Abstract
Of the many types of offenders who suffered the punishment of the pillory in the seventeenth and eighteenth centuries in England, one distinct group was those whose crimes related to the Royal Navy. The Navy's decision to pursue offenders in civilian courts, coupled with its decision to report on offenders, illustrates the importance the Navy placed on the pillory and the civilian courts in curbing fraud, which became a rampant issue from the mid-seventeenth century onward. The Navy expanded its operations but struggled to manage the increased complexity of its financial system, which was subsequently exploited by numerous sailors and civilians. The decision to prosecute offenders in civilian courts brought several issues: informers whose actions brought into question the efficacy of offering rewards, unruly crowds who attacked offenders, and unruly or uncaring offenders who tried to escape or undermine their stint in the pillory by not behaving as expected.
Of the many types of offenders who suffered the punishment of the pillory in the seventeenth and eighteenth centuries in England, one distinct group comprised those whose crimes related to the Royal Navy. Unlike other corporal punishments meted out to sailors by the Navy, such as flogging, which occurred mainly aboard Navy ships, the punishment of criminals in the pillory occurred both near Naval offices and in marketplaces in cities and towns across England; the potential audience was thus significantly greater for this type of punishment and comprised a broader spectrum of the English public. Another key difference was that these sentences were issued by civilian courts on land and were administered not only to sailors and other Navy personnel but also to civilians who defrauded the Navy. The Navy's decision to pursue offenders in civilian courts, coupled with its decision to report on offenders, illustrates the importance the Navy placed on the pillory and the civilian courts in curbing fraud, which became a rampant issue from the mid-seventeenth century onward. 1 The Navy expanded its operations but struggled to manage the increased complexity of its financial system, which was subsequently exploited by numerous clerks, sailors, and civilians. 2 The Navy's decision to prosecute offenders in civilian courts brought several issues the Navy did not have to contend with aboard ships: informers whose actions brought into question the efficacy of offering rewards, unruly crowds who attacked offenders and unruly or uncaring offenders who tried to escape their punishment or undermine their stint in the pillory by not behaving as expected.
The Navy faced difficulties for years in convincing the judges and juries of these courts of the dangers of fraud. As an institution at the forefront of the growing fiscal–military state that emerged in Britain in the late seventeenth century, the Navy was also at the forefront of fraud, the main issue arising from this monetary and administrative revolution. The Navy faced a danger to its finances and lacked the backing of a judiciary that had yet to develop a proper understanding of this new monetary threat. The government's increasing focus on fraud in the early eighteenth century led the Navy to secure more convictions for fraudsters to stand in the pillory. In the end, however, the consistent number of old offenders and fraudsters who refused to be shamed by their punishment undermined the efficacy of the pillory as a deterrent to Navy fraud. By the early eighteenth century, the same crimes would plague other government institutions, crimes the Navy had faced primarily and most prominently, and for which it had campaigned for the use of the pillory to deter. The perceived insufficiency of the pillory eventually led to its abandonment for a host of monetary crimes by the 1730s, as the broader fiscal–military state awakened to the danger first flagged by the Navy in the seventeenth century of such crimes to the very security of the state and its institutions.
Navy punishment and the pillory in early modern England
Corporal punishment was a traditional urban event across England, from the stocks and the pillory to public whipping. The Royal Navy also used numerous methods to punish sailors. Navy captains were allowed to order various informal punishments on subordinates for minor offences. 3 Summary flogging of sailors without trial was a common punishment that was carried out before the Navy community. 4 The Navy also used devices that restrained sailors aboard ships for long periods as a form of humiliation, although such punishments appear to have been discontinued by the eighteenth century. 5 The Navy had two main formal avenues for punishment: the High Court of Admiralty, which dealt with maritime offences ranging from issues of wages and prize money to piracy; 6 and the Court Martial, which, in contrast, was an internal court organised on occasion to deal with crimes such as desertion or officer misconduct. 7 Though the Navy did not punish sailors harshly, punishments did become more severe by the late eighteenth century as the relationship deteriorated between officers and sailors. Nonetheless, many sailors actually used the Admiralty Court extensively to protect their interests against the Navy hierachy. 8
The Admiralty Court also dealt with fraud and embezzlement by sailors, as well as civilians trying to exploit the Navy bureaucracy. The Admiralty Court was limited, however: it did not have the power to inflict judicial punishment on civilians. The Navy instead turned to civilian courts to prosecute civilians as well as impose judicial punishment on its sailors. The courts sentenced sailors and civilians to punishments in the main port cities and towns across England, a deterrent the Navy increasingly relied on after the Restoration. These sentences were not only a means for the Navy to gain justice against civilians, but they also offered a more public humiliation for sailors than being punished aboard a Navy ship.
The common sentence for fraud meted out by the civilian courts was the pillory, in which offenders stood restrained for hours, vulnerable to thrown objects or jeers from the crowd (Figure 1). Unlike whipping, which was increasingly reserved for poor offenders in the eighteenth century, the pillory served to undermine the reputation of gentlemen and established women. 9 In contrast to many punishments in early modern England, the pillory was used on both men and women without distinction. 10 It was well-suited for the Navy as, compared with the majority of crimes heard at the civilian courts, the Navy faced a disproportionate number of female offenders. The punishment of the pillory was an exercise of power by the authorities who sought to unify spectators on their side and mark the offenders out as the other: an assurance to people that authorities were proactive in protecting the public good. 11
‘The Punishment of the Pillory for Perjury Cheating, and Other Misdemeanors’, in John Seller, Booke of the Punishments of the Common Laws of England (1678). ©Guildhall Library. Reference no. AN 18.3.25.
London was regularly home to a large transient force of sailors. On occasion, the authorities faced difficulties executing the sentence owing to the presence of sailors, especially in the eighteenth century. 12 Offenders were usually punished near the people most affected by the crimes. In June 1698, for example, Edward Rigby, a naval captain, was convicted of sodomy at London.’s main criminal court, the Old Bailey, and was pilloried ‘by the Tavern where he endeavoured to play his prank’. 13 The pillory thus afforded local communities a sense of justice, part of a long tradition of involving the public in the punishment process. 14 Although the Navy brought fraudsters to the civilian courts and ceded jurisdiction, civilian judges still tied the punishment of these offenders to the Navy by ordering them to stand in the pillory both in the traditional sites for all offenders and also near the various Naval offices that dotted the capital.
