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THE LAW OF TREASURE TROVE IN ENGLAND AND WALES

The American Numismatic Society

The only legal protection currently afforded coins and other archaeological objects found in England and Wales is the common law of Treasure Trove whose origins go back to the early medieval period.¹ This paper will firstly discuss how the law of Treasure Trove is currently applied in England and Wales and how the system of rewards works; it will then describe the proposal to reform it, the Treasure Bill, which is being considered by Parliament at the time of writing; it will then discuss the main anomalies of Treasure Trove and the difficulties that are encountered in trying to enforce the law and it will conclude by summarising the campaign for reform and the prospects for the future.

What is Treasure Trove?

        The doctrine of Treasure Trove would appear to be Germanic in origin and its adoption in England probably goes back to Anglo-Saxon times. The current law of Treasure Trove in England and Wales would seem to have derived originally from the principle that all ownerless objects should belong to the King and there is a fundamental contrast with Latin system where such objects belong equally to finder and landowner. This law survives today in its purest form in Scotland, where all ownerless objects are still Crown property under the principle of bona vacantia. In England the law of Treasure Trove has developed in a much narrower way. The law first became formulated in 12th and 13th centuries AD and the description of Treasure Trove in Henry de Bracton's De legibus et consuetudinibus Angliae (c.1250) more or less describes current position. Since it is Common Law rather than Statute Law no definitive written version exists of Treasure Trove. In England and Wales Treasure Trove is limited to objects of precious metal buried with intention of recovery and of which the owner cannot be traced. It is the first two elements that cause most difficulty today.
        It has been suggested that Treasure Trove only extends to objects that have been buried with intention of recovery rather than being lost or abandoned or placed in a grave, because the origin of the law was to discourage people from trying to avoid tax by concealing their wealth, but this is probably to put a modern construction on the evolution of a law under which all ownerless objects originally belonged to the Crown. It has also been argued that the law has become limited to objects of gold and silver for similar reasons: because they were only ones worth claiming at the time. But in fact early accounts are ambiguous on this point: Bracton speaks of 'silver or gold or other kind of metal'². So far as the current position is concerned the matter was decided in 1982 by Lord Denning when he decided that objects have to be made 'substantially' gold or silver in order to qualify as Treasure Trove and he thought that they should have at least 50%.³
        If someone finds an object of gold and silver he should report it to the coroner who will then decide whether to hold a Treasure inquest. The coroner will take expert advice, often from the British Museum. If it is declared Treasure Trove then the find is the property of the Crown; in practice this means that a museum has a right to acquire it, but the finder is rewarded.
        In recent years about 20-30 finds a year have been declared Treasure Trove and 90% of these are coin hoards, although there are also occasional finds of prehistoric gold torcs and Roman and medieval jewellery or plate.⁴ Currently 90% of all Treasure Trove cases are found with metal detectors; the remainder being chance discoveries found during building or earth-moving works, or in the course of archaeological excavations. On the other hand hoards of base metal and bronze coins are not Treasure Trove (there are normally about 5-10 such hoards a year).

