Then William Steel, one of the accomplices in both the murders from beginning to end, was sworn, who deposed that he was sent for to the widow Payne’s on Sunday, the 14th of February; that Jackson, Little Sam, one Kelly, and two men more, and Jackson’s wife, were there when he came, which was about two o’clock in the afternoon, and soon afterwards Little Harry, Carter, Edmund Richards, John Race, the last witness, and Carter’s wife came thither; he said he did not know how Carter or Jackson came to be there, but the widow Payne’s son came and called him out, and said he must go to the Castle, his mother’s, for there were two men come to swear against the shepherd; that when he came in he found the two strangers, Galley and Chater, and Jackson, Carter, Richards, and some others; and that they were in general sober, but they sat drinking together about two hours; that Jackson took Chater out of the house to examine him about Dimer; and after they had been out some time, Galley went out to them, but soon returned, and said Jackson had knocked him down; the witness saw he was bloody all down the left cheek; that Jackson was not in the room when Galley came in, but came in with Carter a little time afterwards; that then Galley, addressing himself to Jackson, said he did not know any occasion Jackson had to use him in that manner, and that he should remember it, and took down his name in Jackson’s presence. Galley likewise said he was an officer, and shewed his deputation to the people that were in the room.

This witness, continuing his deposition, said Galley and Chater began to be very uneasy, and wanted to be going, but that the prisoners Jackson and Carter, and the rest of them that were smugglers, persuaded them to stay, and be pacified, and all things should be set right; and the company continued drinking till Galley and Chater were quite fuddled, and were carried into a little inner room to sleep; this was about four or five o’clock, and they continued in the little room two or three hours; the rest of the company sat drinking all the while, consulting what to do with Galley and Chater. The prisoners Jackson and Carter, and Little Sam, Little Harry, Richards, and the witness were at the consultation. It was proposed to put them (Galley and Chater) out of the way, because they should not appear against the shepherd, meaning Dimer; after which it was proposed to throw them into the well in the horse pasture, about a quarter of a mile from Rowland’s Castle, but that it was thought not convenient to put them into a well so near, for fear of discovery.

Here the question was particularly asked Steel, the witness, which of them it was that proposed the murdering them directly and flinging them afterwards down the well; to which he replied, he believed he might.

After this it was next proposed to join and each man to allow them threepence a week, and to keep them in some secret place till they saw what became of Dimer, and as Dimer was served, so these two people (Chater and Galley) were to be served. This was talked of while Chater and Galley were asleep and there was no other proposal made as he heard at that time: but while they were talking of these things, the wives of Carter and Jackson said it was no matter what became of them (Galley and Chater), or what was to be done with them; they ought to be hanged, for they were come to ruin them, meaning the smugglers. He then said that about seven o’clock Carter and Jackson went into the inner room and waked Galley and Chater, and brought them out of the room very bloody and very drunk; he did not see what passed in the room, but was sure they did not go in so bloody, and he believed Jackson and Carter had kicked and spurred them, for they had put on their boots and spurs; that then Jackson and Carter brought them (Galley and Chater) out into the kitchen; and took them through to the street door all very bloody, when they set Galley the officer upon a brown or black horse and Chater up behind him; that Jackson, Carter and Richards put them on horseback, and tied their legs under the horse’s belly and also their legs together; then they tied a line to the bridle, and he (the witness) got upon a grey horse and led them along; that just after they had turned round the corner about 70 or 80 yards from the house, Jackson cried out “Whip them, lick the dogs, cut them.” It was then dark, and the company whipped and lashed them with their horse-whips, some on one side and some on the other with great violence, on the face and head and other parts of the body, and continued doing so while they rode about half a mile to a place called Woodash, or Wood’s Ashes; that there they alighted and Little Sam gave all the company a dram or two, but none to Galley and Chater; that as they were mounted again Jackson and Carter cried out, “D—n them, lick them, whip them,” and they were whipped as before for about a mile further, and then they fell down under the horse’s belly, with their heads upon the ground and their legs over the saddle; upon which Jackson and Carter and some of the others of the gang dismounted and untied Galley and Chater, and immediately set them up again, and their legs were tied together in the same posture, and the company went on whipping them as before till they came to a place called Dean,[7] which was about half a mile further. They were beat very much, and in the judgment of the witness, it was almost impossible they should sit their horses; that when they came to Dean somebody of the company pulled out a pistol and said he would shoot them (Galley and Chater) through the head, if they made any noise whilst they went through the village. He could not tell who it was that threatened to shoot them, but apprehends it was done for fear the people in the village should hear them. They went on at a foot pace, and after they got through Dean they were whipped again as before; and when they came near a place called Idsworth, they fell down again under the horse’s belly, and then some of the company loosed them, and set up the officer (Galley) behind him (the witness), and Chater behind Little Sam, and in this manner they proceeded towards Lady Holt Park, which is near three miles from Idsworth, whipping Galley and Chater as before. But the lashes of their whips falling upon the witness as he sat before Galley, he (the witness) could not bear the strokes, and therefore he cried out, and then they left off whipping Galley in that manner.

