The male castrato singer was a sine qua non of Italian opera seria in the heyday of the genre during the late seventeenth and first half of the eighteenth centuries. Many castrati came to London, encouraged by propitious economic conditions and the warm welcome extended to Italian opera by predominantly aristocratic audiences. The approbation of opera-goers was in marked contrast to the hostility and derision of critics, who satirised castrati in journalistic writings, on the stage and in cartoons as much for their vanity and cupidity as for their disproportionate and ungainly physique, arrogance and indeterminate sexual status.
With impresarios eager to exploit the public's appetite for foreign opera stars, castrati in particular found themselves able to demand salary packages of an order undreamed of by native singers; as early as 1708 Giuseppe Cassani's contract, negotiated by the opportunistic Christopher Rich, specified a salary of £300 in addition to travel costs and ‘Boarding & Lodging, for 8 Months, with alowance [sic] of one Bottle of Wine Every day'.Footnote 1 For the same season, the leading bass singer Richard Leveridge was paid just £100, and the average income for established actors in London was even lower.Footnote 2 The salary that attracted the great Nicolini to London for the 1708–9 season is not known, though Owen Swiney's proposed contract for the following three years allowed for 800 guineas per annum plus the proceeds of a benefit performance, thereby establishing a level of salary expectation that would quickly prove impossible to sustain.Footnote 3 Hard evidence in the form of singers' contracts and company accounts, however, is not easy to come by, and our knowledge of the actual payments received by singers during the first half of the eighteenth century is in fact rather patchy; as a consequence, researchers have often had little more to draw on than rumour and hearsay from biased sources, such as The Prompter's report of the ‘near Four thousand Pounds a Year' that Farinelli was supposed to have earned for singing with the Opera of the Nobility between 1734 and 1737.Footnote 4
The discovery of incontrovertible documentary evidence relating to the remuneration of two castrati working in London in the 1740s and 50s will therefore come as a welcome foil to such gossip and speculation. A couple of lawsuits among the records of the court of King's Bench held by The National Archives at Kew in London provide invaluable new evidence about singers' pay and conditions of work in a decade for which information is in very short supply. Legal records are notoriously difficult to use, but the time and energy invested in understanding them is usually repaid. Compared with the rich archival resources of the equity courts, with their interrogatories, depositions, decrees and other supporting documentation, the records of a common-law court such as King's Bench can yield disappointing results.Footnote 5 The information they contain, which often lacks specific detail, is expressed in language that is formulaic, legally quaint and technically abstruse; court procedure in all but the simplest cases can be convoluted; and the pleading process is at times arcane and repetitive, particularly when litigants resort to the use of alternative pleading – the fictional practice of stating in separate counts multiple versions of the same claim. Add to this the size and weight of the plea rolls themselves, which make them physically difficult to handle, and King's Bench records become something of a challenge. Despite these obstacles, the document class is worthy of close study, for just occasionally it provides significant evidence that is to be found nowhere else. The two complementary studies on which this article is based each take the form of a brief account of a castrato's London career, followed by a discussion of the lawsuit in which he was involved and its significance. At the same time, individual cases are contextualised against a background narrative that charts the vicissitudinous history of opera in London around the mid-century.
Angelo Maria Monticelli
The soprano castrato Angelo Maria Monticelli (c. 1712–c. 1758) made his operatic debut in Venice in 1728 as Paride in Albinoni's Le due rivali in amore. Possessed of a clear, sweet voice and ‘a beautiful face and figure', it was perhaps inevitable that many of his early appearances on the Italian stage saw him cast in secondary female roles.Footnote 6 For twelve years he performed in operas throughout Italy, building a significant reputation that resulted in his being engaged by the Austrian court in 1740.Footnote 7 By then he was sufficiently well known to have attracted the attention of Charles Sackville, Earl of Middlesex, who had recently taken over as the director of Italian opera in London at a time when public support for the genre was waning.Footnote 8 Sackville planned to mount the first full season of Italian opera since 1737–8 at the King's Theatre in the Haymarket, the traditional home of opera seria in London, and invited Monticelli to become primo uomo for the 1741–2 season. Two other established singers – the soprano Caterina Visconti and the tenor Angelo Amorevoli – were engaged to make their British debuts with the castrato. However, their arrival in England in the early autumn of 1741 was delayed by bad weather at Calais; amongst the other passengers awaiting embarkation was Horace Walpole, who wrote of the delay that ‘twas not quite bad, for there I found the Viscontina, Amorevoli and Monticelli, whom some English women in my packet-boat call the Creature'.Footnote 9
For his London debut on 31 October 1741, Monticelli sang the title role in Alessandro in Persia, a pasticcio put together by Baldassare Galuppi, resident composer at the King's Theatre. Apart from the singers already mentioned, the cast included Middlesex's mistress, Lucia Panichi (‘La Muscovita'), the castrato Giovanni Battista Andreoni and Signora Tedeschi.Footnote 10 Although critics were generally uncomplimentary about the music, the quality of the singing was widely admired: ‘the new opera is kept up, as it were, by meer force, against every body's opinion; though the voices (I mean the 3 new ones) are admirably fine'.Footnote 11 Monticelli in particular made quite an impression, with the music theorist and composer Robert Price describing him as ‘the finest singer I ever heard', and Walpole going so far as to compare him with his most illustrious predecessor: ‘Monticello [sic] is infinitely admired; next to Farinelli'.Footnote 12 Later in the same letter, however, Walpole intimates the high cost of assembling such an accomplished troupe: Vanneschi, the librettist, was to receive 300 guineas; a tailor specially brought over from Italy was paid £400; and ‘Monticelli and Visconti are to have a thousand guineas apiece; Amorevoli 850'. The