A taste for salacious gossip, particularly that of a sexual nature, is nothing new. It’s a stereotype, but probably a true one, that Georgian London was a bawdy place and had no shortage of scandal to go round. The spreading of scandalous stories was helped by the 18th century explosion in the newspaper trade, particularly in London. In 1770, London had 5 daily papers; by the 1780s it had 9 dailies, 8 tri-weeklies and 9 weeklies. Aside from political and financial news, a large part of what was driving that growth was the reportage of scandal, whether sexual or otherwise. Given all this, it’s not surprising that legal cases concerning rape, sodomy, bestiality and adultery were eagerly followed and commented upon in the papers. Entrepreneurial businessmen would print cheap mass-produced pamphlets with an account of everything which had happened in a trial, although their reliability is doubtful; sometimes the note-taker in court would get bored or confused and left out bits and misreported others.
One of the more curious Old Bailey cases depicted in Garrow’s Law is that of the prostitute Susannah Hill, who was prosecuted in 1791 by William Garrow on the charge of hanging a man named Frantisek Kotzwara. On 2nd February of 1791, Kotzwara, a Czech musician and small-time composer, visited Hill in her lodgings in Vine Street (an alley in Westminster, now more famous for its place on the London Monopoly board). After dinner, he gave her two shillings and asked her to castrate him. Hill refused, but not wanting to lose Kotzwara’s custom, she agreed to his next odd proposition. He tied a noose around his neck which was attached to the doorknob, and they had sex. After the deed was done, Kotzwara was found dead.
It’s one of the first recorded cases of erotic asphyxiation. (Interestingly, Victorian men who also got aroused by the sensation of being partially hanged could visit ‘Hanged Mens’ Clubs’, in which death by asphyxiation was more of an unfortunate side effect than a planned event). In the subsequent murder trial at the Old Bailey, the jury acquitted Hill because it seemed to have been an accident, at least on her part. Someone – probably the judge – requested that the court records of the trial be destroyed in order to avoid scandal and a slew of copycat cases. It’s very likely that a copy got out anyway, since a pamphlet published in 1797, Modern Propensities; or, An Essay on the Art of Strangling, featured a detailed summary of the trial along with Hill’s memoirs. The front cover illustration of Hill and Kotzwara looking rather jolly, shown below along with the title page, is so prominent that it’s obvious that this pseudo-scientific pamphlet relied very heavily on the scandalous in order to sell.
One perennially bestselling source of sexual scandal is of course adultery. It’s a theme which runs throughout Garrow’s Law and indeed throughout the Georgian press. Then as now, the general public would shake their heads in outrage at the news of some extramarital affair and were only too quick to swallow whatever the media told them. In many cases no doubt the Georgian readers did hold genuine moral beliefs against adultery. Yet these stories wouldn’t have sold as half as well as they did if there wasn’t a keen interest in sexual scandal, hiding behind all the public prurience.
From a modern perspective we might assume that when a husband initiated adultery proceedings, it would be against his wife. That wasn’t the case in Georgian England, where the injured husband would bring an action against his wife’s supposed lover. The lover hadn’t committed a criminal offence as such, but if found guilty of adultery (‘criminal conversation’ as it was euphemistically known) he would have to pay the husband compensation, the idea being that he’d damaged the other man’s property (his wife). Because of this, adultery trials took place in the civil courts, particularly in the Court of the King’s Bench.
The criminal conversation trial between William Garrow and Sir Arthur Hill shown in Garrow’s Law never actually occurred in real life, but the show’s writers based it on an actual trial which is interesting for its rather extraordinary outcome. Sir Richard Worsley (1751-1805) was a politician and antiquarian who married 17-year-old Seymour Dorothy Fleming in 1775. Although she brought the considerable sum of £70,000 into the marriage, they were badly suited and the marriage soon fell apart. Lady Worsley was rumoured to have had 27 lovers. She had a child by Maurice George Bisset, an officer of the Hampshire militia and a friend of Sir Richard’s, with whom she then ran off in November 1781. Although Sir Richard had previously acknowledged the child as his own in order to avoid scandal, after their elopement he was out for revenge, and in 1782 he brought a criminal conversation case against Bisset for £20,000. At first the case looked like a strong one. Lady Worsley’s past history of adultery would tell against her, and there was fairly sound evidence to show that she had lain with Bisset. But as the trial unfolded, shocking revelations brought the prosecution into doubt.