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=== British West Indies === In 1888, [[Louis de Souza (barrister)|Louis de Souza]], a young barrister in [[British Guiana]] was fined $500 and imprisoned for six months for contempt of court for publicly criticising judicial decisions.<ref name=":12">{{Cite journal |date=21 November 1988 |title=Currente Calamo |url=https://www.google.com.au/books/edition/Pump_Court/ZC8WAAAAYAAJ?hl=en&gbpv=1 |journal=Pump Court |volume=8 |issue=110 |pages=49}}</ref> De Souza applied for special leave to appeal his case to the [[Judicial Committee of the Privy Council|Privy Council]] as the decisions that he had criticised were not ongoing or cases in which he appeared and, therefore, broader than disrespect to legal authorities in a courtroom. A few years earlier, in Grenada, a newspaper had also been sanctioned for defaming a judge by printing remarks about a case.<ref>{{Cite news |date=15 December 1888 |title=Contempt of Court |url=https://ufdc.ufl.edu/AA00079373/01348/zoom/2 |access-date=9 February 2025 |work=San Fernando Gazette |pages=3}}</ref> The Privy Council granted De Souza's leave,<ref>{{Cite journal |date=29 December 1888 |title=Currente Calamo |url=https://www.google.com.au/books/edition/Pump_Court/ZC8WAAAAYAAJ?hl=en&gbpv=1&dq=%22louis+de+souza%22&pg=PA98&printsec=frontcover |journal=Pump Court |volume=8 |issue=115 |pages=2}}</ref> with the judges apparently remarking that judges in England are subjected to far worse.<ref>{{Cite news |date=29 December 1888 |title=Mr De Souza Scores a Victory over the Demerara Judges |url=https://ufdc.ufl.edu/UF00094730/12702/zoom/2 |access-date=9 February 2025 |work=Port of Spain Gazette |pages=3}}</ref> De Souza, however, contracted [[tuberculosis]] while in jail and died 3 months after his release.<ref name=":322">{{Cite news |date=17 April 1889 |title=”Death of Mr. L. De Souza |url=https://ufdc.ufl.edu/AA00076890/03224/zoom/1 |access-date=30 January 2025 |work=Nassau Guardian |pages=2}}</ref> His imprisonment was reported across the [[West Indies]] and his death elicited outrage.<ref name=":32">{{Cite news |date=17 April 1889 |title=”Death of Mr. L. De Souza |url=https://ufdc.ufl.edu/AA00076890/03224/zoom/1 |access-date=30 January 2025 |work=Nassau Guardian |pages=2}}</ref> [[Valence Gale]], a [[Barbadians|Barbadian]] journalist, wrote passionately about the events leading up De Souza's death.<ref name=":02">{{Cite news |last=Hoyos |first=F. A. |date=6 September 1952 |title=Our Common Heritage: Valence Gale |url=https://ufdc.ufl.edu/UF00098964/02980/zoom/3 |access-date=3 February 2025 |work=The Barbados Advocate |pages=4}}</ref><ref>{{Cite book |last=Straker |first=D. Augustus |author-link=D. Augustus Straker |title=A trip to the Windward islands |publisher=James H. Stone Press |year=1896 |location=Detroit, Michigan |pages=90 |language=en |quote=}}</ref> One of his articles is credited with paving the way for the passage of [[Barbados|Barbados']] Contempt of Court Act 1891,<ref name=":02" /> the first of many across the [[West Indies]].
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