season continued with Galuppi's Penelope, the composer's first opera for the London stage, and a new pasticcio, Polidoro. Middlesex's star singers were also kept busy outside the opera house, being required, for example, to sing at gatherings such as the ‘great assembly at Lady Conway's' on 9 February.Footnote 13 From 2 March to 10 April Monticelli sang the title role in Galuppi's Scipione in Cartagine, after which he and other members of the company took part in the annual benefit concert for ‘Decay'd Musicians, or their Families' at the King's Theatre.Footnote 14 A week later he sang the title role in Meraspe, a new pasticcio based on Pergolesi's Olimpiade (1735). Burney comments at length on Act II scene 4, which ‘was rendered so interesting by the manner in which it was acted as well as sung by Monticelli, that I have been assured by attentive hearers and good judges, that the union of poetry and Music, expression and gesture, seldom have had a more powerful effect on an English audience'.Footnote 15 The impact of Monticelli's performance is also attested in a contemporary portrait by Andrea Casali, in which the singer is depicted holding a sheet of music containing the text ‘e non lo posso dir'. These words, sung at the end of Act I by Meraspe in a duet with his lover Aristea (played by Visconti), were perhaps chosen by the artist because they recalled one of Monticelli's most memorable moments on the London operatic stage.Footnote 16 Three performances of Ceffalo e Procri were followed by a brief revival of Scipione in Cartagine, which brought the 1741–2 season to an end on 1 June.Footnote 17 Even after the King's Theatre had closed its doors for the summer, Monticelli's celebrity status continued to bring him into contact with the upper echelons of English society; Horace Walpole commented that the singer was not only a regular guest at his own home, but also that he ‘dines frequently with Sir Robert'.Footnote 18 His indulgence in the high life, however, belied the financial state of the company that paid his salary. Middlesex had spent most of the money collected from subscribers even before the season began, and only loans kept the balance in credit; one in particular, the sum of £2,000 that Drummond's Bank advanced at the beginning of February 1742, was consumed in a couple of days and not repaid until almost three years later.Footnote 19
Middlesex re-engaged Monticelli, Visconti and Amorevoli for 1742–3, while at the same time introducing new blood in the persons of Giulia Frasi (soprano) and Caterina Galli (mezzo-soprano). That season Monticelli took leading roles in the pasticcio Gianguir, in Giuseppe Ferdinando Brivio's Mandane, in Porpora's Temistocle, and in Galuppi's new opera, Enrico.Footnote 20 He again performed at the annual concert in aid of the Decayed Musicians' Fund on 30 March 1743, when Middlesex's singers were joined by a number of instrumentalists.Footnote 21 Monticelli took the title role in the final offering of the season, Galuppi's Sirbace, which opened on 5 April and ran for nine performances, closing on 17 May. Just days before, Horace Walpole had noted that ‘Besides what [Middlesex] will lose this year, he has not paid his share to the losses of the last';Footnote 22 confirmation of Walpole's misgivings came when the season's deficit was calculated at more than £1,600.
Notwithstanding the deepening financial crisis that loomed over his project, Middlesex forged ahead with another season of Italian opera in 1743–4; five new operas were produced, and as leading man in over 50 performances Monticelli must have worked hard for his salary. The season opened on 15 November with Rossane, a version of Handel's Alessandro (1726) possibly compiled by Lampugnani, who by this time had succeeded Galuppi as composer in residence at the King's Theatre; one of the sixteen performances was a benefit for Monticelli.Footnote 23 The castrato also sang in Lampugnani's Alfonso, Veracini's Rosalinda and Pescetti's pasticcio Aristodemo Tiranno di Cuma, and performed ‘The salve regina' at the annual benefit for ‘Decay'd Musicians' on 28 March.Footnote 24 On 22 June, six days after Lampugnani's Alceste had closed the season, Lady Ethelreda Townshend wrote that ‘Monticelli and all the singers and dancers of the opera go away next week, there being no more of these entertainments next winter'.Footnote 25
Italian opera was indeed withdrawn for the 1744–5 season, owing to Middlesex's ongoing financial problems; it is not known how the deficit for 1743–4 was repaid, but it is likely that he drew on his personal fortune to some extent. On 6 June 1744 his fellow directors filed a bill of complaint in the court of Chancery against subscribers who remained in arrears for the 1742–3 season, a move that was to prove disastrous in terms of future support for the company.Footnote 26 With no immediate prospect of employment in London, Monticelli returned to the Continent where he sang the title roles in Gluck's L'Ipolito and Galuppi's Ricimero in Milan.
Although still plagued with debt, Middlesex pressed on with a season of opera in 1745–6, engaging Monticelli and Frasi again, together with a fresh intake of Italian singers that included Giuseppe Ciacchi, the soprano castrato Giuseppe Jozzi, Marianna Imer and her younger sister Teresa Pompeati [Theresa Cornelys]. Theatrical activity in London was greatly disrupted by the Jacobite uprising of autumn 1745; the start of the season was delayed until 7 January, when Gluck, now resident composer at the King's Theatre, produced his first opera for the London stage, La caduta de' giganti. The season continued with Galuppi's Il trionfo della continenza, during the second performance of which ‘Monticelli sung to Italian words that fine song out of Samson “Return O Lord of Hosts” – his performance, incomparable'.Footnote 27 Gluck's pasticcio Artamene opened on 4 March and played for ten nights; Monticelli sang the title role, and according to Burney he ‘was every night encored in “Rasserena il mesto ciglio”’.Footnote 28 At the annual benefit for ‘Decay'd Musicians’ on 25 March, he sang two arias from Rossane, ‘Men fedele' and ‘Il cor mio', which by then had become popular concert items.Footnote 29 Later in the same concert he performed ‘O da pastor nel prato' from Lampugnani's Alceste, and a duet with Signora Imer from Galuppi's Il trionfo della continenza, almost certainly ‘Dite belle alme amanti'.Footnote 30 On 15 April, Monticelli took the part of Poro in Alessandro nell' Indie, a pasticcio attributed to Lampugnani, and the season closed with Galuppi's Antigona, in which he sang Demetrio, his last role for the London stage; he left England some time after the final performance on 24 June 1746, never to return. For ten years he continued to take leading roles in opera houses across Europe, his last known performance being at Genoa in 1756.