Rewards and valuation

        Since middle of the last century it has been appreciated that Treasure Trove did not provide a significant addition to the Crown's revenues since there was no incentive for finders to report their finds and the practice has arisen of paying rewards to the finder. In 1886 the Treasury issued a minute stating that objects that had been declared Treasure Trove should be sent to the British Museum for valuation; that the British Museum should have the right to acquire any objects that they wanted and that they should then be offered to other museums (usually the local museum); and that the finder should receive an ex gratia reward, provided he had behaved properly.⁵
        This remains the current basis for the administration of Treasure Trove. One hopes that finders will have made an agreement to split any reward equally with the landowner as a condition for being given permission to search on their land. However, the finder can still receive a full reward even if he has been trespassing and under no circumstances are landowners eligible for rewards. Only if the finder has behaved dishonestly or improperly will the Secretary of State pay a reduced reward: this generally occurs if there is evidence that the finder has concealed his find.
        The one major change has been that the Treasure Trove Reviewing Committee was set up in 1977 with the responsibility of advising the Secretary of State on valuations. This was done to answer criticisms that the British Museum was valuing objects which it wished to acquire. The museum which wishes to acquire Treasure Trove has to find the money to pay the reward out of its own resources: most people incorrectly assume that the Government finds the money for Treasure Trove rewards. The museum pays the Department of National Heritage (which took over responsibility for Treasure Trove from the Treasury in 1993) which then passes the reward on to the finder. One result is that many finds are not acquired because museums are unable to raise the money. For example, the British Museum had to mount a fund-raising campaign in order to acquire the Hoxne Treasure intact, as this was valued at #1.75 million.
        Two recent cases have shown the anomalies of the present system of rewards very clearly. The first concerns a hoard of Iron Age gold coins from Donhead St Mary which was declared Treasure Trove in 1987.⁶ The finder was convicted under 1979 Ancient Monuments Act for metal-detecting on a scheduled site and fined #100. The hoard was subsequently valued at #5,210 and the Treasury decided to reduce the reward to #2,000 in view of the fact that the finder had been convicted for searching on a scheduled monument. Although no museum wished to see the finder receive a reward of #2,000 after he had been convicted of breaking the law, it then became clear that if no museum acquired it the Treasury would return the whole hoard to the finder. In the end therefore the British Museum decided to acquire the hoard as the lesser of two evils. The landowner was aggrieved that he was not entitled to any payment.
        The second case concerns a hoard of 282 silver coins of the 17th century found in a house at Burton Overy in Leicestershire, and valued by the Treasure Trove Reviewing Committee in February 1995 at #9,675. The coins were found by electrician while working in the loft of the house: he then handed them to the owner of the house who reported them to the local museum. The hoard was duly declared Treasure Trove at inquest in December 1994 and the finder was named as the electrician. Leicestershire Museums Services have acquired the whole hoard and the owner of the house was not eligible for a reward, although common sense would suggest that he should have been.
        The preparation of a new Bill to reform Treasure Trove has provided an opportunity to take a fresh look at the whole issue of rewards. Because the circumstances of each find is different it has been felt that it would not be desirable to determine in the face of the Bill how rewards should be paid in every case. However, the Bill will state that landowners and occupiers will for the first time be eligible for rewards, alongside finders. The Bill will further provide that the question of rewards will be looked at in detail in a separate Code of Practice to be drawn up in consultation with interested parties, including representatives of finders and landowners. The Government minister, Baroness Trumpington, spelt out the Government's policy on rewards during a debate on Lord Perth's Treasure Bill in 1994: 'I cannot emphasize too strongly that our paramount objective is to encourage the reporting of finds. We clearly need to ensure that adequate incentives to finders are preserved under any new arrangements. At the same time we want to discourage wrong behaviour'⁷. This statement was intended to signal that the Government would like to continue to pay the full reward to the finder in those cases where the finder had permission from the owner or occupier of the land. However, the Bill will also give the Secretary of State greater flexibility in paying rewards in cases where the finder has not received permission from the owner or the occupier of the land than at present.

The Treasure Bill
        The Treasure Bill, which has been drawn up to replace the medieval law of Treasure Trove with something more suited to present-day conditions, contains the following main provisions:

All objects other than coins will be Treasure provided that they contain at least 5% by weight of gold or silver and are at least 300 years old.
As far as coins are concerned, the Bill will provide that all hoards of coins that are over 300 years old shall be Treasure, except those that contain fewer than ten base-metal coins. Single coins will not be Treasure.
It will not matter whether objects have been buried in the ground with the intention of recovery, or buried in a grave or simply lost: provided they qualify under (1) or (2) above, all such objects will be Treasure.
In addition all objects found together with items that are Treasure will be deemed to be Treasure, whatever they are made of.
The Secretary of State, with the approval of Parliament, will be able to designate additional classes of object as Treasure; he will also be able to remove classes of object from the definition of Treasure.
The Secretary of State shall have the power to disclaim ownership of finds that have been submitted as potential Treasure if it is clear that no museum wishes to acquire them. Such a provision could substantially reduce the number of Treasure inquests and thus speed up the administration of Treasure.
All finds that are likely to be Treasure must be reported to coroners within two weeks.
Coroners will be required to make reasonable efforts to ensure that occupiers and landowners are informed of any reported finds of Treasure on their land.
Coroners will no longer need to summon juries to inquests on Treasure, thus speeding the process up considerably.
Rewards will be dealt with in a separate Code of Practice to be drawn up after consultation with interested parties. The Bill will not come into force until the Code of Practice has been approved by both Houses of Parliament.
The Bill will extend to England, Wales and Northern Ireland.

The main anomalies of the present law

        Since Treasure Trove only includes objects that contain a substantial proportion of gold or silver it affords no protection at all to the great majority of archaeological finds, even though they may be of great historical or cultural value. Despite Lord Denning's judgement that objects had to contain 'substantial' amounts of gold or silver an object in order to qualify as Treasure Trove, each find that has occurred since then has been dealt with differently.
        Several hoards containing gold and silver objects of varying degrees of fineness have been split into portions that have been declared Treasure Trove and portions that have not. Hoards of Roman coins of the mid-third century ad, which are very common in Britain, pose a particular problem under the present Treasure Trove system. This is because they typically contain coins made over a period of up to a hundred years which consist of ever-decreasing amounts of silver. Since Lord Denning's judgement in 1981 coroners' inquests have taken widely differing views on how to deal with coin hoards of this period.⁸
        Even more serious is the fact that many entire hoards of Roman coins are currently not Treasure Trove because they are made of very base silver and, since there is no requirement to report them, many are perfectly legally sold and dispersed before they can be recorded. Thus the information they contain is lost for ever. The hoard of 47,912 base silver radiates of the period ad 253-90 from Normanby (Lincs), discovered in 1985, was the second largest hoard of coins ever to have been found in this country and several members of staff at the British Museum spent over a year cleaning and studying it. At an inquest at Lincoln on 19 May 1987 it was declared not to be Treasure Trove on the grounds that the silver content of the coins was too low and the whole hoard was sold the next day to a dealer. As a result the British Museum was unable to acquire many of the coins from the hoard that it wished to add to its collection. This was a particular loss as the study of the Normanby hoard has formed the basis of our understanding of the coinage of this period.⁹