The growth of regular news reporting in the late seventeenth century made news about those in the pillory more common. Reports from this period have survived in greater numbers, giving us a clearer picture than in years prior of how the event transpired. Another effect of the growth of news reporting was an increase in the audience for these punishments. Reports communicated the penalties for cheating the Navy far and wide, as well as the extensive reward system offered for informants. This coincided with a development whereby, owing to broad cultural and legal shifts after the Restoration, the maiming of offenders who stood in the pillory (branding or ear cropping) for fraudsters and forgers, as well as for other crimes, became far more selective as a punishment, as most offenders now only had to stand in the pillory. 15 The focus of the pillory began to rest solely on being exposed to the public and, ideally, feeling an appropriate level of shame. Zealous crowds could inflict great damage on those they felt deserved worse punishment; some offenders undermined the punishment by failing to behave contritely. 16 The former led to the injury and death of some offenders, while the latter prompted civilian and Navy authorities to question the effectiveness of the pillory in deterring fraud.
The rise in monetary fraud after the Restoration occurred amid the English Navy's growth and rising costs, leading to increased bureaucracy. From 1640 to 1680, the Navy witnessed a major increase in its size and scope, as well as the money involved in its enterprise, driven by England's commercial and warfare endeavours. The years after the Glorious Revolution witnessed an even greater expansion, as the Navy became the state's costliest enterprise, and the presence of military personnel in daily life grew. 17 The increased bureaucracy and the growing number of sailors created opportunities for civilians to navigate and exploit this bureaucracy, which led the Navy to seek prosecution for both sailors and civilians who attempted to profit from its expanding fiscal empire.
In response to the Navy's expansion, which was not met with an equal growth in cash funds, a system was developed in the mid-seventeenth century, in which sailors were given tickets in lieu of wages. This allowed the Navy to maintain solvency while also bringing thousands of civilians into the world of government securities. 18 As Tawny Paul argues, although the financial transformation across the late seventeenth and eighteenth centuries was driven by elites at the Royal Exchange, it also occurred at the Navy offices in London and Portsmouth. Fungible forms of debt allowed a broad swath of the public to become involved in England's financial empire. 19 The Navy, at the forefront of this financial revolution, was the first to experience its main threat: fraud. Long before public opinion solidified in the 1720s on the danger of such monetary crime to Britain's financial integrity, the Navy was expressing concerns by the 1660s about the need to excise such threats.
Forging naval tickets in restoration London
The expansion of trade in the mid-seventeenth century, the cost of naval warfare and the growth in the number of sailors led to a lack of funds to cover wages. The Navy subsequently developed a ticket system in order to delay payments. Fraud soon became an issue, involving sailors, clerks or civilians who forged, stole or fraudulently used tickets. The commodification of wages in the form of paper tickets was central to Britain's financial revolution. The Navy had to continue with tickets for the sake of its solvency, while also dealing with its consequences.
20
In the 1650s, fraud by Navy officers was often tolerated, within limits.
21
Fraud by sailors or civilians was not afforded the same degree of tolerance. Even by the early 1650s, Navy officials were noting the difficulty of preventing fraud. As the Navy Commissioners wrote in August 1653, the Navy office had discovered: many frauds, embezzlements, counterfeiting of tickets, and other abuses […] We wish some persons had power to prosecute them otherwise than by a course of law, or there will be little remedy; there is a tenderness to take away life, and many times want of clear proof as to condemning persons, though sufficient for inferior punishments.
22
Concerns over fraud became acute in the 1660s, at the end of the Second Anglo-Dutch War and the return of a large number of sailors. The introduction of tickets had been a contentious issue, as sailors resented a system that standardised payment delays. The diary of Samuel Pepys, head of the Navy Board, which was responsible for civil administration, contains frequent references both to delays and fraud regarding tickets. In February 1665, Pepys noted a conversation with Robert Waith, Navy paymaster, about the ‘abuse now practised in tickets, and more like every day to be’; in April, Pepys complained about a lack of understanding by Navy officials regarding the difficulty of preventing fraud. 23 Delays worsened owing to the Great Plague of 1665 and the 1666 Great Fire of London, leading financiers to flee London. In November 1666, Pepys complained of ‘every day thousands appear here, to our great trouble and affright, before our office and the ticket office’. 24
Resistance by sailors often ignited disturbances among civilians. 25 Descriptions of protests in early modern England suggest that they were mainly the domain of young men. 26 The Navy's gender balance exacerbated this dynamic. Particularly prominent by the 1660s were press gangs that forced men into service. The presence of young, underpaid sailors in port towns, disillusioned with service, was thus a common feature of the period. 27 The standardisation of the Navy in this period led to the formation of a strict hierarchical system, with codes of conduct that conflicted with the principles of sailor protests, based on collectivism and anti-authoritarianism. 28 Several studies have argued that the extent to which sailors were constrained by such codes has been overemphasised, arguing that tacit consensus and consultation marked seafaring life, with discipline among sailors and between sailors and officers being the norm. 29 As I shall discuss, both internal discipline and outward insubordination were features of the responses of sailors both to ticket fraud and to its punishment.
Richard Elkin, the Navy muster-master and liaison between the Navy Board and the civilian authorities, regularly corresponded with the board throughout the 1660s to discuss various issues, including crime. In December 1666, a man approached Elkin with suspicions that a ticket he had been offered was a forgery. Elkin apprehended the accused forger and brought him to a judge in Kent. Also in December, as well as January, hundreds of sailors gathered at the Navy Victualling Office in London to protest wage delays. 30 In March, upon confirmation of the forgery, the forger was jailed. 31 Elkin informed the Navy commissioners that the forger was sentenced to stand twice in the pillory. As was custom, his crime was written on a paper attached to the pillory to inform passers-by. 32 The forger was set to be pilloried at Gravesend, where Elkin was based. Gravesend was a traditional docking point on the banks of the Thames, and was an area where sailors regularly gathered. The forger was thus punished before the authorities and communities most affected by his crime.
In January and February 1667, some sailors went on mutiny and rioted in London, attacking Navy clerks. 33 As the forger was set to stand in the pillory, tensions among the sailors regarding tickets and payment were especially high; with the Second Anglo-Dutch War almost at an end, the number of sailors in London swelled, with many willing to congregate and vent their frustrations. 34 Elkin noted in his letter that he asked Sir John Heath, Justice of the Peace in Kent, who had aided in the prosecution, to advise the judge that, although the forger was ‘at their honours’ disposal’, the judge should punish the forger as desired by the Navy, to ‘prevent a mutiny’. 35 The Navy was evidently experiencing some issues with the civilian authorities, as Elkin pre-emptively asked the judge to follow his suggestion. He also complained several times in April that the sheriffs had delayed in organising the punishment. 36 On 8 May, the forger finally stood on the pillory in Gravesend.
