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 sometimes upholding the validity of the Canonical impediments, and by sometimes refusing to recognize Papal dissolutions of marriage, could in many cases prove that the Elizabethan grantees had left no legitimate offspring.

Thus the lawyers found an ample scope for further proposed confiscations.

When the chief of Leitrim, Sir Teig O'Rourke, died in 1607 the legitimacy of his children was at once called in question, because it was alleged that their mother was really the wife of Sir Donnell O'Cahane.

The first move in the new policy of confiscation under pretext of law was made not in the midlands, but in the northern portion of County Wexford. A large portion of this territory seems to have been left to the Irish at the first invasion. In the fourteenth century the Irish of Leinster had elected as king a descendant of Donnell Kavanagh, illegitimate son of King Dermot MacMurrough, and he and his posterity had expelled the settlers from most of Carlow, all north Wexford, and such parts of Wicklow as they had occupied.

On the death of Cahir "Mac Innycross," who had been chosen king in 1531 none of his kinsmen could be found willing to assume the dangerous royal