This witness further said that Galley sat upon the horse till they got to Lady Holt Park, and then being faint and tired with riding, he got down; and then Carter and Jackson took him, one by the arms and the other by the legs, carried him towards a well called Harris’s Well by the side of Lady Holt Park; and then Jackson said to Carter “We’ll throw him in the well,” to which Carter replied “With all my heart;” and Galley seemed very indifferent what they did with him; but some of the company saying ’twas a pity to throw him into the well, Jackson and Carter set him up behind the witness again and Chater was still behind Little Sam. They went on in this manner till they came to go down a hill, when Galley was faint and tired, and could not ride any further and got down there; upon which Carter and Jackson laid him on a horse before Edmund Richards, with his belly upon the pommel of the saddle. They laid him across the horse because he was so bad that they could not contrive to carry him in any other manner, and they carried him so for about a mile and a half from the well; that then Richards, being tired of holding him, let him down by the side of the horse; and Carter and Jackson put him upon the grey horse that he (the witness) was upon, and the witness got off. They set him up, his legs across the saddle and his body lay over the horse’s mane; that in this posture Jackson held him on and he did not remember that anybody else held him at that time; that they went on for about half a mile in this manner, Galley crying out all the time “Barbarous usage! barbarous usage! for God’s sake shoot me through the head or through the body.” He (the witness) thought Jackson was at this time pinching him by the private parts, for there were no blows given when he cried so; that Chater was still with the company behind Little Sam, and they went on for about two miles and a half further, the company holding Galley by turns on the horse until they came to a dirty lane, at which place Carter and Jackson rode forwards, and bid the rest of the company stop at the swing gate beyond the water till they should return. Jackson and Carter left them here and went to see for a place proper for taking care of Chater and Galley, but soon came to them again at the swing gate and told them that the man of the house whither they went was ill and that they could not go thither, by which he understood that they had been in the neighbourhood to get entertainment. It was then proposed to go forward to one Scardefield’s, and Little Harry tied Galley with a cord and got up on horseback behind him in order to hold him up on the horse, and they went on till they came to a gravelly knap in the road at which place Galley cried out “I shall fall! I shall fall!” whereupon Little Harry said, “D—n you, then fall,” and gave him a push, and Galley fell down and gave a spirt, and never spoke a word more. He (the witness) believed his neck was broke by the fall; that they laid him across the horse again and went away for Rake to the sign of the Red Lion, which was kept by William Scardefield; that Chater was behind Little Sam and was carried to Scardefield’s house and was very bloody when they came to Scardefield’s; that Jackson and Little Harry went from Scardefield’s with Chater about three o’clock in the morning and Jackson afterwards returned to Scardefield’s and said he had left Chater at Old Mills’s, and that Little Harry was left to look after him that he might not escape. This was Monday, the 15th of February, and they remained all that day at Scardefield’s; that the prisoner Richard Mills the younger was there on that day, and upon hearing from Jackson and Carter that they had passed by a precipice thirty feet deep when they had Chater with them, he said, “If I had been there I would have called a council of war on the spot, and he (Chater) should have gone no further,” or to that effect.

