BATES, JOHN, an English merchant who was tried before the court of Exchequer in Nov. 1606, for refusing to pay an extra duty of 5s. per cwt. on imported currants, levied by the sole authority of the Crown in addition to the 2s. 6d. granted by the Statute of Tonnage and Poundage, on the ground that such an imposition was illegal without the sanction of Parliament. The decision of the case in favour of the Crown threatened to establish a precedent which, in view of the rapidly increasing foreign trade, would have made the king independent of Parliament. The judg ments of Chief Baron Fleming and Baron Clark, of considerable importance from the point of view of constitutional history, are preserved.