Catalogue reference: CO 101/78/5 folio 19.
That Your Petitioner humbly states that he ought not to have been so convicted and sentenced because no evidence was produced or shewn to the Court or Jury of Your Petitioner having given or caused to be given any person or persons drug pounded glass or other deleterious matter to the person or persons named in the said Indictments and because the giving or causing to be given any poison or poisonous drug pounded glass or other deleterious matter in the practice of Obeah with which your Petitioner was charged by the said Indictments is not punishable by the said Act which was intended to prevent the belief in pretences to Obeah and which only punishes and applies to the mixing or preparing with an intent to give or cause to be given any poison or poisonous drug pounded glass or other deleterious matter in the practice of Obeah with which Offences your Petitioner was not charged by the said Indictments and because the Courts in the said Indictments which charged Your Petitioner with having in his possession certain materials notoriously used in the practice of Obeah are uncertain and insufficient and ought to have specified the nature kind or description of materials in order that Your Petitioner might have been enabled to prepare his defence accordingly and to plead his conviction in bar of any other prosecution for the same Offence and because (the said Courts not charging Your Petitioner with having in his possession any of the Articles or things specified in the said Act) no proof was produced or shewn to the Court or Jury of any other materials in the possession of Your Petitioner being in notorious use in the practice of Obeah.