That two or three days afterwards the company met at Scardefield’s again, to consult what to do with Chater; that the prisoners John Race, Carter and Jackson, the prisoner Richard Mills the younger (a son of the prisoner Richard Mills the elder), Thomas Willis, John Mills (another son of old Mills), the prisoners Tapner, Cobby, Hammond, and Thomas Stringer, Edmund Richards, and Daniel Perryer, and he (the witness) were consulting what to do with Chater, and John Mills[8] proposed to take him out, and load a gun, and tie a string to the trigger, and place him (Chater) against the gun, and that they should all of them pull the string, to involve every one of them in the same degree of guilt; but this proposal was not agreed to. Then Jackson and Carter proposed to carry him back to the well near Lady Holt Park, and to murder him there, which was agreed to by all the company; but Richard Mills the younger and John Mills said they could not go with them to the well, because they had no horses; and as it was in their (the other persons’) way home, they might do it as well without them; and so it was concluded to murder Chater, and then throw him into the well.

As soon as it was agreed amongst them to murder Chater and fling him down the well, they went away for Rake to the house of the prisoner Richard Mills the elder, and found Chater in a back skilling or out-house, run up at the back of Mills’s house, a place they usually put turf in; where they found him chained with an iron chain to a beam in the skilling; that Chater was bloody about the head, and had a cut upon one of his eyes, so that he could not see with it; that the prisoner Richard Mills the elder was at home, and fetched out bread and cheese for them to eat, and gave them drink; that the house is a private house, no alehouse; that they all of them went to and again, between the house and the skilling, and that the prisoner Richard Mills the elder was at home all the while; that the prisoner Tapner bid Chater go to prayers, and pulled out a large clasp knife, and swore he would be his butcher; and while Chater was at prayers, he cut him across the eyes and nose, and down his forehead, so that he bled to a great degree. He was ordered by some others of the company to say his prayers, for they were come to kill him, and kill him they would; and some of the company were then in the skilling, and the rest of them were in the house, but no one interposed to save his life; that he (the witness) was in the skilling when Chater was advised to say his prayers and was cut, and that Chater was chained by the leg at the time.

When they had kept him there as long as they thought fit, someone unlocked the chain and set him on horseback, and Race, Richards, Little Harry, Little Sam, the prisoners Tapner, Stringer; the prisoners Cobby, Hammond and Perryer; the prisoners Jackson, Carter, and the witness, set out with him to Lady Holt Park, to carry him down to the well; that when they came to a place called Harting, Richards, Little Harry and Little Sam went back; and when the rest came to the white gate by Lady Holt Park, Carter and Jackson left them, but first told them they must keep along a little further, and they could not miss the well, for there were white pales; that it was about 200 yards further, some pales on the right hand of it, and that there were pales round the well. They went on, found the well by the direction given them, and carried Chater with them; that then Tapner, Hammond, Stringer and Cobby got off their horses, and Tapner pulled a cord out of his pocket, and put it about Chater’s neck, and led him towards the well. Chater seeing two or three pales down said he could get through, but Tapner said, “No, you shall get over,” and he did so with the rope about his neck; they then put him into the well and hanged him, winding the rope round the rails, and his body hung down in the mouth of the well for about a quarter of an hour; and then Stringer took hold of his legs to pull him aside, and let his head fall first into the well, and Tapner let the rope go, and down fell the body into the well head foremost; that they stayed there for some time, and one of the company said he thought he heard him breathe or groan; on this they listened, and being of the same opinion, went to one Combleach, a gardener, who was in bed, and asked him to lend them a ladder and a rope, for one of their company had fallen down the well; which he readily did, not thinking, as the witness verily believed, any otherwise. They brought the ladder with them, but as it was a long one they could not get it down the well through the hole in the breach of the pales; when they all tried to raise it up and put it over the pales; but then, not having strength sufficient, they laid that part of their design aside; and looking about them found a gate post or two, which they threw into the well and then left him.