There can be little doubt that the four seasons Monticelli spent in London consolidated his reputation as a first-rate singer of international standing. Contemporaries were unanimous in extolling his vocal prowess and exceptional acting ability; and the contexts in which he is mentioned in contemporary plays, ballads, pamphlets and other literary sources suggest that within a short time of his arrival in England, he became so well known to the public that his name could effectively serve as a synonym for Italian opera generally. Burney, not normally an easy man to please, reserved an elevated place for Monticelli in the pantheon of illustrious castrati who had worked in the capital, and his assessment of the singer's many qualities provides a suitable peroration to this discussion of his London career:
His voice was clear, sweet, and free from defects of every kind. He was a chaste performer, and never hazarded any difficulty which he was not certain of executing with the utmost precision. To his vocal excellence may be added the praise of a good actor; so that nothing but the recent remembrance of the gigantic talents of Farinelli, and the grand and majestic style of Senesino, could leave an English audience any thing to wish.Footnote 31
Sackville v. Monticelli
The increasingly parlous state of Middlesex's finances in the late 1740s inevitably led to litigation with his creditors, and among the many lawsuits he had to defend was one brought by Monticelli.Footnote 32 In the Trinity term of 1748 the castrato sued the impresario in the court of King's Bench for salary arrears that had been owing since the end of the 1745–6 season.Footnote 33 The preamble to the litigation states that the action belongs to the type known as ‘trespass on the case’, that is, an action to recover damages that are not the immediate result of a wrongful act but rather a later consequence. ‘Case’, as it is sometimes abbreviated, encompassed the form of action known in Latin as ‘assumpsit’ (‘he undertook’) for monetary damages to compensate for breach of a simple contract, that is, a contract not under seal, but one made orally or in writing. In assumpsit the plaintiff's statement of claim (or ‘declaration’) could be either ‘special’ or ‘general’. It was special when he/she declared upon the original contract, setting out the terms of the agreement in detail (‘specially’); this was the form of pleading adopted by Monticelli's legal advisers. Alternatively, if it was alleged that the defendant was indebted to the plaintiff in a certain sum and had promised to pay it off, then the declaration was said to be general and the appropriate form of pleading was ‘indebitatus assumpsit' (‘being indebted, he undertook'). The details of the transaction generating the debt needed only to be set out in summary form, so there developed a small number of standard formulae to cover the most frequently occurring situations; the defendant would be said to be indebted for the price of ‘goods sold and delivered', for ‘work and labour performed', for ‘money lent', for ‘money paid' and so forth. Collectively these categories were known as the indebitatus or ‘common' counts. An action could be maintained even when the plaintiff was claiming not a predetermined fixed sum of money, but an assessment of the reasonable value of work done (‘quantum meruit' – ‘as much as he deserved') or of goods supplied (‘quantum valebant' – ‘as much as they were worth'). Notwithstanding the theoretical distinction between pleading in special and indebitatus assumpsit, in practice the two forms often co-existed within the same action; special assumpsit carried the risk for the plaintiff that the case would collapse if some material detail of the transaction was not proved as set out in the declaration, so it was considered desirable to join a count in special assumpsit with one in indebitatus, if at all possible. Monticelli's counsel makes precautionary use of this form of alternative pleading in the course of presenting his case.
The singer brought his action of assumpsit against Middlesex on account of the latter's failure to honour an express promise enshrined in a mutually binding contract drawn up on 19 April 1745. Initial process in the suit, however, was not entirely straightforward; normal procedure by bill, in which the defendant would be arrested and bailed to appear in court on a certain day, was not available because of the defendant's status as a member of parliament.Footnote 34 Monticelli had therefore to proceed by original writ out of Chancery in order to prosecute his claim. In actions on the case the original writ was an attachment, that is, a writ ordering the sheriff to take personal sureties from the defendant or seize his property to secure his attendance; for this reason, the plea roll records that Middlesex ‘was attached to answer' the plaintiff. Monticelli's declaration informs the court that he and Middlesex agreed terms of employment for the forthcoming season (1745–6) that committed the singer to travel from Vienna (the plea roll gives ‘Viema') to ‘sing and act in the Operas to be … performed at Westminster under the direction of the said Charles', for which services the latter undertook to pay him £1,050 (1,000 guineas). On arrival in London for the start of the season, Monticelli was apparently persuaded to accept only part of the fee he had negotiated (£735, or 700 guineas), presumably as an initial payment with the understanding that the rest would quickly follow. However, by the time of his departure for the Continent in the summer of 1746, the balance was still outstanding and remained so a year later, when he submitted his final demand for settlement of the debt. The assignment of breach that concludes the first part of Monticelli's declaration sums up the situation: ‘Nevertheless the said Charles not further regarding his said promise and assumption has not paid to the said Angelo the Sum of Three Hundred and Fifteen pounds residue of the said Sum of One Thousand and Fifty pounds nor any further part thereof[,] altho' he the said Charles on the first day of June One thousand seven hundred and forty seven was requested by the said Angelo to pay him the same.'Footnote 35 To this special count Monticelli then added an indebitatus claim, stating that Middlesex was indebted to him in another £1,050 ‘for divers Journeys and other Work[,] Labour and service before that time done and performed at the special Instance and request of the said Charles’; and he alleges that the defendant had faithfully promised to pay the said sum ‘when he should be thereunto afterwards requested’. An equally fictitious quantum meruit count follows, according to which the singer had ‘performed other Journeys and Work[,] Labour and service’ for which Middlesex had undertaken to pay ‘so much money as he therefore reasonably deserved to have’, specified to be in the amount of £1,050. Finally he submitted a fourth claim – another indebitatus count, this time for £500 – ‘for so much money laid out[,] expended and paid by the said Angelo at the special instance and request of the said Charles’. Monticelli rounds off his declaration with a second assignment of breach in respect of the last three counts only: ‘the said Charles not regarding his said second third and fourth promises and assumptions so made in form aforesaid hath not paid to the said Angelo the said several sums of money therein mentioned To the damage of the said Angelo of Four hundred pounds’.Footnote 36 There was, of course, only one sum; so one might well ask why it was necessary to go to the trouble of accumulating these multiple counts. The reason appears to have been that, in any save the most elementary of cases, the lawyer frequently found it difficult to estimate in advance of the trial what precise facts would be established by the evidence. As a result, he wished to preserve for himself the maximum area in which to manoeuvre as the testimony unfolded; one device for assuring such flexibility was the use of so-called alternative pleading. In other words, it was important that the plaintiff exhaust all possibilities, lest the one overlooked be the one established at the trial.
Answering through his attorney, Middlesex pleaded the ‘general issue’, that is, he denied that he had assumed ‘upon himself in manner and form as the above Angelo hath above complained against him[,] And of this he puts himself upon the Country’, which is to say, he opted for trial by jury. Any hopes he might have had that the jury would show partiality towards one of their countrymen in a suit against an Italian opera singer – and a castrato at that – were soon dashed. At the trial in Westminster Hall on 8 November 1748 the jury found in favour of the plaintiff, awarding him damages of £315, costs of forty shillings and an additional sum of £25 to represent interest, all of which amounted to £342.Footnote 37 By this time, Middlesex had disbanded his opera company and withdrawn from theatre management almost entirely; a troupe of Italian buffo players took over at the King's Theatre, opening their first season on the very day the verdict in the Monticelli case was returned. Middlesex's period as director of the Italian opera in London had been little short of disastrous; his enthusiasm for the genre could not compensate for a lack of business acumen, and a mixture of fiscal prodigality and managerial incompetence over which he presided had brought the King's Theatre to a state of near collapse. The over-sized salaries paid to singers undoubtedly contributed to the company's demise. The King's Bench case corroborates the sum paid to Monticelli at least, and confirms the testimony contained in Walpole's letter to Mann of 5 November 1741, which is sometimes dismissed as gossip and/or hyperbole.
