The procurator fiscal has never been obliged to prosecute and can choose the level at which to prosecute (either through solemn or summary procedure). The defendant has no right to choose a jury trial, nor can a victim on their own decide to press charges, as the decision on whether to try by jury or summarily belongs to the prosecutor. There is a very exceptional mechanism however, called a "bill for criminal letters", where a victim of a crime can petition the High Court of Justiciary for permission ('to pass the bill') to prosecute; akin to private prosecution in other jurisdictions. The last successful bill passed was in 1982 and previous to that, in 1909. Until 1987, the PF's discretion only extended to the degree to which they should prosecute, if at all; there were no alternatives to prosecution. The Criminal Justice (Scotland) Act 1987 gave procurators fiscal the power to offer fixed penalties instead of prosecution (a fiscal fine), at the time limited to a maximum of £25 and subsequently increased to £300.