One of the most influential considerations in the courts’ attitude towards penal fines is their affordability for low-income offenders. European literature devoted much energy to addressing the use of imprisonment as a substitute penalty in default of payment and the subsequent overcrowding of prisons with poor people who could not paid their fines. These two problems became central focuses in the European criminal systems during the 19th century. This paper aims to investigate more closely the reasons why these phenomena became such a focal issue and the measures taken to manage them. It does so by reviewing historical material from a variety of West European countries.