Giuseppe Manfredini
The second case study involves the soprano castrato Giuseppe Maria Manfredini and the composer and violinist Francesco Geminiani (1687–1762). In discussing the Monticelli case, little attention was paid to the other party in the dispute; but here an exception must be made, not only because Geminiani is a significant musician in his own right, but because one needs to delve into certain hitherto unexplored aspects of his biography in order to understand the reasons for his interest in the castrato.
Best remembered today for his instrumental music and treatises, Geminiani is not normally associated with singing or singers. His preference for sonatas and concertos over vocal forms was acknowledged even by contemporaries such as Charles Avison, who eulogised ‘the admirable Geminiani’ as ‘the greatest in instrumental Music’, as opposed to Benedetto Marcello, whose excellence lay in vocal composition.Footnote 38 Sir John Hawkins later remarked on the negative consequences of such specialisation for Geminiani's reputation with English audiences:
as he had never attempted dramatic composition of any kind, he drew to him but a small share of the public attention, that being in general awake only to such entertainments as the theatres afford. The consequence whereof was, that the sense of his merits existed only among those who had attained a competent skill in the practice of instrumental harmony.Footnote 39
Geminiani may not have left us any operas, but he was well aware of the theatre's money-spinning potential, and in the 1740s he tried on a number of occasions to break into that lucrative, if volatile, market as an impresario. However, his efforts to forge a meaningful career in the theatre met with only limited success and were soon abandoned.
Geminiani appears to have pieced together a living from a variety of income streams, including composition, performing, teaching and picture dealing. Early in 1725 he added yet another string to his bow by accepting the position of ‘Director and perpetual Dictator of all the musical performances’ of the newly founded Philo-musicae Masonic lodge, which met at the Queen's Head Tavern, Temple Bar. His duties included the selection of repertory to be played at lodge meetings, and the hiring of instrumentalists to provide professional stiffening for the members' ensemble of amateur players.Footnote 40 The experience gained in arranging these music meetings may well have encouraged him to try his hand at concert management, and starting on 2 December 1731 he organised a series of twenty weekly subscription concerts at Hickford's Great Room in Panton Street.Footnote 41 However, without a regular source of income Geminiani needed to widen his horizons, and from 1732 his various interests took him first to Paris and later to Dublin, a major musical centre at the time. He continued to give occasional performances in London, and on 21 December 1741 appeared at the Little Theatre in the Haymarket, ‘By Command of their Royal Highnesses the Prince and Princess of Wales’ in a concert of vocal and instrumental music.Footnote 42 Geminiani returned to the Little Theatre the following month to première his ‘several new Concerto's, never play'd before’, and used the venue again in March 1742 for his own benefit concert given ‘At the Desire of several Persons of Quality’.Footnote 43
For the 1744–5 season, Geminiani was engaged with an altogether more ambitious project at the Little Theatre. Lord Middlesex's financial difficulties across the street at the King's Theatre, which precipitated the departure of his principal singers and the closure of the house in June 1744, presented Geminiani with a business opportunity too good to ignore. The prospect of the Little Theatre mounting what was in effect ‘the only show in town’, and playing to houses filled to capacity with London's affluent and cultured elite must have been irresistible. Geminiani consequently set about assembling a new pasticcio opera in three acts entitled L'incostanza delusa, to a libretto by Vanneschi; his precise role in this ‘pastoral Opera’ is unclear, but he probably put the music together and directed the performances, which all took place on Saturdays (9, 16 and 23 February; 2, 9, 16, 23 and 30 March; 6 and 20 April 1745). According to the Fourth Earl of Shaftesbury, the only music contributed by Geminiani himself was the overture and a concerto (probably from his new concerti grossi op. 7) performed between the acts.Footnote 44 The main musical content comprised new songs by the enigmatic Count of Saint Germain, together with two arias by Giuseppe Brivio taken from his earlier opera of the same name (Milan, 1739).Footnote 45 One of the arias was apparently encored every night, but in general L'incostanza delusa was not well received. Galli and Frasi respectively sang the roles of Filandro (first man) and Corina (first woman). The only other singer who can be identified was a ‘Mrs Frederica’, for whose benefit L'incostanza was performed on 6 April. She and Geminiani quickly fell out over the terms they had agreed for the benefit, and at Michaelmas 1745 he instigated proceedings against her, first in King's Bench and later on the equity side of the Exchequer court.Footnote 46
Not long after L'incostanza delusa closed Geminiani travelled to the Netherlands, where he oversaw the engraving of certain instrumental works. He continued to venture abroad during the late 1740s and early 1750s, especially to Paris, though his exact whereabouts on particular dates are difficult to establish with certainty. He was definitely back in London by 11 April 1750, when a concerto spirituale was given for his benefit at Drury Lane.Footnote 47 The following year was notable for the publication of The Art of Playing on the Violin (op. 9), which would become his most influential theoretical work. The National Archives provide further information about Geminiani's activities around this time; at Easter 1751 he again found himself in King's Bench embroiled in an action for breach of contract with a singer, but this time it was Geminiani who was the defendant. The plaintiff in the case was Giuseppe Manfredini, an interesting musician about whom very little is known.
