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 for libelling her, and in January 1822 delivered his speech on the Durham clergy, the finest specimen of his powers of sarcasm and invective, in defence of a printer accused of libelling them in some reflections on their conduct on the queen's death. Brougham had now lost his official rank, and owing to the king's personal spite against him he was debarred from receiving a patent of precedence. This persecution did him no harm, for in one year he made 7,000l. in a stuff gown.

When in 1822 the death of Lord Londonderry made it seem possible that the whigs might come into office. Lord Grey proposed that, should the administration be changed, Brougham should be 'really and effectively if not nominally' leader of the house and a member of the government (Life and Times, ii. 453). This and other negotiations were brought to an end when the king accepted Canning as foreign secretary. With Canning Brougham was far more at one as regards foreign affairs than he had been with Castlereagh. Nevertheless, on 23 April 1823 he made a violent attack upon him for refusing to press the catholic claims. Canning declared he spoke falsely, and a motion was made that both the disputants should be committed to the custody of the serjeant-at-arms. The dispute, however, was at last composed (Parl. Deb. new series, viii. 1089-1102). On 3 Feb. 1824 Brougham made a remarkable speech urging the government to resist the dictation of the Holy Alliance in Europe, dwelling on the iniquity of the French invasion of Spain and the tyranny of the Austrians in Italy. This speech, which excelled all his former political efforts in bitterness of sarcasm and severity of attack, was received with immense applause (ib. x. 53-70; Life of Canning, i. 296). On the news of the condemnation and death of the missionary Smith, he proposed a vote of censure on the government of Demerara, and his speech of 10 June forms an epoch in the history of the abolition of slavery {Speeches, ii. 42-128). In the course of this session he was violently assaulted in the lobby of the house by a lunatic named Gourley. Having been elected lord rector of Glasgow University in 1825, Brougham on his way thither visited Edinburgh on 5 April. A banquet was given in his honour, at which he made several violent and extravagant speeches (''Speeches. . . on 5 April 1825;, Correspondence'', 42). When in 1827 Canning succeeded Lord Liverpool, Brougham, feeling himself generally in accord with the new minister's principles, left the opposition benches and on 1 May took his place on the ministerial side of the house. He brought over with him a body of moderate whigs, who thus for a time separated themselves from Grey. Canning had no wish to be overridden, and offered Brougham the post of lord chief baron, which would have removed him from the house. Brougham, however, objected to being 'shelved,' and refused the offer. He now at last obtained a patent of precedence, and on going circuit was greeted with much rejoicing by his brother barristers, among whom he was popular. His reappearance in 'silk' brought him a large number of cases. This influx, however, did not last long. He was 'deficient in nisi prius tact,' was apt to treat juries with impatience, and seemed to think more of displaying his own powers than of getting verdicts for his clients. During the short time that he continued at the bar his practice declined (Law Magazine, new series, l. 177).

As early as 8 May 1816 Brougham first attempted an improvement in the law; in bringing forward a bill for securing the liberty of the press, he proposed an amendment of the law of libel. On 7 Feb. 1828 he brought forward a great scheme of law reform. In a speech of six hours' length he dealt exhaustively with the anomalies and defects in the law of real property and in proceedings at common law. His extraordinary effort bore ample fruit, for it caused a vast improvement in our system of common law procedure, and overthrew the cumbrous and antiquated machinery of fines and recoveries. The accession of the Duke of Wellington to office in the January of this year sent Brougham back to the opposition; for while, in common with his party, he cordially upheld the duke and Peel in carrying the Catholic Emancipation Bill of 1829, he was not prepared to accord them his general support. Brougham in 1830 vacated his seat for Winchelsea, the borough of the earl of Darlington (created Marquis of Cleveland in 1827), and accepted the offer of the Duke of Devonshire to return him for Knaresborough. At the same time he by no means relished sitting for a close constituency: it consorted ill with his desire to be known as a popular politician, and it kept him back from taking part in the movement for parliamentary reform. While sitting for Winchelsea, he had made unsuccessful attempts in 1818, 1820, and 1826 to gain a seat for Westmoreland. Now, however, a speech he made on 13 July, on bringing forward a motion against slavery, gained him an invitation to stand for Yorkshire. He was triumphantly elected, and in the parliament of 1830 took his seat