The forger did not readily accept his punishment. On the first day, he had to be restrained by several sailors who had gathered, and was handcuffed under the orders of the mayor because he refused to stay still in the pillory. Elkin, in his report, complained that when the forger was finally fixed on the pillory, he boasted about his crimes and ‘did not value the disgrace’. 37 The sailors were keen to ensure the forger was punished and evidently congregated to witness the event. It appears that the sentence was passed only through their presence, not through the civil officers, whom Elkin does not mention in his report. Elkin also complained about the forger's behaviour in prison, as he gloried in his crime and claimed he would repeat it. 38 The sailors’ reaction is unsurprising, given the tension over tickets and the number of them present in London. Elkin's desire for the judge to punish the forger in a specific manner suggests that the Navy and the courts were at odds about how to deal with forgery. The unrest regarding tickets probably led the Navy to be keen to punish the forger. Perhaps Elkin had already experienced prior issues with forgers not being punished properly. Comments in the 1650s suggest that Navy officials were already exasperated by ticket fraud, but that the courts did not share this concern. Elkin's concerns about the judge's sentence suggest a continuation of the disparity between the Navy and the civilian authorities in how to curb fraud.
Elkin feared mutiny, believing that the failure to adequately punish the forger may provoke it, suggesting that the sailors also considered the crime severe and expected the Navy to uphold its duty. During this period, the presence of large numbers of sailors and their anger over wages led to intermittent rioting and disturbances, much to the Navy's annoyance. Some figures in this period enjoyed a tranquil time in the pillory owing to a receptive crowd, while others avoided the punishment with the help of their supporters. 39 The sailors’ anger was to the Navy's benefit, ensuring the forger endured his punishment, a service seemingly not offered by the civil officers at Gravesend. Sailors had long been protesting and rioting against the policies of their superiors, but when the Navy faced fraud as a result of a ticket system that it had introduced, the sailors’ collective action turned away from the Navy hierarchy. The punishment of fraudsters provided an outlet for the frustrations of sailors and relief for Navy officials, who were able to showcase to sailors that it would protect their wages. The Navy relied on its sailors as a coercive arm to ensure the sentence was passed.
In the early 1670s, a 1664 Act against stealing from Navy stores was revived, with an added clause targeting those who obtained wages fraudulently. 40 Cases of forgery appear intermittently in this period. At the Old Bailey in July 1675, two unnamed offenders were fined and sent to stand in the pillory on three occasions for forging tickets. 41 Across the 1670s and 1680s, embezzlement became a focus of the Navy. 42 Yet, apart from a few embezzlement and fraud trials, there is little evidence that the Navy regularly turned to the civilian courts. As Margaret R. Hunt argues, Navy fraud was not properly understood, and judges and juries often disagreed with the Navy about the severity of the crime or were unsure who the victim was. Institutional conviction was a relatively new process. 43 The Navy was also at relative peace for 15 years in the 1670s and 1680s, with a reduced fleet. Not only was there a limited number of sailors away from home whose wages could be stolen, but the maritime community was also in less financial distress, with fewer tickets to obtain fraudulently.
The Glorious Revolution: Growing bureaucracy and forgery acquittals
England's financial revolution from the 1690s onwards precipitated the exponential expansion of the fiscal–military state. 44 The subsequent outbreak of war with France and the War of the Spanish Succession at the turn of the century swelled the Navy's bureaucracy and financial expenditure. In an effort to enlist more men, the Navy expanded its ticketing system; the avenues for civilians and personnel to extract wealth from the Navy were expanded as well. 45 The swelling expenditure of the Navy was the subject of satires regarding ‘upwards of four and Twenty Millions of the Peoples Money unaccompted for to this day’. 46 The financial revolution heightened concerns about fraud. Some contemporaries called for a change in how the crime was punished, while others, mirroring the complaints by Navy officials in the 1650s, feared that juries would be reluctant to impose the death penalty. Others called for the earlier punishment for forgery, i.e., mutilation, to be revived. 47
Along with the growing fiscal–military state and growing concerns over monetary crimes, broader developments also occurred in the English justice system, affecting how Navy crimes were punished. Several studies have argued that in the eighteenth century, the justice system changed dramatically as a result of heightened upper-class fears about security and finances. A class conflict emerged, part of an endeavour by elites to gain hegemony via the submission of the populace. The elite judiciary expanded its repressive powers without consideration for popular sentiment; crimes against goods, property and finances, particularly committed by the lower classes, became more severely punished. 48 More modern arguments have challenged these views, arguing that elites did not wish to alienate the lower classes, as their support was crucial to the functioning of the justice system. Leniency is evident in the use of the justice system to lessen its pernicious nature, as this system was not a tool of elites but was tempered by social norms, values and popular sentiment. 49 As I shall discuss, many examples of the treatment of Navy offenders by the courts and the attitudes expressed by Navy officials in the eighteenth century provide a ballast to modern arguments, as they showcase a desire to protect Navy elites at the expense of the Navy's low-ranking personnel.
When examining records at the Old Bailey, offenders unrelated to the Navy who were tried for forgery received similar sentences to those given to Navy fraudsters: a fine, imprisonment and at least one stint in the pillory. 50 The records, however, suggest that the Navy faced forgery more regularly. Navy reports on fraud, which became common from the 1690s onwards, suggest that the Navy was keenly aware, long before other institutions, of the damage fraud caused not only to its short-term finances but also its long-term security. In May 1693, Richard Gibson, a former clerk at the Victualling Office, wrote to the Navy Board warning of the need to protect the wages of sailors to ensure their loyalty and avoid revolt. 51 While commentary emerged in the 1690s on the dangers of fraud, members of the Navy, at the forefront of this growing financial apparatus, were aware from early on of the threat of such crimes to the legitimacy and security of the state.