Giuseppe was born in 1729 in Pistoia, Tuscany, where his father, the composer and violinist Francesco Manfredini (1684–1762), was maestro di cappella at the cathedral.Footnote 48 He apparently began his career in opera seria in 1748 when he played the role of Pilade in Francesco Antonio Uttini's Astianatte in Cesena. After working in Modena and Venice, he took up residence in Bologna where, on 1 December 1749, Geminiani engaged him to come to England. Manfredini's first concert in London was announced not in a blaze of publicity but unobtrusively in The General Advertiser for 26 February 1750, which states that ‘signora galli, Mrs. arne, Master arne and Sig. manfredini will perform the Vocal Parts in Sig. manfredini's Musical EntertainmentTo-morrow, being Tuesday, the 27th Inst. at Mr Hickford's in Brewer-Street’. On 2 April he took part in Hasse's A Serenata at the Little Theatre, a performance given for the benefit of Caterina Galli, a singer a few years his senior who was already an established presence in London, particularly in Handel's oratorios, and with whom he was to enjoy a close professional relationship.Footnote 49 The first event advertised ‘For the Benefit of Sig. manfredini’ was a concert at Hickford's Rooms on 30 April following, for which he was joined by two singers, Galli and a ‘Mr. Palma’, who was most probably Bernardo Palma, another compatriot.Footnote 50
Like many Italian musicians working in England at the time, Giuseppe did not confine his activities to London, and in October 1750 he visited the fashionable city of Bath, where he sang in Francis Fleming's concert at Wiltshire's Room.Footnote 51 Shortly after this provincial excursion, Manfredini may have gone back to Italy, for he is listed as playing Euristeo in Galuppi's Antigona at the Teatro delle Dame in Rome on 9 January 1751.Footnote 52 He must then have returned almost immediately to London, where he sang the role of Medoro in Domenico Paradies's La forza d'amore at the Little Theatre; this opened on 19 January, so it is unlikely that he was back in time to participate in the early performances.Footnote 53 He had certainly returned by 26 March when the opera was performed for his benefit, and tickets could be ‘had at Mr. Manfredini's Lodgings, at Mr. Brown's, at the Golden Ball in Jermyn-Street’.Footnote 54 This was an area of the city convenient for the Haymarket and its theatres, but by the time of his next benefit, at Hickford's Rooms on 9 March 1752, Giuseppe had apparently moved further afield, to ‘Mr. Tubb's, Marshal-Street, Carnaby-Market’.Footnote 55 On that occasion he was joined by Galli and three instrumentalists, one of whom was the violinist Felice Giardini, a recent arrival in the capital who was to enjoy a long and distinguished career there. Another instrumentalist who was part of Manfredini's London circle was the German woodwind player, organist and composer Charles Barbandt, for whose benefit a ‘concert In two parts’ was given at Hickford's Rooms on 14 January 1752.Footnote 56 According to the newspaper advertisement, Manfredini sang Domenico Alberti's ‘Caro sposo amato’, and performed with Galli ‘Tu vuoi partir ingrato’, a duet by an unidentified composer. The following year he participated again in a benefit for her at Hickford's Rooms on 9 April; Manfredini intended to hold his own benefit with a similar line-up of performers five days later, but the concert was postponed twice and did not take place until 10 May. By this time, he had moved lodgings yet again and was living ‘at Mr. Fielding's, Glazier, Silver-Street, Golden Square’, near his friend Galli in Broad Street.Footnote 57 The last mention of Manfredini on the London concert scene occurs on 4 March 1754 when The Public Advertiser announced that his benefit would be held the following day. Again, the concert had been rescheduled, having originally been planned for 20 February, but the soloists remained the same.
Apart from singing, Manfredini also supplemented his income by composing, and his collection of Sei Arie con Istromenti was ‘Printed for the Author’ in London in 1752. Three of these arias were performed between January and March of that year, perhaps to whet prospective buyers' appetites before proceeding to publication. Galli sang the first of the set, ‘Almen se non poss' io’, at the seventh of a series of subscription concerts on 25 January at the Great Room, Dean Street.Footnote 58 On 22 February, the eleventh night of the same series, she performed ‘Non curo l'affetto’, the second number in Manfredini's print.Footnote 59 Finally, at his benefit concert on 9 March he included performances of the first aria as well as the sixth, ‘Tra il vento’, again with Galli as soloist.Footnote 60 Towards the end of his stay in England, Manfredini was employed by John, Fourth Duke of Bedford, in some capacity; a receipt dated 29 April 1754 and signed by the castrato lists the titles of a number of individual arias used in singing lessons for Lady Caroline Russell, Bedford's only daughter, although it is not certain whether Manfredini actually taught the young singer or was charging for his services as a copyist.Footnote 61 This is the last reference to Manfredini in England; not long afterwards, he set off for Italy where he resumed his operatic career for a few years before a more extended period of employment in Russia.Footnote 62
Manfredini v. Geminiani
Manfredini first brought suit against Geminiani in the Hilary Term of 1751, but the defendant petitioned the court for leave to imparl, that is, he asked for time to consider what answer should be made to the plaintiff's bill, and the case was not heard until the following Easter.Footnote 63 Like the case involving Monticelli, this action of assumpsit was brought not to compel the specific performance of a contract, but to recover damages for its non-performance. We learn from the preamble to the litigation that Manfredini did not present his bill of complaint to the court himself; instead, his place was taken by one Dorothy Butler, his ‘next Friend’ or ‘prochein ami', because he was too young to appear in person, being ‘within the Age of Twenty One Years’. This was the age at which someone ceased to be deemed an infant under common law and attained full adult capacity to act on his/her own account. Dorothy Butler was almost certainly the actress and singer ‘Mrs Butler’ (fl. 1746–50), who played in L'Opéra du Gueux (a French version of The Beggar's Opera) at the Little Theatre in the Haymarket in April–May 1749 and February–March 1750.Footnote 64 If Manfredini did indeed sing in Rome in January 1751 (see p. 55 above), then this would explain why he needed someone to stand proxy for him in court, as in fact, the castrato would have been just over the age of 21 by that time, according to the 1729 date of birth given by Grundy Fanelli.
Manfredini's bill describes Geminiani as ‘the Conductor and Manager of Divers Musical Entertainments performed at Divers publick places under the Orders of him the said Francesco to wit at Westminster’, and it was ‘as a Singer or performer of such Musical Entertainments’ that the castrato was hired in Bologna. Given the way the case subsequently developed, it is highly unlikely that Manfredini and the impresario drew up and sealed a formal contract of employment stipulating each party's terms and duties. The form of bilateral agreement into which they entered was probably a simple contract that was written but not sealed, or one that was even less formal, such as a verbal undertaking. It is possible to reconstruct the main points of their agreement from the various grievances raised by Manfredini in the course of his declaration. This identifies what appear to have been six clauses, which are set out below as far as possible in the plaintiff's own words and in the order in which they are presented on the plea roll:
1. ‘[T]he said Francesco should Conduct the said Giuseppe to London and pay for him all the Expences of the Journey’.
2. Once the singer has arrived in England, Geminiani would provide him ‘with Lodging[,] Diet and Washing’.
3. Geminiani ‘should Defray all the expences that should be Necessary on the Night of the said Giuseppe's benefit’. Manfredini was to receive ‘One benefit Night[,] that is to Say a Musical Entertainment performed at One Night for the benefit and Advantage of the said Giuseppe[,] the profits whereof where [sic] to Arise from the Generosity of the publick[.] And the said Giuseppe should Receive from the said benefit One Hundred Guineas Clear of all Charges and Outgoings[.] And if the profits of such benefit did not Amount to that Sum[,] the said Francesco should make up the Deficiency so that the said Giuseppe should put into his pocket the said clear Sum of One Hundred Guineas.’
4. Manfredini ‘agreed not to Sing at the Opera [i.e. the King's Theatre] or in any other publick place without the Consent of the said Francesco’. Should Geminiani choose to waive his exclusive claim on the singer's services, he still reserved the right ‘to make the Agreement[,] and the Sum Agreed for was to be Divided between them both’.
