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  • ONE:During his absence from the extreme south, General Graham, with about four thousand British and Portuguese, had quitted Cadiz by sea, and proceeded to Alge?iras, where he landed, intending to take Victor, who was blockading Cadiz, in the rear. His artillery, meanwhile, was landed at Tarifa; and on marching thither by land, over dreadful mountain roads, he was joined, on the 27th of February, by the Spanish General Lape?a, with seven thousand men. Graham consented to the Spaniard taking the chief commandan ominous concession; and the united forcesoon after joined by a fresh body of about one thousand men, making the whole force about twelve thousandthen marched forward towards Medina Sidonia, through the most execrable roads. Victor was fully informed of the movements of this army, and advanced to support General Cassagne, who held Medina Sidonia. No sooner did he quit his lines before Cadiz than the Spanish General De Zogas crossed from the Isle de Leon, and menaced the left of the French army. On this Victor halted at Chiclana, and ordered Cassagne to join him there. He expected nothing less than that Lape?a would manage to join De Zogas, and that fresh forces, marching out of Cadiz and the Isle of Leon, would co-operate with them, and compel him to raise the siege altogether. But nothing so vigorous was to be expected from a Spanish general. Lape?a was so slow and cautious in his movements that[15] Graham could not get him to make any determined advance; and on arriving at the heights of Barrosa, which a Spanish force had been sent forward to occupy, this body of men had quitted their post, and Victor was in possession of these important positions, which completely stopped the way to Cadiz and at the same time rendered retreat almost equally impossible. Lape?a was skirmishing, at about three miles' distance, with an inconsiderable force, and the cavalry was also occupied in another direction. Seeing, therefore, no prospect of receiving aid from the Spaniards, General Graham determined to attack Marshal Victor, and drive him from the heights, though the latter's force was twice as strong as the former's. This Graham did after a most desperate struggle. Had Lape?a shown any vigour or activity, Victor's retreating army might have been prevented from regaining its old lines; but it was in vain that Graham urged him to the pursuit. Lord Wellington eulogised the brilliant action of the heights of Barrosa, in a letter to Graham, in the warmest terms, declaring that, had the Spanish general done his duty, there would have been an end of the blockade of Cadiz. As it was, Victor returned to his lines and steadily resumed the siege. In the meantime, Admiral Keats, with a body of British sailors and marines, had attacked and destroyed all the French batteries and redoubts on the bay of Cadiz, except that of Catina, which was too strong for his few hundred men to take.

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TWO:At the opening of 1841 the country might be said to be free from all excitement on the subject of politics. There was no great question at issue, no struggle between rival parties seemed impending. Many of the principal topics which in former years had agitated the public mind had been settled or laid to rest. The Chartist riots seemed to have abated the desire of the leading Reformers to extend the suffrage to the working classes. Still the Government was lamentably weak, and only existed on sufferance. Nor did the conduct of affairs in the House of Commons tend to strengthen their position. The reintroduction by Lord Stanley of his Bill to regulate the registration of voters in Ireland led to much angry discussion with damaging results to the Government, who had already suffered grievous defeats in attempting to arrest the progress of the measure during the previous Session. Two days later Lord Morpeth brought in a Government Bill for the same object. The main features of the plan were to abolish certificates; to make the register conclusive of the right to vote, except where disqualification afterwards appeared; to establish an annual revision of the registers, and to give a right of appeal equally to the claimant and the objector. The main point of difference between this and Lord Stanley's Bill consisted in the tribunal to which the appeal was to be made. The Government proposed for this purpose the creation of a new court, consisting of three barristers of a certain standing. An additional feature of the Government Bill was a proposal to settle the question of the basis of the franchise by fixing upon the Poor Law valuation as the standard; and the Bill proposed to enact that every occupier of a tenement under a holding of not less than fourteen years, of the annual value of 5, should have the right of voting previously enjoyed by persons who had a beneficial interest of 10. The Conservatives complained of the unfairness of thus introducing by surprise a fundamental alteration in the elective franchise of Ireland, founded upon principles unknown both in England and Scotland. It was represented as a new Reform Bill for Ireland, tacked on as a postscript to a Bill for amending the registration. The 5 franchise, it was argued, would in effect be little short of the introduction of universal suffrage. The House divided on the respective merits of the rival Bills, when the