The last in England was the famous Ashford vs Thornton case in 1818. Thomas Thornton was accused of murdering Mary Ashford. He was acquitted ( though much circumstantial evidence was against him) and Mary's brother William appealed. Thornton then demanded the right of trial by combat against William. Trial by battle was still a possibility, in law. The court felt that not enough evidence existed for Thornton's guilt, allowed his plea for trial by battle; William declined, the court set Thornton free.. The outcry was great enough, however, that the law was quickly amended in 1819.

Theologians had begun to doubt the legitimacy of it much, much earlier- it essentially is pretending people have the power to force God to intervene. And as Voltaire famously pointed out, in battle God seemed to always be on the side of the biggest army.