By the 1690s, Navy wages ranged from £18 to £34, while the amount of money held in its stores could be significant. 52 Tensions over wages became acute in this period, with protests and unrest at ticket offices, and work stoppages resulting in sailors being executed. 53 In 1697, a statute on fraud and embezzlement was revised, with £200 offered for information leading to a conviction. 54 The Navy was at the forefront of the dangers of the financial revolution in the form of fraud, as well as how to tackle it: although rewards for prosecutions were not novel, the system the Navy introduced in the 1690s became a significant part of the judicial process in the early eighteenth century, owing to growing concerns about crime. 55 An important development for the Navy was the establishment of the position of solicitor as chief legal counsel. Legal counsel for the Navy Board had operated since 1673, but in 1692, a distinct office was created. 56 The first to assume the office was Edward Whittaker, who wrote detailed reports to the Navy Board on his dealings with the civilian courts, noting the crimes, the Navy's efforts to bring prosecutions and its views on the efficacy of publicising crimes in newspapers.
The creation of the position did not mean, however, that the opinions of civilian courts and the Navy regarding fraud became entirely aligned. Some men accused of fraud successfully argued to the courts that they had forged tickets with the permission of sailors, simply to gain wages without the bureaucracy. 57 Even among Navy officials, older attitudes towards fraud by officers remained forgiving. High-ranking gentlemen generally enjoyed support from the Navy when facing trial. In 1698, for example, Captain Stephen Elliot, set to be tried at the Old Bailey, petitioned the Navy for witnesses to defend his character. 58 Such policies could clash with the desires of other officials, such as Whittaker, to prosecute fraud. In the spring of 1695, he failed to convict several officers, with suggestions that the character witnesses provided by the Navy prevented their convictions. 59 Uncertainties about whether those brought to court by the Navy would be convicted are illustrated by a complaint by Whittaker in August 1695, in which he asked the Navy Board not to give any rewards to those who have reported embezzlement until the offenders in question had been convicted. 60
Along with developments in the Naval bureaucracy to tackle fraud, avenues opened up for sailors to circumvent pay issues, which also provided opportunities for fraud. A common practice was for sailors to employ ‘public receivers’ to buy their wages, who were civilians, often women, operating a ticket-buying business. 61 In Gibson's report in May 1693, he complained of fraud and ‘the evils of tickets falling into the hands of buyers’. 62 The gender pattern of naval crimes is an anomaly compared with the broader crime statistics of early modern England, in which far more men were prosecuted than women, a trend that became pronounced in the late seventeenth century. 63 In contrast, the Navy faced a relatively even number of male and female fraudsters. As part of the growing fiscal–military state, women became prominent figures in navigating naval bureaucracy. 64
From the mid-1690 s onwards, a slew of trials for naval fraud began to appear at the Old Bailey. In 1695, Leah Wilkinson was acquitted of fraudulently claiming several seamen's wages. Anne Lowe, her mother-in-law, had run a ticket-buying business with Wilkinson. At Wilkinson's trial, however, ‘a defect in the Indictment’ was found, so she was acquitted. 65 Acquittals were not distinct to the Navy: at the London criminal courts from 1690 to 1800, 38% of defendants were acquitted. 66 The acquittals of suspected fraudsters are thus not simply a reflection of a disjointed relationship between civilian judges, juries, and the Navy. Yet the charge of defect or flaw in the indictment, as well as a lack of sufficient witnesses or evidence, plagued the Navy, despite strong indications of the accused's guilt. In 1696, suspicions about Wilkinson were again raised. 67 Later that year, affidavits were given to judges about Wilkinson, although no prosecutions were brought. 68
Civilian courts were not the only avenue for the Navy, as cases of fraud and embezzlement were also investigated by the Court of Admiralty, whose secretary fulfilled the same role as the solicitor of the Navy and similarly delivered reports. Such sailors and officers were not publicly punished but rather dismissed, fined, or suspended by the Admiralty Court. 69 In lieu of prosecution at civilian courts, several suspected fraudsters in the mid-1690s, including Wilkinson, were ordered by the court to return money obtained via tickets. 70 The practice of returning money suggests perhaps a concern in the Navy about gaining convictions in civilian courts. The Navy thus relied on the Court of Admiralty to issue fines. In 1695, a year after Martha Rawlinson was fined by the court, in a pattern that would repeat, Rawlinson was instead informing on other suspected fraudsters in order to gain rewards. 71
A series of successful convictions occurred the same year as the dismissal of Wilkinson's initial case. There is little information available, with no report from Whittaker: we know that, in May, a woman and a man, and separately, another woman, were prosecuted for fraud. The pair convicted together were fined over £4, ordered to stand in the pillory on three occasions in Tower Hamlets, close to the Victualling Office, and were also imprisoned. The informant on one of the cases, Luke Bennet, complained about not receiving a reward. 72 Punishments tried in London courts generally occurred in spaces near the Navy Offices, as well as the Royal Exchange, one of three ‘usual places’ for all types of offenders to be pilloried in this period. 73 Court orders often reference the Navy's three offices in London. 74 Temporary pillories were sometimes set up in unique spaces, but the regularity with which the Navy used the locations and the fact that courts did not offer instructions on setting them up, which courts did on other occasions, suggest that they were permanent. 75 Such permanent devices dominated the landscape, serving as reminders of Navy authority. 76
As shown in Figures 2, 3, 4, the areas around the offices were spacious, allowing large numbers to congregate. The locations served to highlight the Navy's jurisdiction and guaranteed a large contingent of sailors. As we have seen in the case of the forger at Gravesend, sailors could prove useful. Some figures who stood in the pillory in this period, such as Daniel Defoe, Nathaniel Mist or Robert Harrison, arranged for their friends to gather to ensure they enjoyed a tranquil time. Sailors instead ensured the opposite. In turn, the punishments highlighted to these sailors the danger of defrauding the Navy and the Navy's power to punish them. Similar to how the punishment of fraudsters allowed sailors to vent their frustrations, reports to the Navy board in the 1710s suggest that these punishments also served the purpose of reassuring officers stationed at these Navy offices, who may have been harmed by the crime, that the Navy would exact justice: for example, in March 1713, regarding a case of stealing from naval stores, the solicitor informed Henry Lee, the commissioner in charge of said stores, of the offender's sentence to stand in the pillory, ‘for his satisfaction’. 77
Benjamin Cole, ‘The Navy Office in Broad Street’ (1756). © Image Courtesy of Yale Center for British Art. Accession No: B1977.14.15187.
Thomas Taylor, ‘The Navy Office in London’ (Crutched Friars) (1714). © British Library Board. Shelfmark: Maps K.Top.25.5.