Steel, the witness, being cross-examined as to this, said, he never heard the prisoner say he would not have them murder the man, and added, that he was sure he must hear them talk of murdering while they were at his house.

John Race being called again, said: That after he had left the company at the widow Payne’s on the 14th of February, he met some of the same company and others, on the Wednesday evening following, being the 17th of February, at Scardefield’s, at Rake; that the prisoners, Richard Mills the younger, Carter, Jackson, Tapner, Cobby, and Hammond, with Steel, Richards, Little Sam, Daniel Perryer, John Mills and Thomas Willis, were there; and it was proposed at that meeting to murder Chater. He could not say who first made the proposal, but to the best of his knowledge, it was either Carter or Jackson, and it was agreed to by all the company; it was not then resolved how it was to be done, but only in general, that he was to be murdered and thrown into a well; that they went to the house of Richard Mills the elder, to join Little Harry, who was left there to take care of Chater, and found Chater chained by the leg upon some turf in a skilling, at the back side of the house; that the prisoner, Richard Mills the elder, was at home, and ordered his housekeeper to fetch bread and cheese, and some household beer, for any of them to eat and drink that would, and was sure that old Mills knew that they came for Chater; that Tapner and Cobby were very earnest to go and see Chater; and Tapner having his knife in his hand, said, “This knife shall be his butcher”; and thereupon the prisoner, Richard Mills the elder said, “Pray do not murder him here, but carry him somewhere else before you do it”; that Old Mills said this on seeing that Tapner had his knife in his hand, and hearing him declare it should be his (Chater’s) butcher; that they then went out into the skilling, and found Chater sitting upon some turf, and Tapner ordered him to say his prayers; whilst he was repeating the Lord’s Prayer, Tapner cut him over the face with his knife, and Cobby stood by kicking and damning him. This, too, was whilst the poor man was saying the Lord’s Prayer. That Chater asked them what was become of Galley, and they told him he was murdered, and that they were come to murder him. Upon which, Chater earnestly begged to live another day; that Cobby asked him his name, and whether he had not formerly done harvest-work at Selsey? To which he answered that his name was Daniel Chater, and that he had harvested at Selsey, and there he became acquainted with Dimer. That Little Harry unlocked the horse-lock that was on his (Chater’s) legs, and Tapner, Cobby and Stringer brought him out of the skilling, and set him upon Tapner’s mare, in order to carry him to the well, to be there murdered, and thrown in; and that all the company knew at that time what was to be done with him; that they rode about three miles towards the well, and sometimes whipped Chater with their horse-whips; and Tapner observing that he bled, said, “D—n his blood, if he bloods my saddle, I will whip him again.” When they came to Harting, Carter, Jackson, Richards, Little Sam, Little Harry, and Steel said, “We have done our parts, and you (meaning the rest of the company) shall do yours.” By which they meant, as he took it, that they had murdered Galley, and that the rest should murder Chater; and Richards, Little Sam and Little Harry, stopped there, and did not accompany them any further; the rest went on towards the well, but Carter and Jackson stopped before they came to it, and told them the well was a little further off, describing it to them, and told them they could not miss finding it, for it had some white pales by it, and that it was not above 200 yards further, and then Jackson and Carter left them; that he (the witness) and Tapner, Cobby, Stringer, Hammond, Perryer and Steel, came to the well, got off their horses, and took Chater off his horse, the witness was not certain which; and either Tapner or Cobby put a cord round his neck; that there was a “shord” in the pales about the well, and he heard Chater say he could get through there, but Cobby or Tapner said, “D—n you, no; you shall not, you shall get over”; that Tapner wound the cord round the pales, and Chater being put into the mouth of the well, hung by the neck for about a quarter of an hour, and then they loosened the rope, and turned the body, so that it fell into the well head foremost. They stayed there till some of the company thought they heard him breathe or groan, and then went to get a rope and a ladder at one Combleach’s, a gardener; that they met Jackson and Carter and told them what they had done, and that they were going to get a rope and a ladder, for Chater was not quite dead; that they all could not raise the ladder; so they got some old gate-posts and stones and threw them down upon him into the well, and then left him.