The
History and Evolution of the Court System in Anguilla
Anguilla’s
368-year old judicial system has evolved through three distinct phases:
1. The Period
Before Union with St Kitts in 1825
2. The Period
of Union with St Kitts
3. The 1967
Anguilla Revolution to Today
1. The Period From
Settlement in 1650 until Union with St Kitts in 1825
Anguilla
was first settled in the year 1650 by runaway indentured servants from Barbados
and small farmers from St Kitts escaping the heavy tobacco taxes, imposed there
to pay for the defence of that island against French invasion. Poor as the soil of Anguilla was in
comparison to St Kitts, they preferred the freedom offered by an island with no
formal government establishment.
In 1666, some sixteen years after the settlement
began, the leading members of the isolated and impoverished Anguillian settlers
formed themselves into a self-appointed Council and elected their own deputy
governor.[1] For many years, this Council acted as an
informal legislature, judiciary and executive for Anguilla. The power it exercised was not sanctioned by
any local or regional statute or other law.
By contrast, Bermuda boasts the second oldest
continually sitting legislature in the common law world dating back to 1621,
the oldest being that of the colony of Virginia in America, 1619.[2] The earliest volume of the laws of Bermuda
was published in 1719, though individual laws had been enacted for a century
previously.[3]
The earliest volumes of the laws of the
Leeward Islands, published in 1740, include laws passed by the Assembly in
Montserrat as early as 1668, indicating the antiquity of that island’s
legislature.[4] That for Nevis contains laws dating back to
1666.[5] That for St Kitts, also published in 1740,
contains earlier laws dating back to 1711, though there had been a legislature
for nearly a century prior to that date.[6]
In almost every other Leeward Island, Royal
Patents were sent out from London for the appointment of a deputy governor, an
island Council and an Assembly to make laws.
The Virgin Islands was the only other colony that at first functioned
without an Assembly. In the year 1773,
the first half-hearted and generally ineffective Assembly was established for
Tortola. It took another ten years before
the first Act of the Virgin Islands legislature was assented to by the Governor
in Chief in Antigua. Generally, the
powerful planters of Tortola sabotaged the Assembly, as they were suspicious of
any development that challenged their primacy over their slaves and their
properties. We can safely assume that
the same motive was at work in the lack of any enthusiasm in the Anguilla
land-owners to demand a formal legislature for Anguilla.
In Anguilla, for some 175 years after the
island’s settlement in 1650, there was no lawfully constituted Assembly to make
laws for the people. When in 1825 the
first laws were passed specifically for Anguilla, they were made by the
Assembly in St Kitts. Such a degree of neglect
by the colonial authorities was unique in the West Indies. The first legislature to be legally
established in Anguilla, by which the people’s representatives made laws for
the island, came about as recently as the year 1976, or 326 years after
settlement.
The earliest Anguilla Councils were
self-appointed and were merely tolerated by the colonial authorities in
Antigua. In later years, the
Governor-in-Chief invariably confirmed the local appointees, and never interfered
in the affairs of the Anguilla Council, as he frequently did in the more
prosperous and consequential colonies of Antigua, St Kitts, Nevis, and
Montserrat. He touched on Anguillian
affairs only when there was an appeal from a decision of the Anguilla Council,
which he would often pass on to the Secretary of State in London for a ruling,
since he exercised very limited authority over the Anguilla Council. The result was that, throughout this early
period, the common Anguillian man and woman endured the unregulated government
of their Council of local, invariably white, planters, without the benefit of
any real supervision by the colonial authorities. There was no Assembly to enact statutes under
which the people could be governed.
Under the colonial regime of the day, no law enacted in one colony could
apply in another. The truth is that
Anguilla was too poor, and of no consequence to the colonial authorities, since
it contributed nothing to the Crown to merit any expenditure of time or money
on its administration. The result was
that up until the year 1825, the Anguilla Council, in effect, acted as the
executive, legislative and judicial branches of the government of Anguilla,
without any formal constitutional or statutory authority.[7]
In the absence of a legislature to enact laws
for good government, a deputy governor of Anguilla was obliged to rely for his
authority on his personal standing in the community, not to mention his
physical prowess. An English historian,
writing in 1707, nearly sixty years after settlement began, described the
settlers of Anguilla this way,[8]
Their business . . . was to plant corn,
and breed tame cattle,[9]
for which purpose they brought stock with them.
