Thus it is clear the possession of an estate by inheritance is created only by a person being heir to it; and the mere purchase of it, though it vests the fee simple in him, can but make him the _assign_ and not the _heir_. The nomination (as it would be in the case of a purchase) of an heir to succeed to the inheritance, has no place in the English law; the maxim being "Solus Deus hæredem facere potest, non homo;" and all other persons, whom a tenant in fee simple may please to appoint as his successors, are not his heirs but his assigns. (See _Williams on the Law of Real Property_.) RUSSELL GOLE. MR. HALLIWELL is perfectly right in his opinion as to the expression "heretofore the _inheritance_ of William Shakspeare." All that that expression in a deed means is, that Shakspeare was the absolute owner of the estate, so that he could sell, grant, or devise it; and in case he did not do so, it would descend to his heir-at-law. The term has no reference to the mode by which the estate came to Shakspeare, but only to the nature of the estate he had in the property. And as a man may become possessed of such an estate in land by gift, purchase, devise, adverse possession, &c., as well as by descent from some one else, the mere fact that a man has such an estate affords no inference whatever as to the mode in which he became possessed of it. The authorities on the subject are Littleton, section ix., and Co. Litt., p. 16. (a), &c. A case is there mentioned so long ago as the 6 Edw. III., where, in an action of waste, the plaintiff alleged that the defendant held "de hæreditate suâ," and it was ruled that, albeit the plaintiff had purchased the reversion, the allegation was sufficient. In very ancient deeds the word is very commonly used where it _cannot_ mean an estate that has descended to an heir, but _must_ mean an estate that may descend to an heir. Thus, in a grant I have (without date, and therefore probably before A.D. 1300), Robert de Boltone grants land to John, the son of Geoffrey, to be held by the said John and his heirs "in feodo et hæreditate in perpetuum." This plainly shows that _hæreditas_ is here used as equivalent to "fee simple." I have also sundry other equally ancient deeds, by which lands were granted to be held "jure hæreditaris," or "liberè, quietè, _hæreditariè_, et in pace." Now these expressions plainly indicate, not that the land has descended to the party as heir, but that it is granted to him so absolutely that it may descend to his heir; in other words, that an _estate of inheritance_, and not merely for life or for years, is granted by the deed. S. G. C.