5. Manfredini promised ‘to Sing and Give his Assistance at all the publick Entertainments that should be Ordered by the said Francesco[, and] to be at the Service of the said Francesco untill the then Next Rising of the British parliament’, that is, until 12 April 1750.
6. Geminiani undertook ‘to Send the said Giuseppe back to Bologna Aforesaid at the Expence of the said Francesco and in good faith’.Footnote 65
Four aspects of this quasi-contract invite comment before proceeding. Our knowledge of Geminiani's whereabouts in the late 1740s is uncertain, so it is significant that the wording of clause 1 suggests he was in Bologna at the time of Manfredini's recruitment and that he subsequently accompanied him to England. The singer's averment later in the bill, asserting that he ‘came from Bologna Aforesaid … with[,] and in the service of[,] the said Francesco to London’, appears to confirm this interpretation.Footnote 66 Secondly, Manfredini was lured into making the arduous journey to England by the promise of a benefit, that is, a supplemental performance from which he would receive all or part of the night's takings. Normally granted to performers as compensation for their less-than-generous salaries, a benefit could range from a mere share of the profits once the house charges (lighting, printing, orchestra, wages of other staff, etc.) had been met, to the so-called ‘clear’ or ‘free’ benefit in which the performer received all the proceeds, the management footing the bill for the house costs. Terms as financially generous as those of the ‘clear’ benefit are rarely encountered, but Manfredini negotiated what appears to have been an even better deal: a ‘guaranteed’ benefit clear of all charges and outgoings, in which the singer was to receive an agreed sum, with Geminiani making up the difference even if the box-office receipts did not cover the sum assured. If, as seems likely, the benefit performance was to have taken place at the Little Theatre, then the promised lump-sum payment of a 100 guineas is in line with the little we know about rates of remuneration for similar events held there in the previous decade; in an Exchequer law suit dating from 1753, Caterina Galli claimed that in 1745 she had received £100 from ‘The Moneys Collected at the little Theatre in the Haymarket at which place the Complainant had a benefit all Expences Deducted’.Footnote 67 Thirdly, the fact that Manfredini believed he was entitled to bed, board and washing, and refers to himself as being in Geminiani's service, tells us something about the nature of the relationship between the two musicians. Hired servants and apprentices could expect to receive maintenance – shelter, food and, in many cases, laundry and clothing – from their master.Footnote 68 In early modern Italy it was not uncommon for a formal agreement, similar to the indentures drawn up between master and apprentice, to be used to regulate the singing teacher–pupil relationship. The teacher would be expected to instruct, feed, put up, and even clothe the student in exchange for a percentage of the latter's current or future earnings; in keeping with the patriarchal tendencies of Italian society, the maestro might even assume the role of father figure and keep a sympathetic eye on his charge's finances, contracts and professional conduct.Footnote 69 Similar conditions obtained in Britain at this time; Charles Burney, for example, was bound as an apprentice to Thomas Augustine Arne in 1744 for a period of seven years, during which time the income derived from the young man's various and often onerous labours accrued entirely to Arne.Footnote 70 Clauses 4 and 5 suggest that Geminiani exercised similar control over Manfredini's affairs. Finally, the fifth clause must be unique in the history of eighteenth-century contract law relating to the performing arts in coupling the termination of Manfredini's employment with the rising of the British parliament; and yet, from the standpoint of a theatre manager with one eye on box-office receipts, such a condition would not appear to be unreasonable.Footnote 71 As a group the House of Commons, consisting of over 550 members, was more likely than most to attend operatic performances on a regular basis. Certainly at the King's Theatre, opera companies tended to open seasons early or late depending on the presence in London of the country audience that ‘came to town’ for reasons connected with parliament and/or the termly sittings of the law courts. Geminiani was doubtless targeting a similar social set at the Little Theatre, and his business strategy there would have been much the same.Footnote 72
In the rest of his bill Manfredini states that, although he had kept his side of the bargain in every respect, Geminiani had not procured the agreed benefit for him. Indeed, he claims that on 22 March 1750, three weeks before his contract of employment was due to expire, Geminiani unilaterally ended the agreement and ‘turned and Dismissed the said Giuseppe out of his Service’. Furthermore, Geminiani ‘did not find or provide the said Giuseppe[,] either from the said Giuseppe so coming to London to that day or at any time from that Day Afterwards[,] with Lodging[,] Diet and Washing[;] nor did he at the said Rising of the said Parliament or at any other time hitherto send back the said Giuseppe to Bologna Aforesaid at the Expence of him the said Francesco’.
Manfredini's first count alleges that on 1 May 1750 Geminiani owed him £300; this indebitatus count was ‘for Work and Labour[,] Care and Diligence of the said Giuseppe before that time done[,] performed and bestowed for the said Francesco in and about the Business of the said Francesco and at his Special Instance and Request’. He then repeats the claim in a quantum meruit count, stating that Geminiani had promised to pay him ‘so much Money as he therefore Reasonably deserved to have’, which Manfredini avers was ‘other [i.e., another] Three Hundred pounds’. Again, this reflects the common practice of presenting the claim in the alternative, so that if the plaintiff failed to recover in indebitatus he could fall back on quantum meruit. It would appear from this that, whatever the nature of the contract negotiated by Geminiani and Manfredini in Bologna, they had not previously reached a set price for the latter's services. Typically, quantum meruit lay to recover reasonable remuneration for services that the parties agreed should be rendered, yet without making explicit mutual promises to that effect. Manfredini was arguing that, although the size of his salary had been left indeterminate, a contract ‘implied-in-law’ had been created between himself and the impresario because of the nature of their professional relationship, it being clear that the party rendering the services was not in the business of making gifts.
Manfredini then submits a second smaller claim, alleging that Geminiani ‘Afterwards the same day and year last Aforesaid [1 May 1750] at Westminster … was Indebted to the said Giuseppe in One Hundred pounds of like Lawfull Money’, which may represent the singer's search for compensation for the loss of his benefit night. This is pleaded using three of the indebitatus counts, each time suing for £100; that is, ‘for Money by the said Giuseppe before that time laid out[,] Expended and paid for the said Francesco’; for ‘Money lent and Advanced’ to the latter; and for money ‘had and Received to the use of the said Giuseppe’. Manfredini claims that all five actions (recte two) were founded on Geminiani's promise to pay him the money ‘when afterwards he should be thereto required’, and as a consequence of his refusal to do so, damages of £400 (that is £300 plus £100) are sought.
