19. Bartolus understands a simple and naked consciousness, without any sign of approbation or concurrence. For this opinion, says Baldus, he is now roasting in hell. For my own part, continues the discreet Heineccius (Element. Jur. Civil. l. iv. p. 411), I must approve the theory of Bartolus; but in practise I should incline to the sentiment of Baldus. Yet Bartolus was gravely quoted by the lawyers of Cardinal Richelieu; and Eutropius was indirectly guilty of the murder of the virtuous De Thou.