NOTE:  Plaintiffs remarks are in bold. 
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1912. B. No. 2110

In the High Court of Justice [in ENGLAND]
KING'S BENCH DIVISION.

Fos. 15

BETWEEN JOSEPH BURFITT,
FREDERICK CARTER,
ESCORT ALFRED HENRY BURFITT,
and ROSALIE ELLEN MARY BURFITT Spinster, Plaintiffs

AND

REVEREND DOUGLAS LLEWELLYN HAYWARD
and RICHARD MAINSTONE, Defendants

Statement of Claim.

1. The Plaintiff Joseph Burfitt is a farmer residing at Goodedge Farm in the Parish of North and South Brewham near the town of Bruton in the County of Somerset. The Plaintiff Frederick Carter is a carpenter also residing in the said parish. The Plaintiff Escort Alfred Henry Burfitt is the son and the Plaintiff, Rosalie Ellen Burfitt is the daughter of the Plaintiff Joseph Burfitt and they are both resident at Goodedge Farm aforesaid.

2. All the Plaintiffs are and were at all material times members of a religious community popularly known as the "Go Preachers." At all material times the Plaintiffs Escort Alfred Henry Burfitt and Rosalie Ellen Mary Burfitt were preachers of the said community and the Plaintiff Frederick Carter occasionally preached at meetings held by the members. The religious tenets of the said community are based on a literal interpretation of the New Testament.

3. The Defendant the Reverend Douglas Llewellyn Hayward is and was at all material times the vicar of the said parish and town of Bruton and the Defendant Richard Mainstone is and was at the like times a local hairdresser in the said parish and town of Bruton.

4. In the month of June 1912 a Convention for the deepening of spiritual life was held by the said community at the farm of the Plaintiff Joseph Burfitt lasting for ten days from the 14th to the 23rd of June at which all the Plaintiffs were present and in which they took an active part as was well known to the inhabitants of the said parish of North and South Brewham and of the parish and town of Bruton and neighbourhood.

5. On or about the 21st of June 1912 the Defendants falsely and maliciously published and caused to be published of and concerning the Plaintiffs and each of them the words following:

“We being overseers of the poor of various parishes in Suffolk, England feel it our duty to warn every man woman and child against countenancing or in any way encouraging those men and women who come among us and call themselves by various names such as ‘Go Preachers,’ ‘No Sect,’ ‘No Church,’ etc. (meaning the Plaintiffs) and endeavour to entice away our children especially our young girls under the cloak of religion. Many girls have been induced to leave their homes to their great distress and sorrow.

"We have seen letters from some of these girls which describe their painful experience among these people abroad. There can be no doubt that the religious fervour and apparent zeal displayed by the people here (meaning the Plaintiffs) may be treacherous baits to catch the unwary for an improper purpose. No words of ours are sufficiently strong to describe this horrible work and in the interests of all we strongly and earnestly warn parents and children to avoid these so-called preachers as they would The Most Deadly Plague."

6. The said words meant and were understood to mean that the Plaintiffs and each of them were guilty of criminal offences and were engaged in and the confederates of people engaged in procuring young girls and women for immoral purposes under the cloak of religion and were hypocrites and persons of the vilest and most loathsome kind and corrupters of public morals and were deserving of public odium and contempt and that this could be proved by the overseers of 20 parishes and all the overseers of Ipswich and by letters from girls who had been the victims of the Plaintiffs and decoyed by them out of the country for the purposes of prostitution.

7. The said words were published in the form of a printed leaflet, a copy of which was transmitted or handed to the Defendant Mainstone by the Defendant Hayward with the request that the former would publicly exhibit it in a prominent place and was by the Defendant Mainstone in accordance with such request exhibited in a glass frame outside his shop in Bruton on and about the 21st June 1912. Other copies of the said leaflet were at about this time distributed in Brewham and Bruton aforesaid and the neighbourhood by the Defendant Hayward to Mrs. Amor who keeps a stationer's shop at Bruton to several persons who passed her shop whilst the said Defendant was there to the Chief Constable to the Magistrate's Clerk and to Police Constable Carr and others.

The Plaintiffs are unable at this stage to give any further or better particulars of publication but they will rely on every publication that may be ascertained on discovery.

8. By reason of the premises the Plaintiffs have suffered much damage and been greatly injured in their reputations and brought into public odium and contempt.

9. The Plaintiffs claim—

(A) Damages.
(B) An injunction to restrain the Defendants and each of them their agents and servants from publishing or circulating or causing to be published or circulated the said words or any of them or any similar libel or attack on the Plaintiffs or either of them.

J. BROMLEY EAMES.

DELIVERED the 26th day of February 1913 by PILGRIM & PHILLIPS of 14 and 15 Coleman Street in the City of London.
Agents for Francis Glover & Son of the City of Bath Solicitors for the Plaintiffs.

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