burgesses, and whether in parliamentary elections to enfranchise non-residents. Where conflicts arose over the choice of a member of parliament, two competing selections were typically made and the matter came before the House of Commons. The Commons quite often decided in favour of the more popularly elected candidate against the nominee of the town council, on the general principle that neither the royal charter nor a by-law could curtail the usual franchise. But as each case rested on the national body swayed by the dominant political party, no principle was steadily adhered to in the trial of election petitions. The royal right to create boroughs was freely used by Elizabeth and James I as a means of securing a submissive parliament. Crown control of boroughs in the restoration The later Stuarts abandoned this method, and the few new boroughs made by the Georges were not made for political reasons. The object of the later Stuarts was to control the corporations already in existence, not to make new ones. Charles II, from the time of his restoration decided to exercise a strict control of the close corporations to secure not only submissive parliaments, but also a pliant executive among the borough justices, and pliant juries, which were impanelled at the selection of the borough officers. In 1660 it was made a rule that all future (town) Charters should reserve expressly to the crown the first nomination (naming) of the aldermen, recorder and town-clerk, and a proviso should be entered placing with the common council the return of the member of parliament. The Corporation Act of 1661 gave power to royal commissioners to settle the composition of the town councils, and to remove all who refused the sacraments of the Church of England or were suspected of disaffection, even though they offered to take the necessary oaths. Even so, the difficulty of securing submissive juries was again so great in 1682 that a general attack on the borough franchises was begun by the crown. A London jury having returned a verdict hostile to the crown and taxation, after various attempts to bend the city to his will, Charles II issued a quo warranto against the mayor and commonalty to charge the citizens with illegal encroachments beyond their chartered rights. The way this was analogous to well-precedented Crown rights to regulate the actions of organised groups of men such as rebels, made it