First, the history of judicial review was inextricably bound up with the development of remedies as opposed to the creation of new heads of review (Craig, 2000; Henderson, 1963; Jaffe and Henderson, 1956). The elaboration of grounds for review took place within, and was framed by, the evolution of adjectival law. Mandamus was transformed into a general tool for the remedying of administrative error. Lord Mansfield (R. v. Barker (1762) 3 Burr. 1265)gave the seminal rationalization of mandamus. It was, he said, introduced to prevent disorder from a failure of justice, and defect of police. There- fore it ought to be used ‘upon all occasions where the law has established no specific remedy, and where in justice and good government there ought to be one’. The evolution of certiorari into a generalized remedy capable of catching a variety of governmental errors occurred later.