Government measure was carried by a majority of five. The result was hailed with cheers from both sides of the House, the Opposition regarding the victory as little better than a defeat. Lord John Russell at first announced that he would proceed immediately with the measure, but he afterwards moved its postponement till the 23rd of April. During the interval Lord Morpeth announced the conversion of the Ministry to the principle of an 8 rating. When the question was introduced again, on the 26th of April, it gave rise to a party debate. While the House was in committee on Lord Morpeth's Bill, Lord Howick proposed an amendment to the effect that the tenant, in order to entitle him to the franchise, should have a beneficial interest in his holding of 5 a year over and above the rent. Lord Morpeth proposed as a qualification for the franchise a lease of fourteen years, and a low rating of 8. Lord Howick proposed that the yearly tenant should be entitled to vote as well as the leaseholder if he had an annual interest of 5 in it; but Lord Morpeth contended, and showed from statistics, that this principle would disfranchise more than three-fourths of the 10 tenant voters in several of the counties. In short, it would have the effect of almost entirely disfranchising the existing occupying constituency of Ireland. On a division, Lord Howick's amendment was carried by 291 to 270. Finally the Bill was reduced to such a jumble of[477] contradictory amendments that it was impossible to proceed with it. Thus ended the great struggle of the Session. Much time had been wasted in party debates and fruitless discussions, and the proposal to give the Irish people the benefit of the Reform Act by putting its perishing constituencies on a proper basis, simple as it may seem, utterly failed. Lord Stanley also abandoned his measure, and there the matter ended. The whole of the proceedings plainly indicated that the doom of Lord Melbourne's feeble Cabinet was at hand.

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THREE:He had, however, lost something of his old self-confidence, and the opposition which he had met with from the State, and the alienation of the people, were not exhilarating. Napoleon saw that he must conciliate the French by concessions, but neither his temperament nor his necessities permitted him to do this liberally. He gave nominal freedom to the press, but he bought up the majority of the editors and proprietors; yet, not being able to do this wholly, the opposition spoke bitter things to him and of him, and damaged his cause seriously. He called on Siys, Carnot, and Fouch to assist in framing his constitution; and he gave peerages to Carnot and Siys, and those once stern Republicans accepted them. But, even with their aid, he could not bring himself to grant a free constitution. Nobody believed him to be sincere even in what he did give. The police were as strict as ever, and yet every night the walls of Paris were covered with proclamations of Louis XVIII., forbidding the payment of taxes, and announcing the approach of one million two hundred thousand men.But in October the patriots of Breda surprised the forts of Lillo and Liefkenshoek, on the Scheldt. Dalton dispatched General Schr?der with a strong force, who retook the forts; but on Schr?der's venturing to enter Turnhout after the insurgents, a body of three thousand of them, under Van der Mersch, armed with pitchforks, bludgeons, and staves, attacked and drove him out. General Bender, who had been dispatched against the insurgents at Tirlemont, was driven out in the same manner. General Arberg was compelled to retreat behind the Scheldt, and the people were victorious in Louvain, Ghent, Bruges, Ostend, and most towns of the district. Both Joseph and his Governor and Commander in the Netherlands now fell into the utmost alarm. The news which Marie Antoinette sent from Paris to her Imperial brother only rendered this consternation the greater. Joseph, with that sudden revulsion which he had manifested on other occasions, after equally astonishing rashness, now issued a conciliatory proclamation, offering to redress all grievances on the condition of the Netherlanders laying down their arms. But they were not likely, after former experience, to trust any such promises of Joseph. On the 20th of November the States of Flanders assumed the title of the High and Mighty States; they declared the Emperor to have forfeited the Crown by tyranny and injustice; they proclaimed their entire independence, and ordered a levy of twenty thousand men.

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THREE:But there was no rest for Frederick. Daun was overrunning Saxony; had reduced Leipsic, Wittenberg, and Torgau. Frederick marched against him, retook Leipsic, and came up with Daun at Torgau on the 3rd of November. There a most sanguinary battle took place, which lasted all day and late into the night. Within half an hour five thousand of Frederick's grenadiers, the pride of his army, were killed by Daun's batteries of four hundred cannon. Frederick was himself disabled and carried into the rear, and altogether fourteen thousand Prussians were killed or wounded, and twenty thousand of the Austrians. This scene of savage slaughter closed the campaign. The Austrians evacuated Saxony, with the exception of Dresden; the Russians re-passed the Oder, and Frederick took up his winter quarters at Leipsic.

