The followers of Wickliffe, then called Lollards, were become extremely numerous, and the clergy were so vexed to see them increase; whatever power or influence they might have to molest them in an underhand manner, they had no authority by law to put them to death. However, the clergy embraced the favourable opportunity and prevailed upon the king to suffer a bill to be brought into parliament, by which all Lollards who remained obstinate, should be delivered over to the secular power, and burnt as heretics. This act was the first in Britain for the burning of people for their religious sentiments; it passed in the year 1401 and was soon after put into execution.
The first person who suffered in consequence of this cruel act was William Santree, or Sawtree, a priest, who was burnt to death in Smithfield.
Foxe's Book of Martyrs
Sawtre was in fact executed to show Parliament that there was a precedent.