Figure 4: Navy Victualling Yard and Little Tower Till. © Barron, C. and Merritt, J. F. (2007). Digitised Images of Maps and Plates from John Strype’s Survey of London [Data files]. Available at: https://www.dhi.ac.uk/data/strype (18 May 2026).
The year 1696 was a busy one for the Navy. At the Old Bailey in July, two women and a man were found guilty of fraud: all were fined and ordered to stand in the pillory at the Pay Office, Cheapside and the Royal Exchange. 78 Also that year, Whittaker investigated a plot involving several officers as well as a number of women pretending to be relations of dead sailors in order to claim wages. In a pattern that became common, only the low-ranking member of the group was punished: Christian Brothers, a young woman who did not enjoy the support from the Navy that would allow her to escape her sentence. Whittaker perhaps learned from his failure that year when the officers were acquitted. He organised several witnesses and promised to ‘provide for’ them. By August, some witnesses were complaining that they had not been given the promised reward. 79 Whittaker names nine suspects in his report, including the officers, whom he describes as the ring leaders. 80 Only Brothers stood trial, with no mention of the others in court, where she is portrayed as the sole operator. Unlike the officers acquitted earlier that year, Brothers ‘could not call any People as to her Reputation’. She was fined the significant sum of £133 and ordered to stand in the pillory three times. 81 Whittaker was still working on the case in December 1697, but no indictments were issued against the other suspects. 82
That same year, the statute on fraud was passed, offering more securities than Whittaker's promise to ‘provide for’ informers. The Navy also began to use the growing newspaper industry. The pioneering role of the Navy in this period's financial innovation found parallels in its early adoption of newspapers to publicise the consequences of fraud, alerting the public to the danger of the crime from an early stage. The government's London Gazette contained a lengthy section from the Navy on various matters, including rewards. Soon after the statute was passed, the Lords of Admiralty often wrote in Gazettes promising ‘protection and encouragement’ for informers. 83 By the late 1690s, the promise of rewards had become common: as one informant noted in 1699, the Navy ‘did promise me encouragement, (as frequently in the gazette they have done others)’. 84
Successful convictions followed in 1697: Christopher Dickenson was found guilty of fraud at the Old Bailey, fined £1, 13s, and 4d, and ordered to stand in the pillory at Charing Cross and Tower Hill, near the Victualling Office. 85 Yet despite new acts passed by Parliament to deter Navy crimes, Whittaker still faced issues with prosecutions, often because of ‘a defect in the indictment’. The encouragement of informants also led to issues. For example, in 1698, when Whittaker brought a case of embezzlement involving 20 suspects forward to the courts based on the information of two informants, the judges notified him that he had ‘not the power (by the said act) to try the same’. He complained that the 1697 statute was ‘defective’, as Whittaker could only prosecute some of those involved for the lesser crime of trespass. 86 Whittaker accused the informants of being involved in the scheme and ensuring that the indictment was insufficient. The informants claimed instead that Whittaker awarded appointments and money to fraudsters and had used his office to enrich himself, thereby discouraging legitimate informants and ensuring that embezzlement would continue. 87
The suspicions regarding Whittaker were seeemingly well-founded, as he was then embroiled in a financial scandal in 1701. He petitioned Parliament, noting his service dealing with ‘Forging seamens tickets, letters of attorney … imbezlements of stores’. 88 The informants’ claims were seemingly widely suspected: that year, a satire appeared criticising the Navy's increased expenditure, with a section on Whittaker's misconduct, which Whittaker even references in his petition. An issue raised was the Navy's use of witnesses: ‘Instead of prosecuting the real offenders, several of ‘em were made witnesses’. There is even a mock list of receipts with costs for ‘entertaining offenders’ tasked with ‘finding offenders’. The satire concludes that such misconduct led the courts to refrain from pursuing prosecutions. 89 The policy of paying witnesses and turning criminals into informers was thus a widely known policy. In turn, the Navy's difficulty securing convictions was a known problem; to those who satirised the Navy, unchecked spending and a lack of care for justice were the root causes of the problems in court. It probably did not help the Navy in its battle against fraud that some contemporaries did not trust either the Navy's growing financial empire or those in its bureaucracy, such as Whittaker, tasked with defending this empire.
The 1710s: Growing convictions and disparities in punishments
Whittaker was subsequently dismissed, and the position of solicitor remained vacant until 1703. In the interim, other figures in the Navy, such as Thomas Lechmere, assumed the duties of solicitor. 90 In late 1701, Lechmere refused to cash tickets owned by Wilkinson, but did not prosecute her. 91 While those who worked in the Court of Admiralty may have succeeded in recovering stolen money, the Navy's continued efforts to bring cases to civilian courts into the eighteenth century suggest that the Navy believed that the ideal deterrent was a judicial sentence. Under the direction of the new solicitor, John Warter (1703–1718), whose detailed reports survive in great number, several fraud and embezzlement cases were prosecuted. The decision in 1703 to merge the position of Secretary to the Admiralty, which dealt with fraud cases for that Court, with Warter's role suggests an intent by the Navy to move towards the civilian courts to deal with fraud, and away from relying on the fines issues by the Court of Admiralty.
By the 1710s, naval fraud, at least its detection, seems to have grown substantially: Warter's report to the Navy board in 1716 on the arrest of seven people laments that ‘There are several other persons that are under Indictments in order to be tryed the next Sessions for the like offences’. 92 Old problems resurfaced in the civilian courts, such as a lack of witnesses. 93 Nonetheless, there was a slew of convictions in the 1710s. The increase in cases was probably affected by the end of the War of the Spanish Succession. Another development that helped the Navy to punish fraud was the hardening of public attitudes towards the crime. The danger of fraud to the prosperity of the state and its institutions was becoming apparent beyond the Navy. 94 The judicial backing received by the Navy from the 1710s onwards ensured that offenders regularly stood in the pillory for fraud.
