Bessborough's appointees on its corporation, giving him control of its two MPs. Bessborough launched a court case in 1747, arguing that Stewart's burgesses were ineligible as they were not resident in the borough. This action prompted the addition of clause 8 to the bill. The heads of the bill were reported by the Committee of the Whole House of Commons on 17 December 1747. The heads were then sent for pre-approval, as required by Poynings' Law, to the Privy Council of Ireland in January 1748 and then the Privy Council of Great Britain in March 1748, both of which debated it strongly and made amendments. Petitions were considered from Stewart and from The Irish Society. The amended bill was returned to the Commons on 28 March and sent to the Irish House of Lords on 31 March. Historical opinion The act's negative reputation is ascribed by A. P. W. Malcomson to James Caulfeild, 1st Earl of Charlemont, who called it "the most outrageous and unconstitutional that ever was enacted" in his 1783 memoirs, which present clause 8 as instigated by Stewart solely to win his court case. William Lynch in 1831 was also critical, stating that all ancient boroughs in Ireland were de jure potwallopers, under the common law as "enforced by the statutes of 10th Hen. VII. ch. 7, and 33rd Hen. VIII"; in this view the 1748 act was one of a series of encroachments on an ancient right. Malcomson argues that Charlemont's account is coloured by political bias and that clause 8 was "only simplifying and making more intelligible the legal position as it already stood". Malcomson accepts the court case as the motivation for clause 8, but suggests that MPs were not acting in Stewart's particular interest but from "dread and uncertainty" of a decision's effect on their own constituency. Stewart's case was decided in his favour in 1758, without reference to the Newtown Act. Malcomson suggests the act did not apply to the case as clause 8 was not retroactive, and that the clause's only effect was between 1748 and 1758, during which time it forestalled any copycat cases being started. The allowance of non-resident burgesses has been presented as a worsening of the Irish House of Commons' unrepresentativeness, and as intended solely to increase the hold of patrons over their boroughs. Malcomson disputes this, suggesting the patron's hold was tight in any case: "what