(3) _Fee-farm_ was the name applied to lands held in return for services which were neither military nor agricultural, but consisted only of an annual payment in money. The “farm” thus indicates the rent paid, which apparently might vary without limit, although it was long maintained that a fee-farm rent must amount at least to one quarter of the annual value. This error seems to have been founded on a misconstruction of the Statute of Gloucester.[67] Some authorities[68] reject the claims of fee-farm to rank as a tenure separate from socage; although chapter 37 of Magna Carta seems to recognize the distinction. ----- Footnote 67: See Pollock and Maitland, I. 274, n. Footnote 68: Pollock and Maitland, I. 218. ----- (4) _Frankalmoin_ is the tenure by which pious founders granted lands to the uses of a religious house. It was also the tenure on which the great majority of glebe lands throughout England were held by the village priests, the parsons of parish churches. The grant was usually declared to have been made _in liberam eleemosinam_ or “free alms” (that is, as a free gift for which no _temporal_ services were to be rendered).[69] In Scots charters the return formally stipulated was _preces et lacrymae_ (the prayers and tears of the holy men of the foundation for the soul of the founder). ----- Footnote 69: Littleton, II. viii. s. 133. ----- (5) _Grand serjeanty_ was a highly honourable tenure sharing the distinctions and the burdensome incidents of knight’s service, but distinct in this, that the tenant, in place of ordinary military duties, performed some specific office in the field, such as carrying the King’s banner or lance, or else acted as his constable or marshal or other household officer in the palace, or performed some important service at the coronation.[70] ----- Footnote 70: Littleton, II. viii. s. 153. ----- An often-quoted example of a serjeanty is that of Sir John Dymoke and his family, who have acted as the Sovereign’s champions at successive coronations from Richard II. to Queen Victoria, ready to defend the Monarch’s title to the throne, if questioned, by battle in the ancient form. Grand serjeanties were liable to wardship and marriage, as well as to relief, but not, as a rule, to payment of scutage.[71] William Aguilon, we are told by Madox,[72] "was charged at the Exchequer with several escuages. But when it was found by Inquest of twelve Knights of Surrey that he did not hold his lands in that county by military tenure, but by serjeanty of finding a Cook at the King’s coronation to dress victuals in the King’s kitchen, he was acquitted of the escuages." ----- Footnote 71: Littleton, II. viii. s. 158. Footnote 72: _History of Exchequer_, I. 650, citing _Pipe Roll_ of 18 Henry III. -----