They were poor and continue so to this day, being perhaps the laziest
creatures in the world. Some people have
gone from Barbados, and the other English Charibbee Islands, thither; and there
they live like the first race of men, without government or religion, having no
minister nor governor, no magistrates, no law, and no property worth
keeping. If a French author is to be
believed, . . . ’The island is not thought worth the trouble of defending or
cultivating it’.
Regular periods of drought; frequent
hurricanes; and a thin, poor and unproductive soil offered limited
opportunities for growing the cash crops that flourished in St Kitts and
Antigua. The people were further
impoverished by the devastations brought by the wars between the English and
the French. Only the keeping of small
stock such as goats, and subsistence farming of such hardy crops as maize,
sweet potatoes, and pigeon peas, could ensure the survival of the people. Fishing added some protein to their
diet. Goats were mainly sold for cash in
St Kitts and Antigua, or were slaughtered on special occasions. The risky enterprises of privateering during
times of war, and the continuous smuggling among neighbouring islands, brought
into the island a limited amount of coin.
Laziness was no part of the hardy Anguillian nature. No one could prosper, far less grow rich, in
such adverse conditions.
As the Governor-in-Chief said of the governor
of Anguilla in a 1724 dispatch, “If his
cudgel happens to be one whit less than a sturdy subject’s, then good night,
governor!” The result was that
Anguillians lived, worked and died through the late seventeenth, the eighteenth,
and the early nineteenth centuries without the benefit of any legal system for
their government.
In the 1730s, Anguilla’s reputation for lack
of a judicial system and any form of government was at its lowest point. In 1734, Governor-in-Chief William Mathew
remarked on the lack of law and a properly constituted method for its
enforcement in Anguilla. He complained
that he did not know what to do with the inhabitants. “They
live, he wrote, “like so many
bandits, in open defiance of the laws of God and men.”
The first effort to create an Assembly for
Anguilla to make laws for the island, then classed among the Virgin Islands, was
an initiative of Governor Mathew in 1734.
As he wrote to the Committee for Trade and Foreign Plantations, the
people of Anguilla were in continuous property disputes. In the absence of a court system, he wrote,
the stronger party always had the better title.[10] Some sort of Court was required for citizens
to have both a fair hearing and also a remedy against wrongs done to them. Additionally, there was no provision for the
trial of criminal cases. Offenders could
not be prosecuted. Governor Mathew gave
as an example a case of a person accused of murder and brought to St Kitts for
trial. There, he was tried and convicted
of murder. When he broke out of jail, he
could not be re-arrested as the Attorney-General advised that his trial in St
Kitts for an offence committed in the Virgin Islands was illegal. His effort at establishing both a court and a
legislature for Anguilla came to nothing.
For the next seventy years until 1825, Anguilla
continued to have no legally established judicial system. All members of the Council were by the
mid-eighteenth century appointed as Justices of the Peace. A committee of them sat to adjudicate
disputes and to hear complaints, and imposed such penalties and fines and gave
such decisions as seemed proper to them.
Appeals from such decisions of the Council lay informally to the
Governor in Antigua, but this right was seldom exercised.
2. After Union with St Kitts
and Until the 1967 Anguilla Revolution of 1967
In the year 1825, prolonged drought; regular
hurricanes; and the long wars with the USA and France, which ended only in
1815, combined to bring the Anguilla planters to their knees. The British blockade of trade with the enemy
during the preceding 30 years devastated the vital Anguillian privateering and
smuggling industries, while the alternating periods of droughts and hurricanes
destroyed the small-stock, crops and homes of the islanders. The law suits in the island’s unofficial
courts after 1780, traces of which have survived in the archives, demonstrate
in a practical way just how the economy had collapsed. The sums being sued for declined from
hundreds of pounds before the American Revolution of 1776 to just a few
shillings and pence in the fifty years before Anguilla was joined to St Kitts.
Their economy having collapsed, the
Anguillians submitted to pressure from London to be governed by St Kitts. London’s main interest in the union, as evidenced
in the correspondence of the Secretary of State with the Governor-in-Chief in
Antigua in the early part of the 19th century, was to have some form of
law-making power that would apply law to the Anguillians, particularly the existing
slavery amelioration laws and the coming Abolition of Slavery Act.[11]
In 1825 the St Kitts Legislative Assembly,
under pressure from London, passed the Anguilla Act to provide for its
laws to extend to Anguilla.[12] Anguillian planters who met the voting qualification
(ownership of 100 acres of land) elected one representative to the St Kitts and
Anguilla Assembly.[13] In this way, in the year 1834, the Slavery
Abolition Act of St Kitts was effective to bring an end to slavery in
Anguilla.
