WARDOUR, Sir Edward (1578-1646), of Chiswick House, Chiswick, Mdx. and St. Martin-in-the-Fields, Westminster.
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Family and Education
bap. 16 Nov. 1578,1 o.s. of Chidiock Wardour† of Chiswick House and Plaitford, Hants and Mary, da. of Henry Becker of London.2 educ. Queen’s, Oxf. 1594; L. Inn 1595.3 m. by 1604, Jane (d.1653), da. of William Bowdler of London, merchant, 3s. (2 d.v.p.) 2da (1 d.v.p). suc. fa. 1611; kntd. 20 July 1618. d. 14 Mar. 1646.4 sig. Edward Wardour.
Junior clerk, Pells Office, Exchequer 1595-?1603,5 clerk of the Pells (jt.) 1603-11, 1637-at least 1643, (sole) 1611-37;6 commr. to examine Sir Sampson Darrell’s* accounts, 1635,7 prevent frauds in the payment of customs for gold and silver thread 1636;8 commr. and recvr. for compounding for false making cloth 1637.9
Commr. annoyances, Mdx. 1613, 1624-5,10 j.p. Mdx. by 1614-at least 1641, Westminster, Mdx. 1618-at least 1641;11 commr. inquiry into John Musgrave’s estates, Mdx. 1615,12 investigate new public buildings, St. Martin-in-the-Fields 1614,13 buildings, London and Mdx. 1616,14 sewers, Mdx. 1619-39, Westminster, Mdx. 1634, Gt. Fens. 1638,15 subsidy, Mdx. and Westminster 1621,16 1641-2,17 Forced loan, Mdx. 1626, Westminster 1626-7,18 knighthood fines, Mdx. 1630,19 oyer and terminer 1638;20 recvr. fines, R. Thames 1636;21 commr. array, Mdx. 1642.22
Member, E.I. Co by 1624-at least 1640.23
Wardour’s family were minor Wiltshire landowners by the early sixteenth century.24 His father Chidiock, the first of his family to sit for Parliament, purchased a senior Exchequer post, the clerkship of the Pells, and was the first member of the family to sit in Parliament. Chidiock was a prominent resident of St. Martin-in-the-Fields, where he was a member of the select vestry. He also acquired a house in Chiswick, in which parish he was buried. According to an early eighteenth century account, Wardour built the original Chiswick House, described as ‘a noble and ancient seat ... after the ancient manner, very regular and strong’, although the building may actually have been constructed by his father. Wardour continued to live in St. Martin-in-the-Fields, but was not as active in parish affairs as his father.25 He may, like his father, have been a puritan, as he was concerned to maintain preaching among the alum workers and John Pym* appointed him one of the trustees of his estate in 1615. However, there is no evidence that he supported nonconformist ministers.26
Wardour left Oxford without a degree after one year. Progressing to Lincoln’s Inn in 1595, his period of study there was briefer still, as he rapidly became an under-clerk to his father in the Pells Office, a post he presumably held until becoming joint clerk with his father in 1603. He became sole clerk at Chidiock’s death in 1611, and so preserved the family’s hold over this office, which was to continue for a further generation.27 As an Exchequer official he was always vulnerable to official pressure and probably had little choice over contributing £20 to the Benevolence raised to compensate for James’s failure to extract a grant of supply from the 1614 Parliament.28
To augment his official income of about £750 p.a., Wardour speculated in investments and purchased several properties, principally in Wiltshire.29 In 1609 he bought the view of frankpledge at two of the crown’s Northamptonshire manors, as well as a reversionary lease of the profits from the fairs and markets held in Devizes, Wiltshire, the latter being quickly sold to the town’s corporation.30 In the following year he paid £1,500 for a 40-year lease on certain profits arising from Malmesbury’s fairs, markets and courts leet as well as a number of copyhold tenements in the town.31 The interest this gave him helps explain his election to Parliament for the borough in 1621, 1624 and 1625. In addition he may have had the support of the borough’s dominant patron, Thomas Howard, 1st earl of Suffolk, with whom Wardour had presumably come into contact when Suffolk was lord treasurer (1614-18).
