] I am sure cases occured during JA's time, right up until Victorian times...
Indeed, apparently well into last century.
In getting his servant, Bunter, to get very friendly with the (women) servants of a suspect to get information, Lord Peter Wimsey says:
'In case of an action for breach, or any consequences of that description, the charges will, of course, be borne by the management.'
("Strong Poison", by Dorothy Sayers.) This was written in 1930 and there is no reason to believe it was not set in 1930 also.