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THREE:Mr. Villiers's annual motion, brought forward on the 25th of June, was scarcely more successful than that of Mr. Cobden. Lord John Russell still harped upon his fixed idea of a fixed duty. In his view the country suffered not from the Corn Law, but only from the form in which it was administered. He said he was not prepared to say either that the Corn Law should be at once abolished, or that the existing law should be maintained. While such was the feeble policy of the leader of that Whig party which had set up a claim to a sort of monopoly of Free Trade principles, it was no wonder that the country began to look for relief to the Minister who had introduced the tariff of 1842; but Sir Robert Peel as yet moved too slowly to rouse the enthusiasm in his favour of the Anti-Corn-Law League. "There were not," he remarked, "ten reflecting men out of the Anti-Corn-Law League, who did not believe that a sudden withdrawal of protection, whether it were given to domestic or colonial produce, would cause great confusion and embarrassment. In the artificial state of society in which we lived we could not act on mere abstract philosophical maxims, which, isolated, he could not contest; they must look to the circumstances under which we have grown up, and the interests involved. Ireland, dependent on England for a market for her agricultural produce, was a case in point. He was not prepared to alter the Corn Law of 1842, and did not contemplate it. Seeing that Lord John Russell had avowed himself a consistent friend to Protection, and was opposed to total repeal, he thought he was somewhat squeamish in flying from his difficulty, and declining to vote against the motion. As to the Corn Law, the Government did not intend to alter it, or diminish the amount of protection afforded to agriculture." On the division the numbers for the motion were[512] 124, and against it, 330. On the whole, the cause of Free Trade made but small progress in Parliament in this year, though out of doors the agitation was carried on with ever-increasing vigour. As regards Mr. Villiers's motion, the progress made was shown principally in the decrease of the majority against it. In 1842, when he first put the question of total repeal on issue before the House, he had 92 votes, and 395 against him; in 1843 he had 125 votes, and 381 against him; in 1844, 124 votes, and 330 against him.
  • FORE:Whilst Burgoyne had been looking in vain for aid from New York, Sir Henry Clinton, at length daring the responsibility of a necessary deed, had set out with three thousand men, in vessels of different kinds, up the Hudson. On the 6th of Octobereleven days before Burgoyne signed the capitulationClinton set out. Leaving one thousand men at Verplank's Point, he crossed to the other bank with his remaining two thousand, and landed them at Stony Point, only twelve miles from Fort Montgomery. He advanced with one-half of his force to storm Fort Clinton, and dispatched Lieutenant-Colonel Campbell to attack Fort Montgomery. Both forts were to be[245] attacked, if possible, at the same instant, to prevent the one from aiding the other. The simultaneous assaults took place about sunset. Lieutenant-Colonel Campbell was killed leading his column against Fort Montgomery, but his brave troops entered and drove the garrison of eight hundred men from the place. Clinton found the approach to the fort of his own name much more arduous. But on went our brave fellows till they reached the foot of the works, where, having no ladders, they hoisted one another on their shoulders to the embrasures, through which they pushed past the cannon, and drove the Americans from their guns, and across the rampart, at the points of their bayonets. It was dark by the time the forts were taken, but the Americans soon threw light enough on the scene by setting fire to several vessels which were moored close under the guns of the forts. Had the English been disposed to risk the attempt to save them, they were prevented by several strong booms and chains thrown across the river. These they afterwards broke through, and, on the 13th of October, at the very moment that Burgoyne was making his first overtures for surrender, the English troops under General Vaughan ascended, in small frigates, as far as Esopus Creek, only thirty miles overland to Saratoga. But Burgoyne having now surrendered, and Gates being at liberty to send down strong reinforcements to co-operate with Putnam, the English vessels and troops were recalled, and returned to New York. Such was the campaign of 1777; equally remarkable for the valour of the British troops, and for their misfortunes; for the imbecility of their Government, and the incapacity or rashness of their commanders.The Grenville Ministry was approaching its extinction. It had done a great work in the abolition of the Slave Trade, but there was another species of abolition which they were disposed to further which was not quite so acceptable. They had supported Wilberforce and his party in their measure for the negroes, but Wilberforce and his friends were by no means willing to support them in liberating the Catholics from their disabilities. Grenville and Fox had made no particular stipulation, on taking office, to prosecute the Catholic claims, but they were deeply pledged to this by their speeches of many years. It was, therefore, highly honourable of