Wardour was named to only four committees in the 1621 Parliament, but spoke at least 17 times. In his first recorded speech, on 17 Feb., he successfully moved that Christopher Kennell or Kennet, with whom Wardour had no known connection, should be allowed to give evidence against the warden of the Fleet.32 On 15 Mar. Wardour added to the list of grievances concerning the lawcourts enumerated by Sir Lionel Cranfield, ‘the imposing of fines upon subjects, for not performing [Chancery] decrees’. He also called for a patent which had granted two such fines to Henry Gibb, a Scottish courtier, to be called in. Wardour may have had a personal interest in the case as one of the men fined, Richard Bowdler, was perhaps related to his father-in-law, William Bowdler.33 Wardour returned to the issue on 26 Mar., when he argued that the fines imposed upon Bowdler and the other parties in the suit were illegal. Moreover, he successfully called for an order to stay Gibb’s patent, which was then in the hands of the clerk of the Hanaper, George Mynne*.34 When Pym reported on 25 Apr. that, notwithstanding the Commons’ intervention, proceedings were still continuing, he was seconded by Wardour, who complained that George Morgan, despite having been informed of the order of the 26 Mar. by Mynne, had procured a further writ in the suit. On the same day Wardour was appointed to the committee to draft a bill to regulate Chancery, and subsequently attended one of its meetings.35 There are other signs that Wardour was concerned about grievances relating to the judiciary. On 23 Apr. he moved that Sir John Bennet, the corrupt judge of the Prerogative Court of Canterbury, should be committed to the Tower before he was ejected from the Commons ‘else [the House had] no power to do it’.36 Four days later, following Sir Edward Coke’s report about the patent for the fees taken by the masters in Chancery, Wardour complained that ‘the seal and day [on the patent was] false’.37
As a Westminster resident Wardour took a keen interest in the city’s election dispute. The election had taken place on 11 Dec. 1620, but one of the successful candidates died shortly after. A further election was held on 30 Dec., without a new writ, when William Man was elected, but supporters of another candidate, Edward Forsett*, petitioned the Commons against the return. Wardour was clearly a supporter of Forsett, who may have known Wardour’s father as a fellow member of the select vestry of St. Martin-in-the-Fields. He argued on 26 Feb. that the petitioners should be allowed counsel and, speaking again in the same debate, criticized the dean of Westminster for refusing to conduct a proper poll. Nevertheless he upheld the power of the bailiff of Westminster to make the return.38 On 22 Mar. he unsuccessfully moved for counsel to be heard, but the House resolved to accept Man’s election after a division.39
Wardour took some interest in issues relating to the House itself. On 26 Mar. he was appointed to the committee to consider improvements to the Commons’ chamber and on 9 May he supported Sir Thomas Roe who had moved that Clement Coke should be committed to the Tower following his assault on a fellow Member, Sir Charles Morrison.40 It was probably in his capacity as a Westminster j.p. that Wardour was named to the committee on 3 Mar. to advise on the best course for finding Matthias Fowle, one of the patentees for gold thread, who had absconded.41 When, on 26 Apr., Sir Dudley Digges presented a petition against the ‘divers very unworthy persons’ who had been recently added to commissions of the peace, Wardour, speaking from his local knowledge, complained that there were 36 members of the Westminster bench, although it was ‘but three parishes’.42
Wardour’s contributions to the House’s deliberations about religion related to Catholicism. On 24 Feb. he supported the evidence produced by Sir Henry Spiller, the Exchequer official in charge of the Crown’s revenues from recusancy, about the reduction in receipts from that source.43 It is difficult to say whether anti-Catholicism or concern for the government’s revenue lay behind his assertion at the second reading of the bill to strengthen the recusancy laws on 4 May that it was ‘fit’ that any man who married a Catholic should pay her fines.44
Wardour’s anti-Catholicism, and his support for the Palatinate cause, is perhaps more unambiguously evident in the debate on 1 May about punishing Edward Floyd, a Catholic barrister who was alleged to have spoken disrespectfully of Princess Elizabeth and her husband, the Elector Palatine. He argued that Floyd should be whipped as many times as the princess was years old, or possibly the combined ages of her and her husband, and that he should also be bored in the tongue. He was clearly less exercised by the question of the jurisdiction of the Commons over non-Members than he had been when he spoke about Bennet, arguing that the House should ‘make a precedent if none before’.45
