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An action was brought by Mrs. Hodder of Hilsea barracks, against Mr. Littlefield, for an assault. The whole appearing frivolous, his lordship recommended one shilling damages, that each party might pay their own costs; the law intending this as a punishment, and an example in other cases, not to trouble the courts with vexatious and frivolous litigations.
— Hampshire Chronicle, Monday 08 August, 1791 source