Contemporary historians imagine reformist activity relating to women in colonial India as a series of public debates scattered across the nineteenth century. Whether such historians discuss sati, widow remarriage, the Rakhmabai case or the Age of Consent controversy, they privilege highly specific vocabularies of contestation, forms of argument and forums of expression. Judicial reformist activity, occurring incrementally within the technical vocabularies of law, tends largely to be disregarded. This disregard is hardly new. Anglo-Indian judges themselves recognized that their reformist activity was shielded from scrutiny when they boasted that ‘judicial decisions have silently promoted the cause of female emancipation and progress.’