Case of Impositions [1606] (Bates's Case)

Bates's Case, also known as the Case of Impositions [1606] 2 St Tr 371, is a significant UK constitutional law case from the Court of the Exchequer that dealt with the Crown's authority to impose duties for trade.

John Bates, a merchant affiliated with the Levant Company, contested the import duty on currants imposed by King James I. He argued that such impositions were illegal unless approved by Parliament. The case was brought before the Court of the Exchequer.

The Court of the Exchequer ruled in favour of the Crown, holding that Bates was obligated to pay the duty. The court maintained that the Crown had the authority to impose duties to regulate trade, and it could not question the King's statement that the duty was indeed imposed for the purpose of regulating trade.

The judgment emphasised the distinction between ordinary and absolute power. Ordinary power, intended for civil justice, was unalterable without Parliament's consent. On the other hand, absolute power, geared towards the nation's safety, could vary based on the royal wisdom. Therefore, if the Crown imposed a duty on imported currants to regulate foreign trade, it was within its authority, as long as the purpose was not solely to raise revenue.

The ruling had significant consequences, as it extended the Crown's ability to impose such duties, providing the Treasury with an unexpected source of income. This judgment, recognised by Robert Cecil, contributed to the Crown's financial gain.

In the long run, the case raised concerns about the Crown's potential ability to levy taxes without parliamentary approval, potentially diminishing one of the main reasons for Parliament's existence. While this concern did not fully materialise until the reign of Charles I, Bates's Case foreshadowed the potential tension between the Crown and Parliament over taxation powers.

Sir Thomas Fleming, whose opinion was pivotal in the case, expressed notable contempt for the business community in his judgment. He dismissed the argument that merchants needed unrestricted access to foreign markets for the common good, asserting that the ultimate goal of private merchants was personal profit rather than the common good.

Sir Richard Lane's Reports, published posthumously in 1657, included a crucial report of Sir Thomas Fleming's opinion in Bates's Case, contributing to its lasting impact on constitutional law history.
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