As for the castellans, the custody of some of the King’s castles habitually (though not necessarily) went with that of the shires in which they stood, but others were quite independent of the sheriffs. Mr. Turner in his second article (_Trans. Roy. Hist. Soc._, 3rd ser., vol. I, p. 247) says with reference to a document of 1220 (or 1221) relating to Bristol castle: “Here we may see another recognition of the claim that the castellans who had been appointed by John had the right to remain in office during the King’s minority.” The only “other” instance given by him of anything that can be construed into recognition of such a claim on the part of a constable holding a royal castle independently (as distinguished from a sheriff holding, in conjunction with his sheriffdom, certain castles within his shire) is the case of Sauvey, which Geoffrey de Serland was on 17th December, 1216, ordered to deliver to William of Aumale, but with a proviso that if he were unwilling to do so, he should come in person, or send a trusty representative, to hear the royal commands concerning the matter (_Pat. Rolls_, vol. i. p. 13; Turner, pt. II, p. 236). This seems to indicate that, as Mr. Turner says (_l.c._), “The Marshal evidently thought it prudent to give him [Geoffrey] a voice in the appointment of his successor”; but it proves nothing as to any claim of right on Geoffrey’s part having been recognized by the Marshal and his colleagues, or even put forth by Geoffrey himself. The Bristol document has in reality no bearing at all upon the point under consideration. It is a letter patent whereby, in December, 1220, or January, 1221 (see above, p. 175), the Justiciar and six other members of the royal Council became sureties for the King to Hugh de Vivonne, who was going to Poitou as seneschal of that country, that if Hugh should be recalled or should resign his office and return to England, “idem dominus noster rex restituet ei castrum Bristolliae sicut illud prius tenuit, vel assignabit ei aliam wardam in custodia alicujus castri vel terrarum ad valentiam _custodiae praedicti castri Bristolliae et terrarum quam habuit de ballio domini regis Johannis et postmodum de ballio dicti domini nostri regis Henrici_; quam custodiam castri Bristolliae et terrarum eidem domino nostro regi Henrico liberavit quando iter arripuit versus Pictaviam” (_Pat. Rolls_, vol. i. pp. 306, 307). The sentence which I have italicized, construed literally, should of course mean that Hugh had originally received the custody of Bristol castle, and of certain lands, by a grant from John, and that this grant had been renewed by Henry. But whatever may have been the case with regard to the other lands here referred to, this was not the fact with regard to Bristol. Until 19th September, 1219, Hugh de Vivonne was merely lieutenant constable of Bristol castle for Savaric de Mauléon; on that day he, acting in pursuance of Savaric’s instructions and for Savaric