 Counsel for the prosecution also obliquely referred to the Amelioration Act 1798 passed by the Legislature of the Leeward Islands, which applied in the British Virgin Islands.That Act provided for penalties for slave owners who inflicted cruel or unusual punishments on their slaves, but it only provides for fines, and does not expressly indicate that a slave owner could be guilty of a greater crime such as murder or another offence against the person.The trial took place under English common law in British Virgin Islands.