        In fact, however, the Normanby hoard was only the largest of a series of more than twenty major coin hoards of this period which have been found in the last fifteen years and which have not been Treasure Trove. In 1993 alone, 21 new Roman coin hoards were been reported, varying in size from eight to over 7,000 coins. Twelve of these were not Treasure Trove and several were broken up before any record can be made. A case in point is a hoard of about 1,500 bronze coins of the late fourth century AD from Amersham in Buckinghamshire: this hoard was found in 1986 but was perfectly legally dispersed shortly afterwards and it has only come to light now because the finder's mother wrote an account of its discovery in the magazine Take a Break; no full record of it will ever be made.¹⁰
        Another difficulty concerns hoards of coins that have been scattered by the plough. Many scattered hoards of coins are nowadays recovered by metal detectorists; often there is no trace of a container, either because it was made of a material which has perished or because it was made of pottery which the metal detector did not locate. There have been a number of cases recently where such hoards have been found not to be Treasure Trove because the inquest decided that it was unclear that they had been deliberately buried.¹¹
        The Treasure Bill states that all coin hoards that are over 300 years old shall be Treasure, except those that contain fewer than ten base-metal coins.
        In addition to the requirement that an object should be made substantially of gold or silver, it is also necessary to establish that its original owner concealed it with the intention of recovering it later, and did not simply lose or abandon it. It is absurd to think that we can today understand the motives that led their owners to bury objects such as gold torcs several thousand years ago and yet this is a question that regularly arises at inquests. In any case this is a completely irrelevant consideration when deciding whether antiquities should be preserved for the nation. Thus, for example, the Bronze Age gold torc found at Monkton Deverill in Wiltshire in 1991 was the subject of a long and costly process of litigation in order to decide this very point. Under the Treasure Bill this difficulty would no longer arise, since all objects other than coins that have a precious-metal content of at least 5% would be Treasure, however they came to be placed in the ground.
        What is more, single objects, however important they might be, are seldom declared Treasure Trove because it is generally considered that they are more likely to have been lost than deliberately buried. A well-known example is the Middleham jewel, discovered in Yorkshire in 1985, and described as 'the most important piece of medieval jewellery discovered in England in this century'.¹² It was not Treasure Trove since it could not be shown to have been deliberately buried with the intention of recovery. It was subsequently purchased by the Yorkshire Museum for #2,500,000.
        In the same way, objects buried in graves do not at present qualify as Treasure Trove, since they too cannot be said to have been buried with the intention of recovery. Thus the Sutton Hoo ship burial, the most important find of early Anglo-Saxon artefacts ever made in this country, was not Treasure Trove, and it was only possible for the British Museum to acquire this unique find for the nation through the generosity of the landowner.¹³
        Another anomaly of the current system is that objects which are made of base metal or of some other material receive no legal protection at all, even if they are found in association with objects that are Treasure Trove. Thus the pots in which coin hoards are found are not declared Treasure Trove, even though they may be of considerable archaeological importance. Under the Treasure Bill objects found in clear archaeological association with treasure would also be protected, while penalties are introduced for failure to report suspected treasure within 14 days.