Wardour took only a limited interest in legislation. On 1 Mar. he moved that the bill against drunkenness should define the offence.46 On 9 May he opposed the bill to prohibit the import of Irish cattle ‘in respect of the dearness of beef here’, although he proposed that the importers should be compelled to use the proceeds to buy English commodities for export, rather than remit money back to Ireland. Low meat prices would have suited both the inhabitants of Westminster and also the clothworkers of the Malmesbury region, and increasing exports would have been particularly important to the latter.47 In addition he was also named on 15 Mar. to consider the bill concerning sheriff’s accounts, an issue presumably of interest to him as an Exchequer official.48
Wardour appears only once in the surviving records of the second sitting. Speaking ‘in his own element’ on 28 Nov., and using the records in his office, he informed the House of the Crown’s receipts from the last subsidy and fifteenth. Testifying that ‘no more cometh into the king’s receipt’ than the sums he had specified, he presumably hoped to persuade the Commons that a vote of one subsidy would be inadequate, but was unsuccessful.49 In March 1622 Wardour contributed £20 towards the Palatinate Benevolence.50
During the 1620s Wardour suffered a series of setbacks to his finances. It was probably these which forced him, by 1624, to sell his house in Chiswick (to Robert Carr, 1st earl of Somerset) and move to Turrett House, a smaller property close by, to which he retired in the summer.51 In 1621 he was sued for £600 after failing to repay a loan from Sir Robert Seymour, a teller in the Exchequer.52 Wardour’s financial difficulties may have been exacerbated by his apparent inability to extract a significant level of unofficial perquisites from his office as clerk of the Pells. In June 1621 Sir William Brouncker, a patentee of the farm of issues of jurors, had sued him in Star Chamber for overcharging fees for writing out issues of jurors, to which Wardour plaintively responded that he had been able to command only £13 in unofficial fees during the previous seven years, far less than his predecessors.53 Faced with such allegedly restricted opportunities for enrichment, Wardour sought other avenues. In February 1622 he purchased another unspecified office for £200.54 Two years later he purchased £400 worth of East India Company stock. However, he does not seem to have been happy with running of the Company and in 1632 he unsuccessfully challenged the authority of the governor, (Sir) Maurice Abbot*.55
Wardour was again returned for Malmesbury in 1624, when he was named to seven committees and was instructed to attend two conferences with the Lords. He also made ten speeches. The first was on 21 Feb., after Speaker Crewe had been presented to the king and the House had returned to the chamber. Crewe, as was customary, had given a bill, concerning probate of suggestions, a pro-forma first reading to initiate the proceedings of the session. Contrary to precedent Wardour tried to debate the measure, but thereupon he was cried down and the House was adjourned.56 Wardour’s next intervention was more orderly. Two days later he supported the proposal to hold a general fast ‘that we may be assisted by the prayers of all those whose voices we bear’, but he was careful to second those who had urged the importance of getting the king’s consent.57
On 1 Mar. Wardour moved for a reading of the House’s declaration of 4 June 1621 declaring its support for the Palatinate, and in the committee of the Whole later the same day he instanced evidence of Habsburg duplicity from the reign of Henry VIII. In addition he argued that successive Spanish kings salved their consciences on their deathbeds for annexing the kingdom of Navarre, or possibly Naples, by instructing their successors to surrender it, which each successor failed to do. He drew a ‘parallel for the Palatinate’, suggesting that once it was in Spanish hands it would not be relinquished.58
On 3 Mar. Wardour was named to confer with the Lords about drafting reasons to be presented to the king to break off the Spanish Match.59 On 19 Mar. he spoke in support of Sir Edward Conway I’s motion that the House declare that it would vote the king six subsidies and 12 fifteenths, arguing that this promise was ‘no greater engagement than before’. He tried to reassure his colleagues that it was not necessary to vote such a large sum immediately, merely to promise by ‘vote of the House’ to assist the king financially ‘in the pursuit of our advice’ should ‘the business require it’. He also pointed out that previous grants had been paid ‘not all at a time, but by yearly collections’. Moreover, he criticized those who wanted a detailed debate on the war, arguing that it was ‘preposterous’ to discuss the matter closely before they had leave from the king. His speech did not impress his colleagues, one diarist describing it as ‘to no purpose’, and the House resolved to vote a much smaller amount.60