Alongside this concerted effort to use the courts to punish fraudsters, the Navy increasingly utilised newspapers. In January 1711, several people were charged at the Old Bailey and put in the pillory for wage fraud. A notice was placed in two London Gazettes detailing their names, crimes and punishments, which finished with: ‘This is to give Notice thereof, for deterring others from the like Practices’. 95 By the 1710s, Gazettes regularly contained news on the punishment of Navy fraudsters in the pillory, always with the comment ‘deterring others’. In contrast to other offenders sentenced at civilian courts, notices of which were published across various newspapers, notices of the crimes and punishments of Navy offenders were predominantly published in the London Gazette, and were isolated from reports on other crimes. Reports of Navy crimes were covered in other newspapers as part of a list of others sentenced at a particular trial session. 96 By this period, the Navy regularly noted in Gazettes that it was receiving letters with information on fraud and other crimes. 97 Navy offenders were similarly isolated from other offenders at London courts after the 1710s: the use of the pillory at the Royal Exchange waned, with the Navy offices becoming the sole locations. 98 This decision, probably influenced by the Navy, reinforced the symbolic nature of the punishment for fraud, just as prosecutions increased and newspapers began consistently reporting on these cases.
The trials of several people for fraud in January 1711 were followed in February by the trial of Hannah Gibson Bruce, prosecuted for attempting to fraudulently obtain Navy wages. Her case is the earliest for which a detailed report from Warter survives. He wrote to the Navy board that he had ‘caused’ Bruce to be prosecuted at the Old Bailey. She was fined only 3s, 4p, a relatively minor amount compared with other cases examined thus far, but was ordered to stand on the pillory near the Navy Office and the Pay Office. Warter wrote that he would put ‘publick Notification in the Gazett for deterring others from the like Practices’. 99 Unlike reports in most newspapers, which often contained only a brief mention of the offender's sentence, the notice on Bruce is especially detailed: it notes that she was convicted at the Old Bailey, where she was set to stand, and how she committed the fraud. The report finishes with the common remark that the notice was for ‘deterring others’. 100
Across 1711, not only fraud or forgery, but also embezzlement, became a focus of Warter, who organised witnesses to attend trials at the Old Bailey and advertised sentences in Gazettes. 101 In early 1712, Wilkinson was finally convicted, accompanied by a report by Warter, which reads similarly to his report on Bruce, mentioning her crimes, how he caused the prosecution and asking for her crime to be published. 102 She stood in the pillory at the Pay Office and was imprisoned for a month. Similar to Bruce, a detailed report on Wilkinson, for the purpose of ‘deterring others’, was published in the Gazette, referring to her as an ‘old offender’ owing to her history of fraud. 103
Some frauds were especially serious and required exemplary sentences. In September 1716, John Potten was charged at the Old Bailey with trying to obtain wages by forging signatures of the Lords Commissioners of the Admiralty, who served on the Board of Admiralty. Potten schemed with the help of a Navy clerk to receive over £1000. He had even threatened to inform on the clerk, presumably to claim a reward. 104 Warter, in his report to the Navy board, wrote that he had received ‘a very exemplary sentence’: Potten was imprisoned for a year, fined £100, and pilloried at the Pay Office. Warter asked the Navy Board to advertise his conviction because it was ‘so exemplary’. 105 The notice in the newspaper about Potten explains how fraudsters were obtaining money by removing ‘r’ (noting deserters) from pay tickets, while others used forged documents. A detailed account is then given of Potten's crime, trial and sentence. 106 The notice serves several purposes: it highlights the prevalence and danger of fraud, explains how to recognise the common tactics of fraudsters so that readers can inform on suspects, and highlights the Navy's judicial backing to punish fraud. The delight of Warter at the sentence contrasts with the annoyance expressed by Whittaker or Elkin in years prior. Potten was pilloried only once, even though the amount stolen was far greater than that of other offenders. Bruce was fined less but pilloried twice for a far less serious offence. Warter's delight suggests that Navy officials preferred higher fines to more stints in the pillory as a deterrent.
At the end of Warter's report on Potten, he gives thanks to Thomas Mann and Anne Graham for information that had led to the indictment of several fraudsters at the Old Bailey. 107 Earlier that year, Warter thanked Mann and Graham, along with three other people, for information that had led to the conviction of 40 people. 108 The rise in informants meant that convictions of men and women at the Old Bailey for fraud became frequent by the mid-1710s. The rise in prosecutions did not mean that fraudsters were discouraged, however; similar to Wilkinson, many offenders kept reappearing. In January 1716, Thomas Martin, ‘a notorious Offender’, stood in the pillory for wage fraud. 109 The following month, six ‘old offenders’ were convicted. 110 In one day in November 1716, another six people were convicted of fraud, all of whom were old offenders. 111 The decision to publish the sentences of fraudsters in newspapers suggests perhaps that the Navy accepted that some of these ‘old offenders’ would reoffend; what was important was that the notices, and the punishment of the pillory more generally, would deter first-time offenders from ever attempting to commit fraud.
Warter's delight at Potten's sentence suggests that the Navy preferred monetary penalties to curb fraud. Yet other reports suggest that the Navy did place importance on the pillory as an act of public penance. In March 1714, Warter complained about John Meeres’ behaviour in the pillory in Portsmouth. Accused of stealing from Navy stores, Meeres was fined about £6, 13s and ordered to be pilloried on ‘the next Markett day’. Warter travelled to the Winchester Assizes to aid in the prosecution by organising witnesses. 112 Warter hoped that his punishment would give ‘satisfaction’ to the Navy, but his subsequent report suggests otherwise. Meeres was the only offender to warrant two reports from Warter, one on his sentence and another on his behaviour in the pillory. In Warter’s report to the Navy Board, he complained that at the pillory, Meeres was ‘insolent and impudent … as if he had done no ill’. Despite his behaviour, Warter recommends that an account be put in ‘publick Prints’. 113 The fact that Meeres warranted a second report shows the Navy's wish for the pillory to impress upon offenders the weight of the crime. His story appeared three days later in the Gazette, with no mention of his behaviour. 114 Despite Meeres’ behaviour, his conviction did highlight the consequences of stealing from the Navy. In the following years, however, the lack of shame shown by fraudsters led to increasing complaints from contemporaries that the pillory was insufficient.