When the case came to court on Wednesday 24 April 1751 (the first day of the Easter term), Geminiani's attorney John Fell denied that his client had given the promises and undertakings in the manner and form set out in Manfredini's bill, and chose to go to trial. He also sought wholly to overthrow the plaintiff's action then and there by entering a plea in bar, that is a plea that, rather than addressing the merits and denying the facts alleged, introduced some extrinsic matter to show the court why Manfredini's case should not be allowed to proceed. For this purpose Fell resorted to the controversial Licensing Act of 1737 (10 Geo. II, c. 28), the opening clauses of which are then quoted virtually word for word on the plea roll. The powers conferred by this act, which remained in force until 1968, were considerable and far-reaching.Footnote 73 Its provisions protected and strengthened the position of London's two patent theatres by restricting the activities of rival houses, and provided a mechanism for the approval of all plays and other stage entertainments by requiring scripts to be submitted to the Lord Chamberlain for his prior scrutiny. But the act did more than just enshrine in statute law the government's right to censor and prohibit drama. Introduced to parliament as an amendment to the 1714 law relating to rogues, vagabonds and actors (12 Anne, c. 23), the legislation was intended to regulate players as well as plays and venues, and it was this aspect of the act that Fell found most useful in making the case for the defence.Footnote 74 The first clause of the 1737 enactment declares:
that from and after the twenty-fourth day of June … every person who shall, for hire, gain or reward, act, represent or perform, or cause to be acted, represented or performed any interlude, tragedy, comedy, opera, play, farce or other entertainment of the stage, or any part or parts therein, in case such person shall not have any legal settlement in the place where the same shall be acted, represented or performed without authority by virtue of letters patent from His Majesty … or without licence from the Lord Chamberlain of His Majesty's household … shall be deemed to be a rogue and a vagabond within the intent and meaning of the said recited Act, and shall be liable and subject to all such penalties and punishments, and by such methods of conviction as are inflicted on or appointed by the said Act for the punishment of rogues and vagabonds who shall be found wandering, begging and misordering themselves …Footnote 75
The notion of ‘settlement’ central to this clause is inextricably bound up with English poor-law legislation. The 1662 Act ‘for the better Relief of the Poor of this Kingdom’ (13 & 14 Car. II c. 12) confirmed that responsibility for relieving poverty lay with the smallest unit of local government, the parish. Every native was deemed to possess a settlement in one parish, and in no other, and relief would be granted to its paupers there and there alone; if they were ‘unsettled’ in a parish and became (or were likely to become) a liability to the local community, they might be forcibly moved on. Criteria were laid down that newcomers had to meet before their entitlement to poor relief was assured; they could qualify by (a) holding public office or paying the parish rate, (b) renting or owning property in the parish, (c) being hired as a covenant servant for a year there, (d) marrying a husband there, (e) having a father settled there, (f) by birth in a parish if a bastard, (g) being apprenticed there, (h) residing there for 40 days after having given the parish authorities prior notice. The ‘penalties and punishments’ of Queen Anne's vagrancy law (referred to above as ‘the said recited act’) included being whipped until bloody, returned to the place of birth or last residence, or sent to hard labour in a house of correction either in England or the colonies.
The second clause of the act quoted on the plea roll states:
that if any person having or not having a legal settlement as aforesaid shall, without such authority or licence as aforesaid, act, represent or perform, or cause to be acted, represented or performed for hire, gain or reward any interlude, tragedy, comedy, opera, play, farce, or other entertainment of the stage, or any part or parts therein, every such person shall for every such offence forfeit the sum of fifty pounds; and in case the said sum of fifty pounds shall be paid, levied or recovered, such offender shall not for the same offence suffer any of the pains and penalties inflicted by the said recited act.
In 1750, £50 had the purchasing power of nearly £4,500 in today's money, and the implication was that any fine left unpaid would expose the offender to the rigours of the 1714 legislation. Geminiani acknowledges that Manfredini had undertaken to perform ‘certain parts in Musicall Entertainments called Operas and Some times called pastoral Operas’, and that the singer ‘was to have hire and Gain’ from him, but he points out that in the city of Westminster, where the performances were to be held,
the said Giuseppe hath not nor ever had any Legall Settlement[.] Nor had the said Giuseppe[,] at the time of the Making of the said promise or at any time since[,] any Authority by Virtue of any Letters patent of our Lord the present King or any License from the Lord Chamberlain to perform any part in any Opera.
Geminiani appears to be arguing, quite unscrupulously, that keeping his promise to employ Manfredini would have left them both vulnerable to penal sanctions – the singer, as an unlicensed performer without lawful settlement in Westminster, and the impresario (his agent), as an accessory before the fact and complicit in the offence. He therefore prays judgment that the case against him be dismissed.
Geminiani then defends himself against Manfredini's claim for £300 for bed and board by alleging that the singer in fact owes him the same sum for ‘Meat[,] Doing Washing[,] Lodging and other Necessaries’. Again, this is pleaded using the familiar indebitatus counts of ‘money laid out, expended and paid’, ‘money lent’ and ‘money had and received’. However, as a concession, he is prepared to deduct and off-set that debt against what Manfredini says is owing to him in damages for various breaches of their agreement, and to declare their liability to each other mutually discharged. And there he rests his case.
Proceedings were repeatedly adjourned for a period of two years, during which Manfredini was several times given leave to answer Geminiani's various pleas. When the parties assembled for the last time on 22 June 1753, the plaintiff filed a demurrer to the defendant's evidence regarding the £100 claim and his plea that the singer could not be employed for want of legal settlement; in other words, Manfredini objected to the legal sufficiency of Geminiani's pleading, maintaining that, even if factually true, it did not entitle the defendant to bar his action and that he was himself entitled in law to succeed on the facts alleged and admitted. In reply, Geminiani simply reiterated his position, and counsel for both parties agreed that a matter of law was in dispute; the jury was therefore dismissed and the demurrer determined by the court. No record of judicial deliberations on the matter survives, but it is possible to discover the court's decision through recourse to the relevant Entry Book of Judgments; a tax of sixteen shillings levied on the court costs was paid on 24 July 1753, and the initial ‘G’ in the right margin of the entry shows that it was Geminiani who was responsible for them, indicating that he lost the case.Footnote 76 The King's Bench judges appear to have taken the view that the impresario, being effectively in loco parentis, had treated Manfredini in an unprincipled manner and had tried to wriggle out of his contractual obligations by exploiting an ambiguity in the law.
