of King William the Lion in 1180, regarding the holding of barony courts, it is provided that neither bishops nor abbots, nor earls nor barons, nor any freeholders (_libere tenentes_) shall hold courts unless the king’s sheriff is summoned, etc. Again, in a statute regarding justice and sheriff moots, we have barons, knights (_milites_), and freeholders (_libere tenentes_) classed together; and a statute regarding the mode of citation refers to persons cited to attend the moots of the justiciary shiref, baron, vavasour (that is, of one holding of a baron), or of any freeholder (_libere tenentis_) that has a court. Then a declaration regarding the freedom of the Church is made by King William at Scone, with the common consent and deliberation of the prelates, earls, barons, and freeholders (_libere tenentium_); and finally there is a statute by the same king that the earls, barons, and freeholders (_libere tenentes_) of the realm shall keep peace and justice among their serfs, and that they shall live as lords from their lands, rents, and dues, and not as husbandmen or sheep-farmers, wasting their property and the country with a multitude of sheep and beasts, thereby troubling God’s people with penury, poverty, and destruction; this curious statute showing not only the position of the _libere tenentes_ as proprietors, but that there was a tendency even at this early period to withdraw land from culture and convert it into pasture land.[304] Then in the Statutes of Alexander the Second there is one _de modo duelli secundum conditionem personarum_, in which reference is made to the _miles_ or knight, or son of a knight, or any _libere tenens_ or freeholder in _feodo militari_ or knight’s fee. Again, in another law, the king statutes that if any _miles_ or knight shall be indicted by inquest, he shall pass through an assize of good and leil knights, or of freeholders of heritage (_libere tenentium hereditarie_);[305] and their position is clearly indicated by a provision in the Quoniam attachiamenta, that any freeholder (_libere tenens_) whose tenement is by his infeftment free from all service, shall fall to a lady by reason of her terce, and unwittingly did service to her, shall not be liable in similar service to his superior.[306] This view of the position of the _libere tenentes_ as freeholders holding land under the thane or baron as sub-vassals of the Crown, is corroborated by a few charters which may be noticed. Thus Robertus de Keth, lord of the same and of the barony of Troup and Marischall of Scotland, grants certain lands within the barony of Troup to his son John de Keth, with the bondmen, bondages, native-men, and their followers, but reserving to himself the superiority and service of the freeholders (_libere tenentium_) of the lands of Achorthi, Curvi, and Hayninghill, lying within the barony of Troup. Again, Morgund, son of Albe, grants to his son Michael one davach of his land of Carncors in Buchan, to be held of himself in fee and