A man may be a peer by prescriptive right, by creation, or by hereditary right; and peers are created in two ways, either by the ancient mode of writ of summons, or by letters-patent. At the present day, persons are almost invariably ennobled by the latter process. For if a person summoned by the sovereign to attend parliament as a peer, should die before he can take his seat, the peerage so created would fail, and would, therefore, not descend to his heir. On the other hand, a peerage created by letters-patent descends to the heir of the person so ennobled under any circumstances. The writ of summons, however, is not obsolete, and is used when, for some reason, it is deemed desirable to call the eldest son of a peer to the Upper House of parliament during his father’s lifetime. In this case, whether the person summoned does or does not take his seat, is obviously immaterial, so far as the descent of the father’s peerage is concerned, because, if the eldest son has a son, the grandfather’s title will descend to him, if he outlives his grandfather. When the eldest son of a peer is summoned to the Upper House in his father’s lifetime, he sits by the baronial title of the peerage. Thus, the Earl of Albemarle, who is also Viscount Bury and Baron Ashford, being, in 1876, advanced in years, his eldest son, Viscount Bury, was summoned to the House of Lords, not, however, as such, but as Baron or Lord Ashford. In the creation of a peerage, the limitations—that is to say, the arrangements as to how it shall descend—may be analogous to the limitations of real estate; for a title is just as much a hereditament—which simply means something that can be inherited—as an acre of land, except that the latter is termed in law a corporeal or tangible hereditament, and the former an incorporeal hereditament. Accordingly, a title may be _in fee_, in which case it will descend to the heirs-general of the first holder; _in tail_, male or female, when it descends to the eldest son, &c., or his brothers and their eldest sons, &c.; or it may be, as we have seen, _for life_, when, at the death of the holder, it expires.