Beyond Potten's case, the disparity in punishments for fraudsters is evident, with the wealth and status of criminals seeming to have played a role. In December 1716, when seven people were indicted for fraud, they suffered six months’ imprisonment and were pilloried. The other offender, Goodard Wood, who admitted to forging several documents to receive the wages of various sailors, was imprisoned for a year and paid a £50 fine, but escaped the pillory. 115 Wood was a clerk in the Victualling Office. In contrast, the other six were likely of lesser means, given that one of them, Sarah Langsdale, had been publicly whipped in October, which was a rare punishment for affluent figures by this period. 116 All of the crimes were published in the Gazette. 117 A similar case occurred the following year, making the reason for such disparities clear. In March 1717, Warter recorded two cases: Robert Townsend was accused of stealing wages, while James and Elizabeth Watson were accused of forging a will to receive wages. Townsend was the ‘late Master of the Salisbury Prize’. He was fined £100, while the Watsons were fined 6s, 3d. However, only the Watsons were pilloried. 118 Warter makes clear the reason for the disparity: Townsend, ‘appraising to be of ability, had his fine the larger & was therefore by the court execus’d further punishment’. The Watsons were not able to pay ‘any great fine’, and so they were pilloried. 119 Warter's report finishes with the same request to publish the crimes in the Gazette, which followed the same formula as the other reports. 120
It is not surprising that Townsend did not stand in the pillory, not only because of Potten's example or issues Whittaker faced in the 1690s, but also because, as discussed above, the Admiralty Court often dismissed rather than prosecuted said officers. The Navy's use of newspapers helped offset the loss of publicity from the absence of the pillory: Townsend and Wood's sentences still served as a deterrent, but the audience was smaller than those who would have witnessed or heard about their public punishment. Judging by Warter's comments on Potten, fines were the most important; for those who were sentenced to stand in the pillory, such as Meeres, the Navy still placed stock in the punishment inflicting shame on them, in lieu, it seems, of the ideal sentence of a substantial fine.
Warter's delight at Potten's sentence suggests a lack of influence by the Navy over the sentence, but the court's decision to fine Wood and Townsend, even though courts often sentenced gentlemen to stand in the pillory for similar crimes unrelated to the Navy, 121 suggests that the Navy did have some influence. In this period, general offenders unable to pay a great fine were charged a lesser amount and put in the pillory on more occasions, but those deemed able to pay a substantial fine could not avoid the pillory simply by paying it. 122 In 1696, Whittaker had failed to convict the officers because of the support they received from senior Navy officials, suggesting disagreement among officials over the need to punish fraud. That Townsend, Potten and Wood were convicted and not provided with witnesses suggests that, in the two decades since, Navy officials had become more unified in their desire to condemn fraud. Yet fraud by gentlemen still did not carry the same sentence as fraud by poor offenders. The experiences of Navy offenders in the justice system illustrate that, in certain respects, despite growing concerns about fraud, England's penal system was designed to serve the interests of institutions and their elites at the expense of the poor. These disparities were unique to the punishment of Navy offenders, which is unsurprising, given that, as we have seen, the Navy regularly treated its officers differently from its sailors. These punishments also indicate that the Navy had gained a great deal of influence over sentences at the civilian courts.
‘Extremely mild’: Growing violence and the growing inadequacy of the pillory
In the spring and summer of 1727, several men and women were pilloried for fraud; some turned informers to avoid punishment. 123 Wilkinson was one of those punished, being ordered to stand in the pillory and to serve one year's imprisonment. The Navy made a great effort to manage her trial by paying her accomplice to testify. 124 A hardening attitude towards fraud is evident in her trial: she is described as ‘one of those vile persons, who makes a Practice’ of defrauding others. 125 Yet even by this period, after many successful convictions and more consistent use of witnesses, the Navy faced difficulties: Eleanor Cavenor was acquitted at the same sessions, because her fraud was not proven ‘to the Satisfaction of the Jury’. 126 Several failures followed that summer, owing to ‘flaws’ in the indictment or ‘disputes’ in the law. 127 Whittaker complained in the 1690s that judges argued that fraud legislation was insufficient, not that they did not take fraud seriously; in contrast, jury acquittals suggest a lack of belief in the conviction. Unlike judges, who were mainly elites, juries consisted of a broader spectrum of the public. 128 Judges, even when fraud was still a nascent public issue in the early eighteenth century, would probably have taken the crime more seriously than the average juror, who might not appreciate financial crime or institutional convictions as especially heinous. By the 1730s, however, attitudes towards fraud were hardening among all levels of society.
The violence meted out to those in the pillory was becoming an issue in this period. As one man wrote in 1731, the ‘design of the law’ of the pillory is ‘merely to expose the person’, but ‘the populace thinks the sentence too favourable […] there are some instances where the criminal has dy’d on the spot’. 129 Punishing criminals before the Navy offices encouraged those directly affected by their crimes to attend, which could result in violent reactions from the crowd. The space around these offices allowed crowds to get close to those in the pillory, making it difficult for officers to defend them. Focusing on London, while some offenders had been attacked in the pillory in the late seventeenth century, there were no deaths, and a few reports of crowds defying officers. Crowd behaviour seemingly shifted in the eighteenth century. Surveying 1700–1750, 35 pillory events are recorded: nine offenders received support, 14 were beaten, and four died, with a clear upward trend of violence – crowds attacked offenders two times more from 1725 to 1749 than from 1700 to 1725. 130
The violent tendencies of crowds also caused issues for the Navy. The incentives offered by the Navy led many fraudsters to become informants, such as Wilkinson's accomplice. Francis Wetheridge, who had been embroiled in a bribery case in 1713, was convicted of fraud in 1716 and was referred to in newspapers as an ‘old offender’. 131 By the 1720s, Wetheridge had become a regular informant. In early 1727, Edward and Katherine Ankers complained to the Navy Board that he had made false allegations against them. 132 A witness in a fraud case in July was ‘Honest Dame Wetheridge’, probably his partner. 133 In August, Wetheridge was informing on more suspects. 134 In 1730, he informed on several suspected fraudsters, who stood in the pillory in April, some of whom died. No enquiry was ordered into the deaths, which was common for incidents at the pillory. 135 The behaviour of Meeres had warranted a long report from Warten; the report may simply be lost, but no report on the deaths exists from the solicitor, Thomas Jobber. Instead, the Navy Board simply asked Wetheridge for more names. He writes only that the offenders had ‘stood in the pillory, & some died under the sentence’ or shortly thereafter, before giving the names of nine other suspects. 136 The Navy's rewards were implemented writ large across the justice system in the early eighteenth century. Some people, similar to Wetheridge, became professional informers, which led to several false convictions, triggering reforms in criminal trials in 1732. 137 However, despite the questionable motives of figures such as Wetheridge, the Navy continued to encourage informants to come forward.
