Clifton Star Chamber Case

The Clifton Star Chamber Case or Clifton vs. Robinson refers to a court case that took place in early modern England, in 1601, before the Star Chamber, concerning the abduction of children by choir schools.[1]

The caseEdit

In 1601, Henry Clifton, a nobleman from Norfolk,[2] sued the Blackfriars company (headed by Gyles, Robinson, and Evans) for their abduction of his son Thomas Clifton, on 13 December 1600.[3] Henry Clifton obtained a warrant from Sir John Fortescue, who granted it using his authority as a member of the Privy Council due to his connections and high social status.[4][5][6] The basis for the case is not that Thomas Clifton was forcibly impressed into the choir school (which was entirely legal) but that the boy was made to act in the plays of Children of the Chapel.[7] In 1606, possibly as a result of this case, the royal patent allowing the Master of the Children of the Chapel Royal to impress children into service was revised to stipulate that choristers who had been forcibly impressed would not be "used or employed as Comedians or Stage players."[8]

Importance of the caseEdit

The Clifton case is one of the only surviving objections to the common practice of forcibly impressing boys into ecclesiastical choir schools in medieval and early modern England. It is notable that the objection is to the child's involvement in the controversial children's theater companies of the period. Forcible impressment was royally sanctioned, as is evidenced in letters from Elizabeth I on 15 July 1597 for the master of the Children of the Chapel.[7] The prevalence of the practice is evidenced by documents such as an authorization for the Chapel Royal in 1420 and An Ordinance of the Lordes and Commons Assembled in Parliament, for the Apprehending and Bringing to Condigne Punishment, All Such Lewd Persons as Shall Steale, Sell, Buy, Inveigle, Purloune, Convey, or Receive Any Little Children (9 May 1644).[7] Besides Thomas Clifton, we also have information on the recruitments of Salmon Pavey, Avery Trussell, John Chappell, Nathan Field, John Motteram, Philip Pykman, and Thomas Grymes by choir schools.[7][9]


  1. ^ "Henry Clifton". 2016. Retrieved 2020-02-18.
  2. ^ Heller, Herbert Jack (2000). Penitent Brothellers: Grace, Sexuality, and Genre in Thomas Middleton's City Comedies. Newark: University of Delaware Press. p. 123. ISBN 9780874137019.
  3. ^ Archives, The National (2016-05-12). "The National Archives - Kidnapped to order: child actors in Shakespeare's day". The National Archives blog. Retrieved 2020-02-18.
  4. ^ Jenstad, Janelle (29 September 2017). "Blackfriars Theatre". The Map of Early Modern London. University of Victoria. Retrieved 30 October 2017.
  5. ^ Forse, James H. (1993). Art Imitates Business: Commercial and Political Influences in Elizabethan Theatre. Bowling Green: Bowling Green State University Popular Press. pp. 191–194. ISBN 9780879725952.
  6. ^ Bullough, Vern L.; Bullough, Bonnie (1993). Cross Dressing, Sex, and Gender. Philadelphia: University of Pennsylvania Press. pp. 80–81. ISBN 9780812214314.
  7. ^ a b c d Ackroyd, Julie (2017). Child Actors on the London Stage, Circa 1600: Their Education, Recruitment, and Theatrical Success. Chicago, IL: Sussex Academic Press. pp. 4–58. ISBN 9781845198480.
  8. ^ Lamb, Edel (2009). Performing Childhood in the Early Modern Theatre: The Children's Playing Companies, 1599-1613. Basingstoke: Palgrave Macmillan. p. 10. ISBN 978-0230202610.
  9. ^ Corrigan, Brian Jay (2004). Playhouse Law in Shakespeare's World. Madison: Fairleigh Dickinson University Press. pp. 74–75. ISBN 9780838640227.