Problems of enforcement
        In recent years the law of Treasure Trove has proved to be notoriously difficult to enforce. The problems encountered can best be illustrated with reference to two different cases, both connected with finds of Iron Age coins.
        The first case arose from the large find of Iron Age coins found at the site of a Romano-Celtic temple at Wanborough in Surrey in the mid 1980s.¹⁴ An initial discovery of Iron Age coins from this site was reported to the Coroner and declared Treasure Trove at an inquest in 1984. Unfortunately, the findspot was revealed at the inquest and this encouraged unscrupulous individuals to search on the site, without permission and often at night, and cause considerable damage. It will never be known exactly how many coins were found, because most of them were immediately dispersed in trade, but estimates suggest that the total was probably more than 9,000, and possibly as high as 20,000. This would have made it the biggest find of its kind from this country by a very considerable margin.
        The police recovered several hundred coins from individuals at the site, and they were declared Treasure Trove at a second inquest. One of the individuals from whom coins were recovered was Mr Hancock, who was subsequently convicted of theft of Crown property. He was then acquitted at the Court of Appeal (in 1990) because the higher court found that the trial judge had misdirected the jury when he advised them that the fact that the coins had been declared Treasure Trove at an inquest meant that their status as Crown property was sufficiently well established to stand up to a criminal prosecution.¹⁵ The problem essentially hinges on the differing burdens of proof required at Coroners' inquests and in criminal prosecutions. A jury at a Coroner's inquest simply has to decide whether a find is Treasure Trove or not on the balance of probabilities: in other words it has to decide whether it was more likely that a particular find was deliberately buried with the intention of recovery or came to be in the ground for some other reason. On the other hand, an individual can only be convicted of a criminal offence if the jury is convinced beyond reasonable doubt that he must have committed the crime. In the nature of things it will always be very difficult, if not impossible, to prove beyond reasonable doubt how a particular object came to enter the ground several hundred or thousand years ago. The lesson of this case, therefore seems to be that it will always be very difficult to obtain a conviction for theft of Treasure Trove under the current law.
        The second case has shown very clearly the limitations of the law of Treasure Trove once objects have been removed from the soil and lost their provenance. The inquest, held at the West London Coroner's Court on 3-4 November 1994, concerned three groups of Iron Age coins which had been detained by Customs at Heathrow Airport in July 1993 from a dealer who was attempting to export them to the United States. There was no evidence as to where the coins were actually found, beyond that provided by the coins themselves: they were all of types that are only found in England, and two of the three groups could be attributed to East Anglia. It thus provided an important test of whether it would be possible to recover objects once they had entered the trade.
        The British Museum gave as its opinion that the three groups (of 594 silver coins made by the Iceni in East Anglia, 56 gold coins of the Iceni and 7 gold coins of the ruler Verica) were parts or all of three hoards which had not been to Inquest. Counsel for the dealer argued that he had bought the coins from various other dealers and they represented 'stock'; he also argued that even if the coins were found together they might have been found outside the UK and anyway they were more likely to be votive offerings or burial deposits than hoards deposited with the intention of recovery. The jury found that the coins were not Treasure Trove. The lesson of this case is that it seems unlikely that a Treasure Trove verdict would be obtained in any other cases where it is suspected that an undeclared find is being sold in the UK or exported even through experts could be sure that the objects were found in this country. Furthermore, even if a verdict of Treasure Trove had been given, it is doubtful whether this would have withstood the higher standards of proof required in any subsequent criminal action for theft or handling stolen property. Perhaps the most damaging aspect of the case is that this message has not gone unnoticed and is likely to be exploited by unscrupulous individuals.
        The dealer's solicitor concluded: 'Treasure trove is an anachronistic law being enforced on inadequate evidence...I hope this important inquest leads to a radical revision of the treasure trove law'. Another report on the case was headed 'Treasure Trove: time for a change'.¹⁷ The Treasure Bill would have dealt with most, although not all, of the problems thrown up by this case: it would make the question of whether a particular object was Treasure or not a straightforward matter of fact in almost all cases; it would also cope with the 'votive deposit' argument and it would help with the standard of proof required.
        It is of course always difficult to prove the provenance of objects once they have been unearthed. More depressingly, even when there is very strong evidence, juries often refuse to convict because, it has been said, they tend not to regard the removal of objects from other people's land as a serious offence.