Many sailors were ashore in this period following the Anglo-Spanish War. Impressment also intensified in these years as a pressure valve in lieu of prosecuting violent or poor offenders. The solution lessened disorder, but these problems returned when sailors came ashore, underpaid but more organised. 138 Sailors congregating at punishment sites and defying officers became an issue on occasion in the 1730s and 1740s, as did clashes between sailors and Londoners in the streets. 139 Perhaps, in April 1730, it was a similar case to the forger in 1667, when sailors gathered to ensure he received justice. Perhaps also, similar to Elkin's desire for the forger to be punished to avoid a mutiny, the Navy accepted some deaths as a more useful outlet for the frustration of its sailors.
Violence and disturbances were not confined to enlisted men. In April and May 1730, there were reports that some offenders were severely beaten. 140 Elizabeth Needham, John Middleton and John Waller, among others, died at the pillory in these years. The deaths of Navy offenders in April 1730 occurred within the context of increasing public disdain towards the crime, evident in the punishment of other fraudsters. In February 1729, Thomas Kinnersley and William Hale, both well-known figures, were charged with forgery at the Old Bailey, stood in the pillory twice, and were ‘spit on a hiss’d by every Body’. 141 Kinnersley and Hale soon died in prison, suggesting they had been severely injured. 142 The violence towards them was probably influenced by the infamy of the men, yet the treatment of lesser-known fraudsters in the pillory suggests that a clear disdain for the crime had emerged in society. In December 1728, the forger Paul Kerney was ‘very much pelted by the Populace, and fell from the Pillory several Times, and when taken down seem’d almost dead’. 143 In February 1730, two months before the Navy offenders died in the pillory, when Andrew Dalton stood in the pillory for fraud, so great was the crowd's anger and violence that a constable was severely injured trying to protect Dalton. 144
By the late 1720s, there was public outcry that the pillory was insufficient for forgery. The main issue mirrored complaints about both Meeres and the forger in 1667: the punishment did not instil the adequate level of shame in offenders. 145 Even when harsh sentences were reintroduced, such as the mutilation of Thomas Hayes in 1729 or Japhet Cook in 1731, contemporaries complained about their behaviour and argued that they should be hanged. 146 The outcry led to the passage of a law in 1731 stipulating that the penalty for forgery was capital punishment. 147 By the 1750s, fraud accounted for 7–8%%of all capital offences. 148 For the Navy, whose early foray into fungible debt led poor and elite alike to exploit its finances, the two-tier system of corporal punishment for poor offenders and heavy fines for gentlemen was over.
A series of amendments in the 1730s ensured that the common tactics of naval forgers were no longer misdemeanours but capital crimes. 149 In 1737, Catherine Leng escaped death only owing to pregnancy for forging the will of a sailor who owed her money. The change in tone of the courts towards fraud is clear in her trial: her crime constituted seemingly only a wish to expedite her repayment, but she was described as an ‘evil disposed Person’. 150 In December 1741, James Lee and Dominick Fitzgerald became the first offenders sentenced to death at the Old Bailey for naval fraud, a crime for which the pillory was now considered ‘extremely mild’ and not ‘adequate to the Crime’. As one newspaper noted before the trial regarding the pair's forgery, ‘this crime is made capital’. 151 In May 1744, Sarah Lowther was also only spared death for forging a will owing to being pregnant. 152
Some suspects were found guilty of fraud rather than forgery, so the pillory was still used for some Navy crimes.
153
For example, in July 1744, Christian Squires was found guilty of: a new trick invented by the Forgers of Seamens Will, because the Forgery comes within the Statute which punishes that Crime with Death; but fraudulently obtaining Letters of Administration is only a Misdemeanor, or Perjury.
154
Conclusion
The expansion of the Navy's mercantile and warfare operations, and its subsequent decision to manage its finances via a ticket system, were developments that fraudsters increasingly exploited. Men and women alike were keen to exploit the Navy's struggles to properly police its finances, at times with the help of those within the Navy office. The prevalence of women within the Navy bureaucracy meant that the Navy faced a disproportionate number of female offenders; the pillory, used on men and women equally in early modern England, was ideally suited to deter fraud. The Navy, at the forefront of England's financial revolution of the late seventeenth century, suffered at the forefront of its main negative. Reading the satires of the period, the financial empire that the Navy created, which fraudsters exploited, was subject to suspicion. The bureaucracy the Navy developed to manage its growing infrastructure, which fraudsters abused, was itself also deployed to combat fraud. One of the main tasks of the new position of Navy solicitor was to target fraud, as the Navy was one of the early proponents of institutional conviction. While the Navy could not use informal punishment aboard ships against civilians who defrauded its finances, it could have punished sailors who defrauded and embezzled in this way. Instead, the Navy chose to bring sailors to civilian courts to be punished ashore, deeming the public punishment of sailors and civilians alike the ideal deterrent.
Early experiences with fraud led the Navy to innovate: offering rewards before it was the norm, as well as leveraging the growing newspaper industry to highlight said rewards and show how to detect forgery and the punishment for committing it. However, trying to innovate in the face of a new threat meant that attitudes between civilian judges and juries and the Navy towards fraud were disjointed until well into the eighteenth century. There was probably a lack of understanding of institutional conviction, combined with issues of insufficient evidence, defects in indictments, and complaints about the inadequacy of legislation. Such problems point to structural issues within the English judicial system, which was initially ill-equipped to respond to the Navy's signal in the late seventeenth century on the danger of fraud to the security of the state and its institutions. As Gibson made plain, deterring fraud was more important than simply protecting finances; a lack of effort to combat fraud undermined trust in the institutions at the centre of Britain's fiscal–military state.
The commodification of debt in the late seventeenth century enabled a broad swath of the populace to participate in state finance. The involvement of such figures in state finance highlights the two-tier justice system in cases of financial fraud. The Navy had long treated officers and sailors differently in regard to fraud; only the hardening attitude towards the crime ended these disparities. The benefit to the Navy of this changing attitude was realised in the 1730s, as the danger of fraud to the health and prosperity of the state became apparent. The pillory was deemed insufficient to protect England's finances: for forgery, the death penalty became the Navy's and the state's method of ‘deterring others’; for frauds, the pillory maintained its role as a warning. The pillory served for years seemingly as a stopgap to lessen the impact of fraud on the Navy's finances, but the solution the Navy ultimately discovered to the exploitation of its complex bureaucratic and financial system was to remediate the system itself. Across the eighteenth century, the Navy reformed its pay system and thereby eliminated the delays and the bureaucracy that had enabled fraud in the first place. 159
Footnotes
Funding
Funding provided by the University of Limerick.
