It was evident that the qualifications for voting could not long remain far wider in one class of constituencies than in another; that the franchise of the boroughs must, in time, be extended to the counties. This was done in 1884,[208:6] and the change more than doubled the county electorate. The franchise, therefore, is now substantially uniform throughout the United Kingdom, except that certain owners and leaseholders have a right to vote in counties, and that in some old towns the freemen still possess the suffrage. Inasmuch as most of the boroughs are included in counties, the occupier, householder, or lodger would be entitled on the same qualifying property to vote in both; and hence a man in a borough would have two votes at an election, while another man with the same qualification outside of the borough would have only one. To avoid this result it is provided that a man shall not be entitled to vote at an election for a county in respect of the occupation of a dwelling-house, lodging, land or tenement in a borough;[209:1] but he may vote in the county on account of the ownership of land in a borough which he does not occupy, or on account of land which he both owns and occupies if he occupies other land in the borough sufficient to qualify him there.[209:2] [Sidenote: The Existing Qualifications.] Although the franchise is now substantially uniform, it is not exactly the same for the different parts of the United Kingdom; nor is it by any means simple. The latest acts have not codified the law. It must still be sought in many statutes, whose provisions are so complicated, and often obscure, that they can be understood only by studying the interpretation put upon them by the courts. The reader who wishes to ascertain the law on a special point must refer to treatises upon the subject, such as Rogers on "Elections." It will be enough for our purpose to summarise the various franchises as they exist to-day. [Sidenote: Property.] There are two qualifications which are not universal. One of these, relating to property rights in land, applies only to counties, and to some extent to boroughs which are counties in themselves.[209:3] It confers the right to vote on owners of land[210:1] of forty shillings yearly value, who hold an estate of inheritance; or who hold an estate for life, and are in actual occupation of the land, or have acquired it by some means other than purchase, or whose land is of five pounds clear yearly value.[210:2] Under this franchise come, also, the leaseholders of land of five pounds yearly value if the original term was not less than sixty years, and fifty pounds value if the term was not less than twenty years.[210:3] The corresponding qualifications for Scotland and Ireland are slightly different in their conditions and in the values required. [Sidenote: Freemen.]