere. These volumes, along with several other records relating to Star Chamber, can now be found as part of the Egerton family papers (Ellesmere Manuscripts) at the Huntington Library in California.119 Star Chamber records can also be found in several other US repositories.120

Early printed volumes, written before the loss of the auxiliary Star Chamber archive, provide us with more evidence of otherwise lost Star Chamber material. John Rushworth’s Historical Collections, compiled while the court was still active, contains copies of over 150 entries in the decree and order books, and refers to reports for the first twelve years of Charles I’s reign.121 Other seventeenth-century publications, with either first-hand access to the court or to its surviving records, provide details about several other Star Chamber actions that have otherwise been lost.122

It is easy for the records of the court of Star Chamber to be defined by what no longer survives. No other court that proceeded by English bill suffered such a loss, and researchers working on Star Chamber are hampered by the hole left by the missing decree and order entry books. However, the survival of so many incidental records – of accounts, fines, law reports and treatises – means that there is a rich Star Chamber archive, albeit one spread rather more widely than those of most English equity courts. Taken together, these records help to fill the gap of the missing Star Chamber collection. This guide, and others like it, serve as a road map to these records, to advise researchers where to look for Star Chamber material and what to expect when it is found. While we wait patiently for the decree and order books to appear in some long-forgotten basement, we can take solace in the fact that thanks to the continuing work of researchers, volunteers and staff at The National Archives and other repositories, the Star Chamber archive is more complete and connected now than it has ever been.