Edward's next move was against clerical encroachments. In 1279 he compelled Archbishop Peckham to withdraw some legislation made in a synod called without the royal permission--a breach of one of the three great canons of William the Conqueror. Then he took the offensive himself, by persuading his parliament to pass the Statute of Mortmain (de religiosis). This was an act to prevent the further accumulation of landed property in the "dead hand" of religious persons and communities. The more land the church acquired, the less feudal taxation came into the royal exchequer. For undying corporations paid the king neither "reliefs" (death duties) nor fees on wardship and marriage, and their property would never escheat to the crown for want of an heir. The Statute of Mortmain forbade any man to alienate land to the church without royal licence. It was very acceptable to the baronage, who had suffered, on a smaller scale, the same grievance as the king, for when their subtenants transferred estates to the church, they (like their masters) suffered a permanent loss of feudal revenue. A distinct check in the hitherto steady growth of clerical endowments began from this time, though licences in mortmain were by no means impossible to obtain. Second Statute of Westminster. The great group of statutes that date from Edward's earlier years ends with the legislative enactments of 1285, the Second Statute of Westminster and the Statute of Winchester. The former contains the clause _De Donis Conditionalibus_, a notable landmark in the history of English law, since it favoured the system of entailing estates. Hitherto life-owners of land, holding as subtenants, had possessed large powers of alienating it, to the detriment of their superior lords, who would otherwise have recovered it, when their vassals died heirless, as an "escheat." This custom was primarily harmful to the king--the greatest territorial magnate and the one most prone to distribute rewards in land to his servants. But it was also prejudicial to all tenants-in-chief. By _De Donis_ the tenant for life was prevented from selling his estate, which could only pass to his lawful heir; if he had none, it fell back to his feudal superior. Five years later this legislation was supplemented by the statute _Quia Emptores_, equally beneficial to king and barons, which provided that subtenants should not be allowed to make over land to other persons, retaining the nominal possession and feudal rights over it, but should be compelled to sell it out and out, so that their successor in title stood to the overlord exactly as the seller had done. Hitherto they had been wont to dispose of the whole or parts of their estates while maintaining their feudal rights over it, so that the ultimate landlord could not deal directly with the new occupant, whose reliefs, wardship, &c., fell to the intermediate holder who had sold away the land. The main result of this was that, when a baron parted