them, though very impolitic, to endeavour to do something, at least, to show their sincerity. Though the king was obstinately opposed to any relaxation of the restraints on this class of his subjects, yet the Fox and Grenville Ministry had introduced a milder and more generous treatment of the Catholics in Ireland. The Duke of Bedford, as Lord-Lieutenant, had discouraged the rampant spirit of Orangeism, and admitted Catholics to peace and patronage. He had abandoned the dragooning system, and had managed to settle some disturbances which broke out in the autumn of 1806, without even proclaiming martial law. These measures had won the cordial attachment of the Catholics both in Ireland and England, but, in the same proportion, had exasperated the Church and War party against them in both countries. Their adding another three-and-a-half per cent. to the income and property taxes had still further embittered these parties, and the antagonism to them was every day becoming stronger. Yet they resolved, in spite of all this, to make an attempt to do some justice to the Catholics. They managed to carry an additional grant to the College of Maynooth, and on the 4th of March, when this grant was debated, Wilberforce, though[533] wanting the support of Ministers for his Slave Trade Bill, made a violent speech against all concessions to the Catholics. He declared the Protestant Church the only true one, and, therefore, the only one which ought to be supported. "He did not profess," he said, "to entertain large and liberal views on religious subjects; he was not, like Buonaparte, an honorary member of all religions." Undeterred by these tokens of resistance, Lord Howick, the very next day, moved for leave to bring in a Bill to enable Catholics to hold commissions in the army and navy on taking a particular oath. He said that it was a strange anomaly that Catholics in Ireland could hold such commissions since 1793, and attain to any rank except that of Commander-in-Chief, of Master-General of the Ordnance, or of General of the Staff, yet, should these regiments be ordered to this country, they were, by law, disqualified for service. A clause had already been added to the Mutiny Bill to remove the anomaly. He proposed to do away with this extraordinary state of things, and enable his Majesty, at his pleasurefor it only amounted to that, after allto open the ranks of the army and navy to all subjects, without distinction, in Great Britain as well as Ireland.
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  • FORE:On the Rhine, the war was carried on quite into the winter. The King of Prussia did not stay longer than to witness the surrender of Mayence; he then hurried away to look after his new Polish territory, and left the army under the command of the Duke of Brunswick. Brunswick, in concert with Wurmser and his Austrians, attacked and drove the French from their lines at Weissenburg, took from them Lauter, and laid siege to Landau. Wurmser then advanced into Alsace, which the Germans claimed as their old rightful territory, and invested Strasburg. But the Convention Commissioners, St. Just and Lebas, defended the place vigorously. They called forces from all quarters; they terrified the people into obedience by the guillotine, Lebas saying that with a little guillotine and plenty of terror he could do anything. But he did not neglect to send for the gallant young Hoche, and put him at the head of the army. Wurmser was compelled to fall back; Hoche marched through the defiles of the Vosges, and, taking Wurmser by surprise, defeated him, made many prisoners, and captured a great part of Wurmser's cannon. In conjunction with Pichegru, Dessaix, and Michaud, he made a desperate attack, on the 26th of December, on the Austrians in the fortified lines of Weissenburg, whence they had so lately driven the French; but the Duke of Brunswick came to their aid, and enabled the Austrians to retire in order. Hoche again took possession of Weissenburg; the Austrians retreated across the Rhine, and the Duke of Brunswick and his Prussians fell back on Mayence. Once there, dissatisfied with the Prussian officers, he resigned his command, he and Wurmser parting with much mutual recrimination. Wurmser was not able long to retain Mayence; and the French not only regained all their old positions, before they retired to winter quarters, but Hoche crossed the lines and wintered in the Palatinate, the scene of so many French devastations in past wars. The French also repulsed the enemy on the Spanish and Sardinian frontiers.On the 10th of January the army came in sight of Corunna and the sea, but no transports could be seen in the bay. They were detained by contrary winds at Vigo, and the last hope of safety seemed cut off. Sir John, however, quartered his troops in Corunna, and determined to defend it manfully till the transports could get up. But great was his chagrin at the proofs of the miserable management of the Commissariat Department. On a hill above the town were four thousand barrels of gunpowder, which had been sent from England, and had been lying there many months, and the town was a great magazine of arms. Sir John replaced the weather-worn muskets of his troops with new ones, supplied them with fresh, good powder, and, after removing as many barrels of powder into the town as the time would allow, he blew up the rest, producing a concussion that shook the place like an earthquake.