From 1825 Anguilla began to share the
judiciary of St Kitts. The Chief Justice
of St Kitts and Anguilla, under the authority of a Writ of Assizes issued by
the governor, visited Anguilla at intervals to conduct the Court of Oyez and
Terminez for the trial of criminal cases.
All previous trials between 1650 and 1825 had been completely
unauthorised by any similar enactment or other formal law or legal system.
The first Courthouse on Anguilla appears to
have been deputy governor Benjamin Gumbs’ house[14] on the
top of Crocus Hill, turned over to public use after his death. There is no surviving record of how this came
to be. The little complex of
out-buildings around the main house served as the Customs House, Post Office
and Police Station.
Illus 1. The Old Courthouse on top
of Crocus Hill on Armistice Day, 1919
It
was for some 150 years the administrative centre of the island. It was approached from South Hill and North
Hill villages and the west via the public footpath from North Hill. It passed down into Katouche Bay Valley and
up the public path to the Valley where the road leading to the Masara Resort
now runs. The Old Courthouse was ideally
located, as Crocus Bay, the main port of entry, lay to the west at the foot of
the hill, while the town of The Valley lay immediately to the east. When the Chief Justice visited Anguilla from
St Kitts, the main building of the complex served as the Courthouse. Living accommodation for the visiting Judge
was problematic. For at least the first
50 years after 1825, the visiting Judges complained to the lieutenant governor
in St Kitts that, as there was no guest-house in Anguilla, they were forced to
spend their nights on board the schooner in the harbour.
Presiding at the first sittings of the Court Oyez
and Terminez, and later of the Court of Kings Bench, to hear criminal and civil
cases in Anguilla was Richard Williams Pickwood, CJ of St Kitts and Anguilla,
and Anguilla’s first High Court Judge. Joining
him on the bench at the Courthouse were two Assistant Justices, who acted as
assessors of the facts.[15] A minute of their proceedings in criminal
matters for several years is preserved in the records held in the Archives in
Basseterre, St Kitts, and at Kew Gardens in London.
After 1825, Anguilla’s legal and judicial
system evolved in tandem with that of St Kitts, and the colony was now
officially titled “St Christopher and Anguilla.” Significantly, in 1882, when the Council and
Assembly of Nevis were dissolved, and Nevis joined to create a three-island
colony, it was, from then until 1967, officially known as the “Colony of St
Christopher and Nevis”. The name of Anguilla
was dropped, until briefly added to the 1967 Associated State.
With the passing of the Slavery Abolition
Act of 1834, Special Magistrates appointed by St Kitts were stationed in
Anguilla to oversee the Apprenticeship Period which lasted until 1838. After 1838, and until 1882, the Magistrates
of Anguilla were usually professional lawyers who were appointed as Stipendiary
Magistrates, meaning they got paid. The
first on record was Thomas Egar (who served 1835-1841).[16] He was followed by other qualified lawyers
who doubled as the St Kitts-appointed local administrator for Anguilla. The most famous and long-lasting was Chief
Justice Pickwood’s son, Robert William Pickwood, who served for 20 years from
1842-1862. He was so dedicated to his
duties in Anguilla and so well-respected by everyone that, when he died in St
Martin, the funeral that the French gave him was described in the official
correspondence as almost a state funeral.
The old Courthouse with its out-buildings
stood from the mid-1700s, when it was first built, until 1955 when
Hurricane Alice hit the island. This
hurricane completely destroyed the wooden structure, leaving only the stone
foundations remaining.
Illus 2. The foundations of the Old
Courthouse on Crocus Hill
The
masonry basement, including the cellar which served as the prison cell while Court
was in session, can still be seen there.
The ruins are overshadowed by two large, ugly, black Rubbermaid water
storage tanks and two equally large and ugly radio aerials raised in the
Courthouse yard. Goats, mimosa and
Flamboyant trees and strangler fig compete to see which can be first to totally
destroy the abandoned remains.
