Worlledge V Manning (1786)
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''Worlledge v Manning'' (1786) East, 26 Geo. 3 CB; 126 ER 34 is a
landmark A landmark is a recognizable natural or artificial feature used for navigation, a feature that stands out from its near environment and is often visible from long distances. In modern use, the term can also be applied to smaller structures or f ...
judgment in
English law English law is the common law legal system of England and Wales, comprising mainly criminal law and civil law, each branch having its own courts and procedures. Principal elements of English law Although the common law has, historically, be ...
by the House of Lords and was formative to the modern legal understanding of private property rights. A precedent for gleaning is to be found in the Bible at Leviticus 19:9-10. The matter related to
gleaners Gleaners, Inc., also known as The Volunteers Of Gleaners, is a Jackson, Mississippi-based non-profit organization founded by Gloria Martinson in 1986 (not to be confused with the Gleaners Food Bank in Indiana, a non-profit organization which h ...
' rights and arose from a disagreement about gleaning during the 1785
harvest Harvesting is the process of gathering a ripe crop from the fields. Reaping is the cutting of grain or pulse for harvest, typically using a scythe, sickle, or reaper. On smaller farms with minimal mechanization, harvesting is the most labor-i ...
. After the barley crop had been cut and cleared, a
Timworth Timworth is a village and civil parish north east of London and east of Cambridge in the West Suffolk district of Suffolk in eastern England. Located around two miles north of Bury St Edmunds, its 2005 population was 50. At the 2011 Census the ...
shoemaker, Benjamin Manning, had gone onto the land of John Worlledge, the richest farmer, in the adjoining parish of
Ingham, Suffolk Ingham is a village and civil parish in the West Suffolk district of Suffolk in eastern England, located about six miles north of Bury St Edmunds on the A143 to Thetford in Norfolk. The village boasts a single church, post office and a pub, the C ...
to
glean Gleaning is the act of collecting leftover crops from farmers' fields after they have been commercially harvested or on fields where it is not economically profitable to harvest. It is a practice described in the Hebrew Bible that became a legall ...
and had carried away a quantity of barley. Worlledge disputed his right to do so and brought an action for trespass in the Court of Common Pleas. The court decided in Worlledge's favour in May 1786 and awarded him damages and costs. : The court held that the
defendant In court proceedings, a defendant is a person or object who is the party either accused of committing a crime in criminal prosecution or against whom some type of civil relief is being sought in a civil case. Terminology varies from one jurisdic ...
was not an
inhabitant Domicile is relevant to an individual's "personal law," which includes the law that governs a person's status and their property. It is independent of a person's nationality. Although a domicile may change from time to time, a person has only one ...
of the parish in which he gleaned, and was not entitled to the gleaning support. The Court therefore decided that ''a stranger had no right to glean''.Henry Blackstone, Reports of cases argued and determined in the Courts of Common Pleas Volume
page 54
accessed 2 October 2012).
This was the first time that gleaners’ rights had been challenged and it served as a precedent and possible catalyst for the landmark case '' Steel v Houghton'' a year later. In a separate matter, Manning attempted to prosecute Worlledge for
assault An assault is the act of committing physical harm or unwanted physical contact upon a person or, in some specific legal definitions, a threat or attempt to commit such an action. It is both a crime and a tort and, therefore, may result in crim ...
at the
Suffolk Suffolk () is a ceremonial county of England in East Anglia. It borders Norfolk to the north, Cambridgeshire to the west and Essex to the south; the North Sea lies to the east. The county town is Ipswich; other important towns include Lowes ...
quarter sessions court.


See also

* ''Steel v Houghton'' (1788)


References

{{reflist 1786 in case law English property case law 1786 in British law House of Lords cases