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  • FORE:Whilst the Opposition was in the dejection of disappointed hopes, suddenly there arose an explosion of popular opinion against the Catholics, stimulated and led on by an insane fanatic, which threatened the most direful consequences, and produced sufficiently frightful onesthe so-called Gordon Riots.
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  • FORE:Lord Howe arrived from England, and cast anchor off Sandy Hook, a few hours after the Declaration of Independence had been read to the army by Washington. He had been expected by his brother, General Howe, who had arrived at the same point on the 29th of June, supposing he should find the admiral there. General Howe found Washington already in New York, and actively engaged in throwing up entrenchments, both there and on Long Island, to close the Hudson against the British fleet. Washington's headquarters were at New York; those of General Sullivan, at the western extremity of Long Island, opposite to New York; and Governor's Island, Paulus Hook, New Rochelle, and other points, were strongly defended to protect the rear of the city. At the time of Admiral Howe's arrival, the army of Washington did not amount to more than seventeen thousand men, of whom three[228] thousand were sick, and but about ten thousand men fit for duty. From his letters to Congress, it is clear that he entertained very little hope of maintaining his ground in case of attack, for the fresh forces brought by Howe from England, being joined by the shattered remains of Sir Peter Parker's squadron, amounted to twenty thousand men. A few days afterwards, however, he was joined by two regiments from Philadelphia, and by large bodies of New York and New England Militia, raising his army to twenty-seven thousand men, but of these a large number were sick. He now posted strong reinforcements in Brooklyn. On this General Howe quitted Sandy Hook, and advanced to Staten Island, where he could watch the operations of the enemy. The Americans abandoned Staten Island, on his approach, without firing a gun.At this crisis George Grenville brought in and carried through a measure, which showed how useful he might have been, had he never been raised out of his proper element to rule and alienate colonies. He was now fast sinking into the grave, though but fifty-eight years of age. This measure was a bill to transfer the trial of controverted elections from the whole House of Commons to a select Committee of it. Ever since the famous Aylesbury case, the whole House had taken the charge of examining all petitions against the return of candidates and deciding them. This was a great obstruction of business; and Grenville now proposed to leave the inquiry and decision to the select Committee, which was to be composed of fifteen members of the House, thirteen of whom were to be chosen by the contesting claimants for the seat, out of a list of forty-five, elected by ballot from the whole House. The other two were to be named, one each, by the contesting candidates. The Committee was empowered to examine papers, call and swear witnesses, and, in fact, to exercise all the authority previously wielded by the whole House. It was opposed by Welbore Ellis, Rigby, Dyson, and Charles James Fox, not yet broken from his office shell into a full-fledged patriot. It was, however, carried, and being supported in the Lords by Lord Mansfield, who on this occasion manifested an unusual disregard of his party principles, it was passed there too.
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  • THREE:By permission of the Corporation of Liverpool. Reproduced by Andre & Sleigh, La., Bushey. Herts.