Wardour appears to have attended the privileges committee, although he was not one of its members. When John Glanville reported on the Norfolk election dispute on 24 Mar. in favour of the election of Sir Thomas Holland and Sir John Corbett, Wardour protested that the details of the case had been omitted, and stated that he himself had thought that the return was invalid because the sheriff had refused a poll. He may have been acting in connivance with Glanville, who also opposed the return but had been overruled by rest of the committee, and with Coke’s support, he secured a ruling from the Commons for Glanville to give the details of the case.61 On 6 Apr. Wardour spoke in support of (Sir) Humphrey May, who had stated that all restitution bills should start in the Lords, claiming that Henry Elsyng, the clerk of Parliaments, had told him that the Lords had resolved to reject all such measures originating with the Commons.62
Wardour remained concerned to ensure that the laws against recusants were effectively enforced. When the Lords objected to a proposal of the Commons to petition the king to issue a Proclamation on the subject, Wardour complained that if ‘there be not some course taken’ by ‘some such ways’ it would be thought that ‘the same coldness and connivancy’ towards Catholicism continued.63 Anti-Catholicism may also explain why on 27 Apr. he moved for the abolition of licences for eating flesh in Lent to be included in the bill for the continuance or repeal of expiring statutes, but he was unsuccessful.64
During April Wardour, as an Exchequer official, was called upon to provide information during the impeachment of lord treasurer Cranfield (by now 1st earl of Middlesex). On 2 Apr. and 10 May he supplied the Lords with damaging information regarding Cranfield’s transactions.65 In addition on 22 May he complained in the Commons that Middlesex had collected the profits from the patent concerning the selling of wine in taverns without paying any rent to the Crown.66 On 1 May Wardour was appointed to the committee to consider the bill for rescinding Morgan’s Chancery decree, which had so exercised him in 1621.67 In addition he was also among those instructed to investigate the warden of the Fleet on 9 April.68 His position in the Exchequer presumably explains his appointment to the committees for bills concerning fees licenses for alienations (3 Mar.) and duties on coal (29 Apr.), as well as the committee to investigate the new impositions (9 April). In addition, on 4 May he and Sir Robert Pye, another Exchequer official, were instructed to report the profits the Crown had received from concealments over the last 40 years.69 He was also appointed to attend the conference with the Lords about the monopolies bill (7 Apr.), and to consider the bills for the preservation of fish (25 Mar.) and the sealing of writs (30 April).70
Wardour was re-elected in 1625, but made only two speeches and was named to the same number of committees. On 21 June he was among those appointed to supervise the House’s collective communion and, together with John Whitson, he seconded John Pym’s proposal for a petition to the king for a general fast, arguing that the need was even greater than in 1624 ‘in respect of the plague and other occasions.71 On 27 June he was named to consider the bill to restrain the granting of writs of habeas corpus.72 On 1 July, after Sir Edwin Sandys reported from committee that the new imposts on wines should be included as a grievance, Wardour proposed that the tax collectors themselves should be called to account ‘for nothing has come to the king.’ However, this suggestion does not seem to have been taken up.73 There is no evidence that he attended the Oxford sitting.
After this Parliament it is unknown whether Wardour again put himself up for Malmesbury, but worsening relations with the town may explain why he was not re-elected. During the 1620s he faced increasing difficulty in collecting the rents from his tenants in the borough. Citing ancient deeds, they claimed that their rents had originally been paid to the abbots of Malmesbury, that none in the town was sure at what level they had been set, and that Wardour’s attempts to increase them were questionable. The dispute was complicated by the loss of legal documents, which Wardour accused the ‘confederating’ tenants of withholding, and in 1628 he commenced legal proceedings against at least 30 of them.74