In the years after 1955 when Hurricane Alice destroyed Governor Benjamin Gumbs’ old Courthouse building, temporary quarters
were found in the private home of “Uncle Willie” opposite the present Comprehensive
School.
Illus 3. Uncle Willie’s house in the background
across the road from the Secondary School in 1969 during the Invasion by
British troops
The
original wooden building has now been replaced with a modern concrete
structure, occupied by NAGICO across from the High School.
Illus
4. The concrete building that replaced the original wooden structure of Uncle
Willie’s house, as seen today from the approximate position the photograph in
illustration 3 was taken
It was only in the year 1964 that the St
Kitts government built a new Courthouse for Anguilla. Wallace Rey was appointed to head Anguilla’s
public works after he retired from the US Air Force Base in Antigua where he
had found employment at the start of World War II. Wallace Rey designed and built the new Court
building. Its reinforced-concrete
transverse arches that reach up from the foundations, and go up and over the
roof to descend on the other side, made it one of the most imposing structures
at the time on the island. Its design
reflects that of St Mary’s Anglican Church, which he also designed and built
around the same time.
Wallace Rey’s 1964 building served, at first,
only the Magistrate and the occasional visiting High Court Judge. Later, it was to also house the Anguilla
House of Assembly, and the Court of Appeal.
These all shared the one-room premises without difficulty, since when
the High Court Judge or the Court of Appeal visited, no other Court or the
Assembly sat. The Magistrate doubled as
Registrar of the Supreme Court.
This was the system in place which I met when
I was appointed Magistrate of Anguilla and Registrar of the Supreme Court in
August 1976.[17] At that time, and for the next several years,
the only lawyers in the public service were the Attorney-General and the
Magistrate. The first Crown Counsel to
assist the Attorney-General, Kurt Defreitas, was appointed in the late 1980s. As for Wallace Rey’s building in which I
served as Magistrate and Registrar, it is no longer a Courthouse. It presently serves as the offices of the
Statistics Department.
Illus 5. Wallace Rey’s courthouse
building, much the worse for wear after Hurricane Irma
The short-lived West Indies Federation broke
up in 1961 when Jamaica chose to go into independence rather than stay tied to
the smaller islands. Trinidad and
Barbados left shortly after, and the Federation was dissolved. By the year 1967, the individual colonies of
the Leeward and Windward Islands were themselves headed to independence. They first entered into the intermediate status of ‘Associated Statehoodship’ with Great
Britain. The old, separate Supreme
Courts of the Leeward Islands and that of the Windward Islands, re-established
after the collapse of the Federation in 1961, were merged into the new ‘West
Indies Associated States Supreme Court’.
3.
From the Anguilla Revolution of 1967 to Today
Associated Statehoodship
brought with it the West Indies Associated States Supreme Court. It had a short life span in Anguilla. Almost immediately, Anguilla was in rebellion
against being forced into Statehoodship with St Kitts and Nevis. The Anguilla Revolution of 1967 was the first
successful armed revolt in the British West Indies. I am told that the thirteen members of the St
Kitts police force manning the police station were packed onto a LIAT airplane
still dressed in their pyjamas. The St
Kitts Judge was jeered out of his Courthouse and chased down the runway until
he boarded a waiting flight to take him back to St Kitts. The social welfare officer, Raphael Lake, was
appointed Magistrate by the Anguilla Council, and functioned in that office until
he was replaced by the British administration after their invasion of the
island in 1969.
In 1971 the British
Parliament passed the Anguilla Act, which permitted Britain to
separately administer the Anguillian part of the Associated State of St Kitts,
Nevis and Anguilla. Britain selected and
paid for a Magistrate, a High Court Judge, and three Judges of the Court of
Appeal. These were appointed by the
Judicial and Legal Services Commission of the West Indies Associated
States. Appeal lay to the Privy Council,
and at least one appeal went all the way before Anguilla re-joined the official
West Indian judicial family. The Judges
were mainly retired West Indians, while the Magistrates came from either
Britain or the West Indies.
In the early part of 1972, the first laws
for Anguilla, made in Anguilla, were enacted under the provisions of the 1971
Constitution. There were twenty-six laws
in all, covering such matters as financial administration,[18] police,[19] council elections,[20] marriages,[21] courts,[22] and taxes.[23] These laws were made by the Commissioner “after consultation with the Anguilla Council”. They were not introduced into and debated in
any legislative Assembly in the normal way.
