Unlike other European societies, the English rarely employed the ordeal in non-criminal proceedings. The mandatory use of the ordeal in certain criminal proceedings appears to date from the Assize of Clarendon in 1166. Prior to then, compurgation was the most usual method of proof, and the ordeal was used in cases where there was some presumption of guilt against the accused or when the accused was bound to fail in compurgation. A distinction was made between those accused "fama publica" (by public outcry) and those accused on the basis of specific facts. Those accused "fama publica" were able to exculpate themselves by means of compurgation, whereas those accused on the basis of specific facts and those who were thought to have bad character were made to undergo the ordeal.