Mr. Justice Stephen's summing-up was studiously fair and even subdued
in tone, but he directed the jury that even if Lord Salisbury's language was not true, it might still be of the nature of fair and reasonable comment on Mr. O'Brien's speech ; and it is on this account, we suppose, that a new trial is to be applied for on the ground of misdirection of the jury, Mr. O'Brien's counsel maintaining that if instead of advising he had discountenanced outrages on land-grabbers, Lord Salis- bury had grossly libelled him in proclaiming that he had advised them. No doubt the jury took into account that Mr. O'Brien's own frequent and great violence of language had prevented him from coming into Court with clean hands to complain of like violence in another.