They were enacted by the Commissioner.
This was not a satisfactory state of affairs, and this early period was
marked by disputes between the local members of the Anguilla Council and the
British Commissioner.
The first general elections under the new
Constitution were held on 24 July, 1972.
The Fourth Anguilla Council that resulted found itself completely
without any power. Laws continued during
1973 to be made by Her Majesty’s Commissioner “after consultation with the Anguilla Council” without the benefit
of debate in any Legislative Assembly.[24] The situation remained unchanged during 1974
and 1975. The Anguilla Council was
continually unhappy with the arrangement that gave the Commissioner total power
and control. The result was a series of
strikes and other civil unrest during the period of legislation by the
Commissioner.
The constitutional crisis of 1974 and 1975,
caused in part by the lack of an Assembly in Anguilla, was calmed when the
British agreed to constitutional reform.
The 1976 Anguilla Constitution[25] was made on 19 January
and came into effect on 10 February, 1976.
For the first time, this provided for laws to be made by the
Commissioner “with the advice and consent
of the Assembly”. Laws passed from
this date were introduced into and debated in the Legislative Assembly, and
then assented to by the Commissioner.
These are proper laws as we understand them. They can be said to be the first laws that
were truly made by the elected representatives of the people. The first such law was a humble and
insignificant one, now long forgotten.
The Anguilla Fund and Financial Administration (Repeal) Ordinance, No
1 of 1976 did nothing more than bring back the old St Kitts Finance and
Audit Ordinance of 1965 with such modifications as were necessary to bring
it into conformity with the Constitution of Anguilla. It was passed by the Legislative Assembly on
13 May, 1976. It commences with, what
for a lawyer, are the magical words, “Enacted
by the Legislature of Anguilla”.
Modern constitutional government had at last come to Anguilla.
In 1980, the People’s Action Movement political
party in St Kitts gained power by defeating the Labour Party in general
elections. The administration of the new
St Kitts-Nevis premier, Dr Kennedy Simmons, negotiated with Britain for
independence. The British agreed, on
condition that Sombrero was transferred to Anguilla from which they could more
easily control the light-house on that island and the sea approaches to the
Panama Canal, and on condition that St Kitts let Anguilla go. So, by mutual agreement, Anguilla was
separated from the Associated State and reverted to full colonial status. St Kitts-Nevis agreed, and Anguilla was
brought under full colonial rule on 16 December 1980 by the Anguilla Act
1980 of the UK Parliament.
In the year 1982, the Eastern Caribbean
Supreme Court, to give recognition to the demise of the Associated States and
their replacement by independent Commonwealth Caribbean countries, replaced the
West Indies Associated States Supreme Court throughout the region. The Robert Bradshaw regime had previously
vetoed Anguilla’s participation in any regional institutions, including the
regional Court. The new St Kitts
government of Dr Kennedy Simmonds relented, and Anguilla began to join the
various regional bodies. The Anguilla
Assembly passed the Eastern Caribbean Supreme Court Act, and re-entered
the fold of the regional judiciary. From
that time the Magistrates and Judges of Anguilla have been selected and appointed
by the Judicial and Legal Services Commission, headquartered in Saint Lucia.
By the late 1990s the old Courthouse was no
longer adequate to serve as a multi-purpose building. The tourism industry had fuelled an enormous
growth in the economy, and crime and other litigation had mushroomed. With British financial assistance, a new
building was constructed in the administration grounds. Until Hurricane Irma of 2017, it housed the
Magistrate’s Court, the High Court, and the House of Assembly. With the destruction of the roof over the
House of Assembly on 6 September 2017, the two surviving courtrooms struggle to
serve all three bodies as best they can.
Illus 6. The present Courthouse
building of the 1990s
Delivered by Invitation at the Launch of the
Computerised Registry System at the Court House in the Valley, Anguilla, on
Friday 8 June 2018
[1] Abraham
Howell, Anguilla’s first deputy governor, in a patent preserved in the Anguilla
Archives stored at the Courthouse, describes himself as having been elected as
deputy governor in the year 1666.
[2] In
England, between 1653 after the dissolution of the ‘Rump Parliament’, and 1659
when the Rump Parliament was recalled, Oliver Cromwell ruled England as Lord
Protector during the period known as the ‘Protectorate’. The UK Parliament
therefore has been continuously sitting only since 1659.
