Note 810 — Chapter VIII · DECLINE OF THE JUDICIAL COMBAT.
Reading edition
Hale, Pleas of the Crown, II. chap. xxix. According to Pike (Hist. of Crime in England, I. 286 sq.), the record shows that approvers almost invariably either died in prison or were hanged in consequence of the acquittal of the party whom they accused. It was very rare that a combat ensued.