Wardour’s absence from Parliament in the late 1620s came at a particularly inconvenient time for him because he came up against one of the minor early Stuart revenue-raising schemes, this being to enable the Crown to confiscate the estates of intestate bastards. In late 1625 Wardour and one Ford were granted administration of the estate of Wardour’s father-in-law, William Bowdler, who had recently died leaving goods worth about £3,000. However, the attorney-general brought a suit in the Exchequer claiming that Bowdler had been illegitimate, and although Wardour and Ford denied this, he secured an order restraining them from administering the estate until the Crown’s rights had been resolved. The issue was still unresolved in 1628, when Wardour and other interested parties petitioned the Commons. The petition was read on 18 June and referred to committee, from which Selden reported six days later, when it was argued that the estates of bastards should be treated no differently from those belonging to anyone else. After the session was adjourned the Privy Council, perhaps mindful of the committee’s conclusions, and citing the uncertainty about Bowdler’s illegitimacy, rescinded the Exchequer order and left the settlement of the estate to the ordinary legal processes.75
During the 1630s Wardour purchased the lease of six acres in Soho, London, at an annual rent of £31, and secured a share in the lease of a waterpipe there from the 4th earl of Bedford (Sir Francis Russell*).76 Wardour Street, developed in the 1680s, took its name from his descendants.77 Wardour stood for Westminster in the elections to the Short Parliament in 1640, but was unsuccessful. There is no evidence that he stood again in the autumn.78 In 1641 he was implicated in the First Army Plot, intended to secure the release of the earl of Strafford (Sir Thomas Wentworth*).79 On 2 Jan. 1643 he received permission from the House of Lords to go to Oxford as part of a delegation to present the Westminster peace petition to the king, but he was stopped by order of the Commons three days later and placed in custody. He had absconded by 16 Feb., when the Commons ordered an ordinance to be drawn up providing for a substitute to execute his clerkship in his absence.80 Wardour went on to join the royalist Exchequer at Oxford, where, in addition to fulfilling his own duties, he temporarily also took on those of the auditor of the receipt, held by the parliamentarian Sir Robert Pye. However, since the one office was intended to control the other, he was obliged in November 1643 to relinquish the auditorship to Robert Long*, who held the reversion.81
Wardour died intestate in Oxford on 14 Mar. 1646, where he was buried in the chancel of All Saints.82 As his eldest son, Edward, had died July 1645, he was succeeded by his only remaining son, William. Edward had been joint clerk of Pells with his father since 1637, but the family’s continued control of the office was secured when, shortly after Wardour’s death, it was granted to William, who filled it again after the Restoration.83 On 26 Jan. 1647 administration of part of Wardour’s property in and around London was granted to William Wheeler†, possibly to secure it from sequestration by the parliamentarians. A year later a further grant, covering the rest of the estate was made to a creditor, but a third grant was made to his son William in 1656.84 No other member of the family subsequently sat in Parliament.
Ref Volumes: 1604-1629
Author: Henry Lancaster
- 1. St. Martin-in-the-Fields ed. T. Mason (Harl. Soc. Reg. xxv), 12.
- 2. Harl. 1174, f. 123; R.C. Hoare, Hist. of Wilts. ‘Frustfield Hundred’, 96; W. Phillimore and W. Whitear, Hist. Collections relating to Chiswick, 7.
- 3. Al. Ox.; LI Admiss.
- 4. Le Neve, Mon. Angl. i. 224-5; CD 1628, iv. 365; St. Martin-in-the-Fields, 39, 51, 172; Phillimore and Whitear, 7; 4th DKR, 188; Shaw, Knights of Eng. ii. 169.
- 5. CSP Dom. 1595-7, pp. 16, 356.
- 6. Exchequer Officeholders comp. J.C. Sainty (L. and I. Soc. spec. ser. xviii), 215; CSP Dom. 1641-3, p. 494.
- 7. CSP Dom. 1635, p. 319.
- 8. T. Rymer, Foedera, ix. pt. 2, p. 25.
- 9. CSP Dom. 1637, p. 546.
- 10. C181/2, f. 199v; 181/3, f. 157; Rymer, vii. pt. 4, p. 96.
- 11. C66/1988; 66/2859; C181/2, f. 331v.
- 12. C181/2, f. 222v.
- 13. APC 1613-14, p. 283.
- 14. Ibid. 1615-16, p. 483.
- 15. C181/2, f. 342; 181/4, f. 191; 181/5, ff. 101v, 142v.
- 16. C212/22/20.
- 17. SR, v. 63-4, 153.
- 18. C66/2376; Rymer, viii. pt. 2, p. 144; C193/12/2, f. 75v.
- 19. E178/7163, m. 5.
- 20. C181/5, f. 114.
- 21. C66/2745/16.
- 22. Northants RO, FH133.
- 23. CSP Col. E.I. 1622-3, p. 487; Cal. Ct. Mins. E.I. Co. 1640-4, p. 30.
- 24. VCH Wilts. xi. 169; xii. 56; Harl. 1174, f. 123.