    TESTIMONIALS
    THREE:The taste for Italian music was now every day increasing; singers of that nation appeared with great applause at most concerts. In 1703 Italian music was introduced into the theatres as intermezzi, or interludes, consisting of singing and dancing; then whole operas appeared, the music Italian, the words English; and, in 1707, Urbani, a male soprano, and two Italian women, sang their parts all in Italian, the other performers using English. Finally, in 1710, a complete Italian opera was performed at the Queen's Theatre, Haymarket, and from that time the Italian opera was regularly established in London. This led to the arrival of the greatest composer whom the world had yet seen. George Frederick Handel was born at Halle, in Germany, in 1685. He had displayed wonderful genius for music as a mere child, and having, at the age of seven years, astonished the Duke of Saxe Weissenfelsat whose court his brother-in-law was a valetwho found him playing the organ in the chapel, he was, by the Duke's recommendation, regularly educated for the profession of music. At the age of ten, Handel composed the church service for voices and instruments; and after acquiring a great reputation in Hamburgwhere, in 1705, he brought out his "Almira"he proceeded to Florence, where he produced the opera of "Rodrigo," and thence to Venice, Rome, and Naples. After remaining in Italy four years, he was induced to come to England in 1710, at the pressing entreaties of many of the English nobility, to superintend the opera. But, though he was enthusiastically received, the party spirit which raged at that period soon made it impossible to conduct the opera with any degree of self-respect and independence. He therefore abandoned the attempt, having sunk nearly all his fortune in it, and commenced the composition of his noble oratorios. Racine's "Esther," abridged and altered by Humphreys, was set by him, in 1720, for the chapel of the Duke of Chandos at Cannons. It was, however, only by slow degrees that the wonderful genius of Handel was appreciated, yet it won its way against all prejudices and difficulties. In 1731 his "Esther" was performed by the children of the chapel-royal at the house of Bernard Gates, their master, and the following year, at the king's command, at the royal theatre in the Haymarket. It was fortunate for Handel that the monarch was German too, or he might have quitted the country in disgust before his fame had triumphed over faction and ignorance. So far did these operate, that in 1742, when he produced his glorious "Messiah," it was so coldly received that it was treated as a failure. Handel, in deep discouragement, however, gave it another trial in Dublin, where the warm imaginations of the Irish caught all its sublimity, and gave it an enthusiastic reception. On its next presentation in London his audience reversed the former judgment, and the delighted composer then presented the manuscript to the Foundling Hospital, where it was performed annually for the benefit of that excellent institution, and added to its funds ten thousand three hundred pounds. It became the custom, from 1737, to perform oratorios[156] on the Wednesdays and Fridays in Lent. Handel, whose genius has never been surpassed for vigour, spirit, invention, and sublimity, became blind in his latter years. He continued to perform in public, and to compose, till within a week of his death, which took place on April 13, 1759.
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    THREE:DUBLIN CASTLE. (From a Photograph by W. Lawrence, Dublin.)

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    Hitherto the United Irishmen had obtained little support from the Catholics, who were entirely out of sympathy with the Protestantism of one section of the party, and the irreligion of Wolfe Tone and his immediate associates. They preferred to look to the British Government, and especially to Pitt who was known to be favourable to the Catholic claims. But the Protestants in the Irish Parliament were too strong for him, and only a few remedial measures were passed and those inconsiderable in extent. In 1792 Sir Hercules Langrishe, with the consent of the Government, succeeded in carrying a Bill which admitted Catholics to the profession of the law, removed restrictions on their education, and repealed the Intermarriage Act. In 1793 the Irish Secretary, Major Hobart, succeeded, after much Government pressure, in carrying a second Catholic Relief Bill, admitting Catholics to the grand juries, magistracy, and finally to the franchise, though not to Parliament. Further than that Pitt could not be induced to go. He would neither consent to the admission of Catholics to Parliament, nor would he consent to a measure of Parliamentary reform, though the state of the representation was about as rotten as could possibly be conceived. From an inquiry instituted some years earlier it appeared that out of a House of 300 members 124 were nominated by 53 peers, while 91 others were chosen by 52 commoners. The British ascendency was, in fact, maintained by a system of organised corruption and place-holding, which failed only when religious bigotry carried the day.[See larger version]The main subject for consideration at that moment was the policy of continuing the Act for the suppression of the Catholic Association, which was to expire at the end of the Session of 1828. In connection with this subject a letter from Lord Anglesey came under the Ministry's consideration. "Do keep matters quiet in Parliament," he said, "if possible. The less that is said of Catholic and Protestant the better. It would be presumptuous to form an opinion, or even a sanguine hope, in so short a time, yet I cannot but think there is much reciprocal inclination to get rid of the bugbear, and soften down asperities. I am by no means sure that even the most violent would not be glad of an excuse for being less violent. Even at the Association they are at a loss to keep up the extreme irritation they had accomplished; and if they find they are not violently opposed, and that there is no disposition on the part of Government to coercion, I do believe they will dwindle into moderation. If, however, we have a mind to have a good blaze again, we may at once command it by re-enacting the expiring Bill, and when we have improved it and rendered it perfect, we shall find that it will not be acted upon. In short, I shall back Messrs. O'Connell's and Sheil's, and others' evasions against the Crown lawyers' laws."
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