[3] Acts
of Assembly, Made and Enacted in the Bermuda or Summer Islands, from 1690 to
1713/1714. (London: Printed by John Baskett) v,79 pages folio, 1719.
[4] Acts
of Assembly Passed in the Island of Montserrat; from 1668, to 1740, Inclusive,
with an Abridgement. (London: Printed by Order of the Lords Commissioners of
Trade & Plantations by John Baskett) x,146 pages folio, 1740.
[5] Acts
of Assembly, Passed in the Island of Nevis from 1664, to 1739, Inclusive, With
an Abridgment. (London: Printed by Order of the Lords Commissioners of Trade
& Plantations by John Baskett) viii,168 pages folio, 1740.
[6] Acts
of Assembly Passed in the Island of St Christopher; from 1711 to 1735,
Inclusive. (London: Printed by John Baskett) x,182, 1leaf, 169-198 pages
folio, woodcut ornaments, 1739.
[7] Anguilla
Council Minutes, 1819-1841, previously cited.
[8] John
Oldmixon, The British Empire in America (1708), Vol 2, p.264.
[9] The
term ‘cattle’ at the time included pigs, sheep and goats. It was probably this last which the settlers
brought to the island.
[10] CO
152/21: Mathew to the Committee.
[11] See
for example the various correspondence and dispatches at CO.407/1 between Lord
Bathurst and Governor-in-Chief Maxwell on the need for Anguilla to have laws.
[12] CO.240/16,
at folio 315: Act No 198. An Act to Authorise the Freeholders of the Island
of Anguilla to Send a Representative to the House of Assembly in the Island of
St Kitts (usually referred to as the “Anguilla Act”.
[13] In
Anguilla and the Leeward Islands the property qualification was removed in
1951, and universal franchise was introduced by the first Elections Ordinance.
[14] Its
dimensions are so modest that one has difficulty referring to it as his ‘Estate
Great House’.
[15] CO.240/17,
folio 1. The law which enabled this sitting was entitled, Act No 1: An Act
for Establishing Courts and Settling Due Methods for the Administration of
Justice in the Island of Anguilla.
[16] CO.239/67,
Dispatch No 13: Mr McPhail to EG Stanley, Secretary of State for the Colonies
[17] Among
the hats the Magistrate of Anguilla wore at that time were Registrar of the
Supreme Court; Coroner; Registrar General of Births Deaths and Marriages;
Registrar of Companies, Trade Marks, Patents, Co-operative Societies, Credit
Unions, Friendly Societies, Newspapers, and Trades Unions; Secretary to the
Medical Board; and Island Archivist. That explains why, when the Registry of
the Supreme Court and the Registry of Companies were hived off in the 1990s,
the Magistrate remained head of the Judicial Department.
[18] The Anguilla Fund and Financial Administration
Ordinance, No 1 of 1972.
[19] The Anguilla Police Ordinance,
No 3 of 1972.
[20] The Anguilla Council Elections Ordinance,
No 4 of 1972.
[21] The Marriage Validation Ordinance, No
8 of 1972.
[22] The Court of Appeal (Special Provisions)
Ordinance, No 10 of 1972; and the Supreme Court
(Amendment) Ordinance, No 26 of 1972.
[23] The Rum Duty (Anguilla) (Amendment) Ordinance,
No 13 of 1972; Boat Licensing (Amendment) Ordinance, No 14 of 1972; Liquor
Licensing (Amendment) Ordinance, No 15 of 1972; Export Duty (Amendment)
Ordinance, No 16 of 1972; Stamp Act (Amendment) Ordinance, No 18 of
1972; Vehicles and Road Traffic (Amendment) Ordinance, No 19 of 1972; Firearms
(Amendment) Ordinance, No 20 of 1972; Public Pounds (Amendment)
Ordinance, No 21 of 1972; Anguilla Airport (Embarkation) Tax Ordinance,
No 24 of 1972.
[24] There
were eight such laws in all, including the Anguilla Roads Ordinance, No
5 of 1973; the Anguilla Local Constables Ordinance, No 6 of 1973; the Accommodation
Tax Ordinance, No 7 of 1973; and the Telecommunication Ordinance, No
8 of 1973.
[25] The
Anguilla (Constitution) Order 1976, (SI 1976 No 50).
