APPELLATE PRACTICE — Grounds of Appeal — Distinction Between Grounds of Law and Mixed Law and Fact — Determination of Nature of Ground of Appeal

"In determining whether a ground of appeal is one of fact, mixed law and facts or facts simpliciter, the court should go further than the ground of appeal as couched by the appeal and move down to the particulars of error numerically tabulated thereunder. This is because it is the total package of the ground of appeal and the particulars therein that complete the exercise leading to the conclusion whether a ground of appeal is one of exclusive law or one of mixed law and fact or one of facts simpliciter. It is the experience in quite a number of cases that while the ground of appeal deals with pure and unadulterated law, the particulars that edify the grounds move to the stream of mixed law and fact, and in some cases to facts and facts only."