- 25. HP Commons, 1558-1603, iii. 581-2; J.F. Merritt, Social World of Early Modern Westminster, 118; VCH Mdx. vii. 56, 74; L. Sanders, Old Kew, Chiswick and Kensington, 108-9; PROB 11/118, f. 75; J. Bowack, Antiqs. of Mdx. (1705-6), p. 48.
- 26. HP Commons, 1558-1603, iii. 581; CSP Dom. 1628-9, p. 109; Som. RO, DD/BW/2/146-7.
- 27. Exchequer Officeholders, 215-6.
- 28. E351/1950.
- 29. G. Aylmer, King’s Servants, 209; VCH Wilts. viii. 40; Wilts. IPMs ed. G.S. and A.E. Fry (Brit. Rec. Soc. xxiii), 144, 234, 344.
- 30. CSP Dom. 1603-10, p. 555; B.H. Cunnington, Some Annals of the Bor. of Devizes, i. pt. 2, pp. 45-6; ii. 142; VCH Wilts. x. 269.
- 31. C2/Chas.I/W18/8; 2/Chas.I/W37/43.
- 32. CD 1621, v. 510.
- 33. CJ, i. 555b.
- 34. Ibid. 574b; Nicholas, Procs. 1621, i. 226.
- 35. CJ, i. 590b; C.R. Kyle, ‘Attendance Lists’, PPE 1604-48 ed. Kyle, 194.
- 36. CJ, i. 587b.
- 37. CD 1621, iii. 99.
- 38. CJ, i. 528b, 529a; CD 1621, iv. 107; J.F. Merritt, Social World of Early Modern Westminster, 84, 119.
- 39. CJ, i. 568b.
- 40. Ibid. 573a, 616a.
- 41. Ibid. 536a.
- 42. Ibid. 590a.
- 43. Nicholas, i. 91.
- 44. CD 1621, iii. 163.
- 45. CJ, i. 601b, CD 1621, iii. 125.
- 46. CJ, i. 532b.
- 47. Ibid. 615b; CD 1621, iii. 214.
- 48. CJ, i. 555a.
- 49. Nicholas, ii. 242; CD 1621, v. 224; vi. 328-9.
- 50. SP14/156/15.
- 51. VCH Mdx. vii. 74; CSP Dom. 1637-8, p. 90.
- 52. E112/102/1358.
- 53. STAC 8/79/14; CSP Dom. 1639, p. 396. During this dispute Wardour rather strangely claimed to have been appointed Foreign Apposer in 1610, an Exch. office held by William Cholmley* from 1607 to 1627. Exchequer Officeholders, 84.
- 54. M. Prestwich, Cranfield, 378, n. 3.
- 55. CSP Col. E.I. 1622-4, p. 487; 1630-4, pp. 265, 298.
- 56. ‘Hawarde 1624’, p. 144; CJ, i. 671a.
- 57. Rich 1624, p. 2; CJ, i. 716a.
- 58. CJ, i. 676a; ‘Spring 1624’, p. 59; ‘Pym 1624’ i. f. 13v.
- 59. CJ, i. 676b.
- 60. Ibid. 743a; ‘Lowther 1624’, f. 38v; Holles 1624, p. 45.
- 61. ‘Spring 1624’, p. 161; ‘Pym 1624’, i. f. 40v.
- 62. ‘Nicholas 1624’, f. 114; ‘Spring 1624’, p. 176. This speech is attributed to Sir Edward Coke in CJ, i. 755b.
- 63. ‘Spring 1624’, p. 184.
- 64. ‘Pym 1624’, i. ff. 80v, 82.
- 65. LJ, iii. 286a, 364b; R. Tawney, Business and Pols. under Jas. I, 241.
- 66. ‘Spring 1624’, p. 236.
- 67. CJ, i. 696a.
- 68. Ibid. 769a.
- 69. Ibid. 678a, 760b, 778b, 783a.
- 70. Ibid. 695a, 749b, 757b.
- 71. Procs. 1625, p. 204
- 72. Ibid. 253.
- 73. Ibid. 285.
- 74. C2/Chas.I/W37/43; 2/Chas.I/W18/8.
- 75. CD 1628, iv. 360, 447; APC, 1628-9, p. 214; C.M. Gray and M.J. Cole ‘Bowdler’s case: the intestate bastard’, Univ. of Toronto Law Jnl. xx