The campaign for reform
        What has really transformed the picture in the last twenty-five years or so has been the widespread use of metal detectors: this has resulted in an enormous increase in the number of antiquities being found and the vast majority of these are not covered by the law of Treasure Trove. A recent survey by the Council for British Archaeology has attempted to quantify the precise number of objects being found.¹⁸ It is very difficult to be precise, and only a few metal detectorists co-operated, but it is estimated that several hundred thousand archaeological objects are being found each year, maybe around 400,000. Of these, only a very small percentage, no more than about 5-10%, are reported to museums.
        The movement for reform started in earnest after the war. In the late 1970s the Council for British Archaeology sponsored a Bill to reform the law which was introduced into the Lords by Lord Abinger in 1979 and again in 1981-2. However, it did not have Government support and it failed in the Commons. Towards the end of the 1980s, the Surrey Archaeological Society, working with Lord Perth and the British Museum began to plan a new Bill, which was drafted after extensive consultation. One boost to the campaign for reform was the creation of the Department of National Heritage in 1992 and its assumption of responsibility for Treasure Trove from the Treasury a year later, since for the first time Government policy on archaeological and portable antiquities was all dealt with in one place.
        The Treasure Bill went through many successive drafts before it was introduced into Parliament and the result was a compromise that is acceptable to all parties, so far as possible, and has been supported by all the main organisations representing archaeologists, museums, landowners and dealers. The final version of the Bill that emerged was much less ambitious than earlier drafts: in order to obtain any measure of Government support it had to be based on the premise that it will not require additional resources. The one major group to oppose the Bill was the National Council for Metal Detecting. This, it seems, is not so much because the Bill contains anything harmful to their interests - it does not - but because of a long history of distrust between archaeologists and metal detectorists.
        In March 1994 Lord Perth introduced the Treasure Bill as a Private Member's Bill in the House of Lords. The Bill passed through the Lords with the support of those Peers who took part in the Second Reading Debate, including strong backing from the Labour and Liberal Democratic spokesmen. This helped to overcome initial doubts on the part of the Government and it subsequently introduced extensive drafting amendments. However, the Bill failed in the Commons, where it did not receive any time for debate. After a gap of eighteen months, a slightly amended version of Lord Perth's Bill was been reintroduced into Parliament by Sir Anthony Grant, MP in December 1995 and it now has a real chance of success. A number of amendments have been made to answer the concerns expressed by the metal detectorists and as a result it is hoped that they will be persuaded that this Bill does not pose a threat to them.
        The Government has announced that it sees reform of Treasure Trove as one part of a two-fold approach to this problem. The other initiative is to publish a Discussion Document on Portable Antiquities which was issued in February 1996. This paper makes a distinction between two aspects of the problem: the public acquisition of finds, which the Treasure Bill addresses, and the recording of finds, which is what the proposals on portable antiquities are intended to tackle. The Paper notes that perhaps as many as 400,000 objects of archaeological interest are discovered every year in England and Wales and that at present only a few of these are recorded.¹⁹ The Paper confirms that the Government accepts that there is an urgent need for action to improve the arrangements for the recording of such objects and it will discuss the relative merits of voluntary and compulsory schemes. The Paper concludes by stating that the Government's provisional view is that a voluntary Code of Practice, combined with limited reform of the law of Treasure Trove, represents the best and most practicable way forward and it will invite comments from interested parties.
        Perhaps the most encouraging sign for the future lies in the fact that there is a growing consensus amongst both archaeologists and metal detectorists in favour of co-operation. Andrew Palmer's recently published The Metal Detector Book prominently displays the following message on the back cover: 'This book promotes responsible behaviour among detectorists and advocates the recording and reporting of all finds'.²⁰ Equally, archaeologists are increasingly willing to acknowledge the contribution played by metal detectorists in bringing archaeological finds to light and actively to seek their co-operation in excavations. Although breaking down the distrust that still exists on both sides will take time, it does now seem that this more likely to happen than not. The main beneficiary of this process will be our knowledge of the past as an increasing proportion of the hundreds of thousands of coins and other metal detected objects that are discovered each year receive proper archaeological recording.