One may well ask oneself why Geminiani hired a castrato in the first place; to answer that question one needs briefly to consider the unstable conditions that prevailed in London's opera houses around the middle of the eighteenth century. After Monticelli's final departure from the King's Theatre in 1746, Middlesex and his company staggered on for another couple of seasons despite mounting debts. Chastened by the whole experience, he eventually withdrew from direct involvement in the promotion of opera in London, but before doing so he engaged an Italian buffo company managed by Giovanni Francesco Crosa for the 1748–9 season.Footnote 77 This new troupe, which included the castrato Gaetano Guadagni, opened on 8 November with Rinaldo di Capua's La commedia in commedia to a libretto by Vanneschi, who had succeeded Middlesex as impresario at the opera house. The newspapers heralded the piece as ‘A Burletta, or Comic Opera … being the first of this Species of Musick Drama ever exhibited in England’, and there followed over 40 performances of various other works of a similar type which, according to Burney, ‘pleased the public, and filled the theatre, very successfully, during the whole season’.Footnote 78 With the management of the King's apparently committed to opera buffa for the foreseeable future, Geminiani may have resurrected the idea of setting up a home for serious opera at the Little Theatre, an ambition he had first tried to realise with L'incostanza delusa during the 1744–5 season, when there was a similar dearth of opera seria in the capital. A nucleus of good singers trained in the seria tradition was available locally (Galli and Frasi, for instance), but if the venture was to stand any chance of success the services of a castrato – the focal point of any opera seria – would be required; hence his trip to Italy in the late autumn of 1749 to recruit the up-and-coming Manfredini. Meanwhile, however, events back in London had taken an unexpected turn. After their successful first season in England Crosa and his company travelled to Brussels, where they experienced considerable upheaval in personnel and a number of important members left. What is more, when the depleted troupe returned to the Haymarket in the autumn of 1749 it soon found itself performing at the Little Theatre, which was smaller and less prestigious than the King's, on account of a dispute between Crosa and Vanneschi over who was responsible for paying the salary of one of the dancers. The 1749–50 season began on 21 November with eight successive performances of Il negligente by Vincenzo Ciampi, who had joined the company as composer and music director during the previous season. By the new year Crosa and Vanneschi had apparently patched up their differences and the buffo players were back at the King's Theatre, offering Gaetano Latilla's Madama Ciana and reprises of his Don Calascione from their first season. However, the loss of Crosa's principal players in Brussels had adversely affected the company's ability to draw the crowds, both at the Little Theatre and at the King's; to reverse this downward trend in audience numbers and avert financial disaster, Crosa performed something of an artistic volte-face and embraced opera seria. On 25 January 1750 The General Advertiser appended the following announcement to its notice for Madama Ciana:
To endeavour to please the Quality, that are Encouragers to the Performances at this Theatre, on the 20th of February next, will be performed a New Serious Opera, called l'adriano in siria, the Musick entirely New, composed by Sig. ciampi …
This played to thin houses for eight performances between 20 February and 3 April, interspersed with two nights of Il negligente. On 31 March Crosa again attempted to kindle the audience's interest in the genre, this time with Ciampi's Il trionfo di Camilla, but that work expired after only two nights. It was under such inauspicious conditions that Manfredini entered the London musical scene in late February 1750. By the time of his arrival, Crosa had already moved to plug the gap in the market – small as it proved to be – that Geminiani sought to exploit; the latter's vision of a future in which the Little Theatre would serve as an alternative venue for opera seria while the King's fed the British public a diet of burlettas was overtaken by events beyond his control. Furthermore, Frasi, whom he may have earmarked as his leading lady, had joined Crosa's company and was singing the part of Emirena in Adriano, and the title role in Il trionfo di Camilla. With the public's limited taste for serious opera once more catered for at the King's Theatre, where Guadagni was singing the castrato parts, Manfredini's talents were considered surplus to requirements. However, this return to the status quo ante was short-lived; the season was brought to a premature close at the end of April by Crosa's bankruptcy, imprisonment and subsequent flight to the Continent, ‘leaving the performers and innumerable tradespeople, and others, his creditors’.Footnote 79 Following his departure, Italian opera at the King's Theatre ceased altogether and would not resume until 1753. This time Geminiani did nothing to fill the vacuum; the Crosa débâcle, coming so soon after the failure of Middlesex's company, must finally have brought home to him the reality of the situation – namely that any hope of making opera seria economically viable in London was a forlorn one in the current climate.
The case of Manfredini versus Geminiani illuminates the career of a virtually unknown singer/composer and throws new light on the activities of one of the most interesting and colourful figures in the musical life of eighteenth-century Britain. Not only does it advance our knowledge of the benefit system, about which far less is known for musicians than for actors; it also helps to explain the somewhat dim view that contemporary music historians have taken of Geminiani's character. Hawkins comments that ‘his contracting of debts, and neglect in payment of them, seem to indicate as well a want of principle as discretion’.Footnote 80 Burney is even more judgmental, remarking in particular that ‘a propensity towards chicane and cunning, which gratifies some dispositions more by outwitting mankind, than excelling them in virtue and talents, operated a little upon Geminiani’.Footnote 81 If the Licensing Act really did pose a threat to the employment of foreign musicians in London from 1737, then by 1749 Geminiani (of all people) ought to have known about it. Exceptions to the act were evidently made and legal impediments circumvented, to judge from the number of continental musicians who appear to have worked in the British theatre with impunity. It was therefore morally fraudulent for him to claim that it was the constraints of the act that had prevented him from employing his young charge.
Geminiani's failure to honour his obligations probably arose from an unforeseen change of circumstances that removed opportunities for the singer and prevented the impresario from discharging his contractual commitments. It must have been difficult to maintain scrupulous standards of probity in the unpredictable and cut-throat world of London opera during the 1740s and 50s, and the evidence that has come to light thus far concerning Geminiani's involvement with singers suggests that he was as much sinned against as sinning, his case against Mrs Frederica indicating that singers as much as impresarios could play less than fair.Footnote 82 This was hardly the ideal moment to introduce an aspiring castrato to the London stage, financial difficulties and disputes making the 1749–50 season an ‘unsuccessful’ one for the opera.Footnote 83 The decision to bring Manfredini to London may well have been taken in good faith, but the failure of Geminiani's plans left him with a redundant singer on his hands and a law suit for compensation to defend. Left high and dry in a foreign city and barely out of childhood, Manfredini appears to have eked out a living from performing in public concerts, particularly benefits in support of himself or, more occasionally, other musicians. His eventual decision to sue Geminiani was both brave and desperate, though presumably a decision taken with the advice of more experienced London friends. His trust in the British judicial system, as a foreign national, was evidently rewarded. Such was the precarious lot of singers in the tough commercial world of London's theatres; irrespective of one's standing, be it highly paid international star like Monticelli, or inexperienced youth like Manfredini, one still had to fight one's corner.
