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556 by a label, or else placed them in the first quarter of their shield. Consequently from this precedent a rule was deduced that it was permissible and correct to give a Royal quartering precedence over all others. The position of the Mowbrays, Dukes of Norfolk, as Earls Marshal no doubt led to their own achievement being considered an exemplary model. But it appears to have been overlooked that the Mowbrays bore these Royal Arms of Brotherton not as an inherited quartering but as a grant to themselves. Richard II. apparently granted them permission to bear the arms of Edward the Confessor impaled with the arms of Brotherton, the whole between the two Royal ostrich feathers (Fig. 675), and consequently, the grant having been made, the Mowbrays were under no necessity to display the Mowbray or the Segrave arms to bring in the arms of Brotherton. A little later a similar case occurred with the Stafford family, who became sole heirs-general of Thomas of Woodstock, and consequently entitled to bear his arms as a quartering. The matter appears to have been settled at a chapter of the College of Arms, and the decision arrived at was as follows:—


 * [An order made for Henry Duke of Buckingham to beare the Armes of Thomas of Woodstock alone without any other Armes to bee quartered therewith. Anno 13 E 4.]


 * Memorandum that in the yeare of the Reigne of our Soveraign Lord King Edward the iiijth, the Thurtein in the xviijtin day of ffeverir, it was concluded in a Chapitre of the office of Armes that where a nobleman is descended lenyalle Ineritable to iij. or iiij. Cotes and afterward is ascended to a Cotte neir to the King and of his royall bloud, may for his most onneur bere the same Cootte alone, and none lower Coottes of Dignite to be quartered therewith. As my Lord Henry Duke of Buckingham, Eirll of Harford, Northamton, and Stafford, Lord of Breknoke and of Holdernes, is assended to the Coottes and ayer to Thomas of Woodstoke, Duke of Glocestre and Sonne to King Edward the third, hee may beire his Cootte alone. And it was so Concluded by [Claurancieulx King of Armes, Marche King of Armes, Gyen King of Armes, Windesor Herauld, Fawcon Herauld, Harfford Herald].

But I imagine that this decision was in all probability founded upon the case of the Mowbrays, which was not in itself an exact precedent, because with the Staffords there appears to have been no such Royal grant as existed with the Mowbrays. Other instances at about this period can be alluded to, but though it must be admitted that the rule existed at one time, it has long since been officially overridden.

A territorial coat or a coat of arms borne to indicate the possession of a specific title is either placed in the first quarter or borne in