        (A fuller version of this paper entitled 'Treasure Trove and the case for reform' has been published in Art, Antiquity and Law I, 1 February 1996, pp. 11-26.)

Roger Bland

Practical information
Postal address and telephone/fax numbers:

British Museum
Department of Coins and Medals
Great Russell Street
London WC1B 3DG
Telephone + 44 171 323 8404
Fax + 44 171 343 8171
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¹ The classic work is Sir George Hill, Treasure Trove in Law and Practice (Oxford, 1936), but this is now nearly sixty years old. The current position has been authoritatively described by Norman Palmer, 'Treasure Trove and Title to Discovered Antiquities', International Journal of Cultural Property 2, 2 (1993), 275-318.
² Henry de Bracton, De legibus et consuetudinibus Angliae: quoted in Hill, op. cit. n. 1, pp. 191-3.
³ Attorney-General of the Duchy of Lancaster v G E Overton (Farms) Ltd. [1982] 1 All ER 524-31.
⁴ The Treasure Trove Reviewing Committee. Annual Report, 1994-95 (Department of National Heritage 1995) lists 27 cases of Treasure Trove dealt with in the year 1994-95.
⁵ Hill, op. cit. n. 1, p. 240.
⁶ British Archaeological News January 1987, p. 73; id., February 1987, p. 3; id., March 1987, pp. 10-11; id., April 1987.
⁷ House of Lords Debates 23 March 1994, vol. 553, col. 733.
⁸ In two cases (Stevenage and Chalfont St Peter) all coins down to and including the reign of Trajan Decius (ad 249-51), which have an average fineness of 40-50%, were declared Treasure Trove. In another two cases (Oliver's Orchard, Colchester and Burwell Farm, Barton) all coins of the Central Empire down to and including the joint reign of Valerian and Gallienus (ad 253-60) and all early coins of Postumus (ad 260-8) (coins with a minimum average silver fineness of 11%) were declared Treasure Trove. In the case of a hoard of 4 silver denarii and 407 silver and base silver radiates to ad 276 from Drax (North Yorkshire), the inquest drew a dividing line somewhere between the reigns of Maximinus (ad 235-8) and of Trebonianus Gallus (ad 251-3), as the hoard contained no coins minted during this period. On the other hand, the following hoards which contained a few coins made later than 268 were declared Treasure Trove in their entirety: Wareham (8 bronze coins, 151 denarii and 1,396 radiates to ad 271), Bassaleg (1 denarius and 904 radiates to ad 271) and Wortley (11 denarii and 70 radiates to ad 271). But the hoard from Caerleon, which contained 51 base silver radiates to ad 271, was not declared Treasure Trove, while no inquest was held on the hoard from Fineshade (Northants), which contained 89 denarii and 173 radiates to ad 261.
⁹ R F Bland and A M Burnett (eds.), The Normanby Hoard and other Roman Coin hoards, Coin Hoards from Roman Britain VIII, London, 1988, pp. 114-215.
¹⁰ Take a Break 15 January 1994. When contacted after the publication of this article the finder told the author that he had retained just seven coins from the hoard which he allowed the British Museum to record.
¹¹ One case concerns a hoard of 26 silver pennies of reign of King Stephen (1135-54) found at Portsdown Hill in Hampshire. The inquest was held on 23 March 1995 and decided that the find was not Treasure Trove. In an account he has written, the finder stated 'my view was that as we had found no container, or contemporary pot shards, the coins could have come from a lost purse dropped by a knight on horseback' (David Lodder, 'Portsdown Hill King Stephen hoard', Treasure Hunting June 1995, pp. 32-5). When the jury gave its verdict Mr Lodder records 'there seemed to be a look of almost disbelief on the face of the Coroner'. As a consequence, the coins were sold at auction by Buckland, Dix and Wood (London), 28 June 1995, lots 171-91 and no museum acquired any of them.
¹² John Cherry, The Middleham Jewel and Ring, The Yorkshire Museum, York, 1994.
¹³ For a discussion of the issues involved at the Treasure inquest see P V Hill (et al.), 'The Treasure Trove inquest' in R L S Bruce-Mitford, The Sutton Hoo Ship-Burial, I, British Museum Publications, London, 1975, pp. 718-31.
¹⁴ M G O'Connell and Joanna Bird, 'The Roman temple at Wanborough, excavation 1985-1986', Surrey Archaeological Collections 82 (1994), pp. 1-168.
¹⁵ Alan Ward, 'Treasure Trove and the law of theft', International Journal of Cultural Property, 1992, pp. 195ff and Palmer, op. cit. n. 1, pp. 288-89.
¹⁶ Quoted in 'A gift to the gods' (unsigned) published in The Searcher January 1995, p. 8 and Treasure Hunting January 1995, p. 10.
¹⁷ Coin News December 1994, p. 19.
¹⁸ Colin Dobinson and Simon Denison, Metal Detecting and Archaeology in England, English Heritage/Council for British Archaeology 1995, pp. 10-11 and 81.
¹⁹ One exception is Norfolk where a voluntary agreement between metal detectorists and Norwich Museum has been running for several years. Around 20,000 objects a year are recorded and the equivalent of three members of staff are employed on this.
²⁰ Seaby, London, 1995. It is also perhaps significant that this is the first book on metal detecting to have been published in this country by a mainstream commercial publisher.