84 THE ZOOLOGIST. 
discover, unless any of the pleadings in the action have by 
chance been preserved. The plaintiff may without doubt be 
identified as Dr. Cuthbert Tunstall, created Bishop of London in 
1522, appointed Keeper of the Privy Seal in 1523, and translated 
to the see of Durham in 1530. Some account of him will be 
found in Faulkner’s ‘ Historical and Topographical Account of 
Fulham,’ 1818 (p.199), Hutchinson’s ‘ History of Durham’ (vol. i. 
p- 440), and in Fox’s ‘ Synopsis of the Newcastle Museum,’ 1827 
(p. 5), in a memoir of one of its founders, Marmaduke Tunstall, 
author of the ‘ Ornithologia Britannica,’ and a descendant of the 
Bishop’s brother, Sir Brian Tunstall, who was killed at Flodden 
in September, 1518. In the last-named work will be found a 
pedigree of the Tunstall family. 
Dr. Tunstall, whose portrait hangs in the library at Fulham 
Palace, was evidently a naturalist who liked to see the birds 
building in his park, and no doubt was one of those who warmly 
supported the measure for the protection of wildfowl which 
became law only a few years later. 
In 1584 an Act was passed by which “ Shovelers,’ Herons, 
and other wildfowl were protected between the 1st March and 
the 30th June. This Act intituled, ‘‘ an Acte to avoide destruction 
of Wilde-fowle”’ (25 Hen. VIII. cap xi) prohibited the taking of 
‘any maner of egges of any kinde of wildfowle from or in any 
neste place or places where they shall chaunce to be laide by any 
kinde of the same wildfowle upon peine of imprisonment for one 
yere, and to lose and forfait for every egge of any Crane or 
Bustarde so taken or distroid xx pence, and for every egge of 
every Bittour, Heronne, or Shovelarde viijd, and for every egge of 
every Malarde, Tele, or other wildfowle one penie ; the one moitie 
thereof to be to the King our soveraigne lorde, and the other 
halfe to him that will sue for the same in forme aforesaide.” * 
The heronry in the Bishop’s park was in all probability 
a very ancient one at the date of the action, Fulham itself being 
a place of great antiquity. In the earliest document in which 
nouvellement imprimé, corrigé, & revieué ; ove plusieurs bonnes Notes en la 
Marge par tout le Livre, &c. Folio, London, MDCLXXIX.” These Reports go 
back to the time of Edward I., and were printed from ancient MSS. in the 
possession of Sir J. Maynard, Knt., Serjeant-at-Law to Charles IT. in 1678. 
** Herons were protected by 19 Hen. VII. c.11. See Nelson’s ‘Game 
Laws’ (sixth edition, pp. 168. 169). 
