With regard to the castles a further question remains. Falkes de Bréauté in the “Complaint” which he addressed to the Pope in 1225, and which is preserved in the Barnwell Annals, speaking of the arrest of Peter de Maulay in 1221, says: “De qua captione non ante dictus nobilis evadere potuit quam ea castra quae sibi tam a domino Guala quam etiam a patre domini regis commissa fuerant restitueret, contra pristinum juramentum quod patri fecerat de non restituendis eisdem castris donec iste rex legitimae foret aetatis” (W. Cov., vol. II, p. 260). On this Mr. Turner (pt. I, p. 284) observes: “The castles, he says, were entrusted to Pierre as well by Guala as by King John. It would seem from this that although the castellans were not re-appointed on the King’s death by letters patent under the seal of the Earl Marshal, their castles were formally delivered to them by Guala. The statement is confirmed by a letter dated May 10th, 1220, from Pandulph, who succeeded Guala as legate, to Ralph de Neville the vice-chancellor, in which he asks him to send the form under which Guala delivered castles to their wardens (Shirley, _Royal Letters_, i. 117).” Pandulf’s words are these: “Item, formam sub qua dominus Gualo castra ad custodiendum tradebat nobis mittas, si ipsam habes, vel ab his qui sciunt diligenter inquiras, et quod inveneres nobis rescribas.” I venture to think that Mr. Turner’s suggested interpretation of these two passages is a little overstrained. The words of Falkes need not imply any formal act of delivery posterior to the one whereby Peter had originally received the castles to hold for John. Falkes’s “Complaint” is not a legal document, and we are neither obliged nor entitled to construe its phraseology as if it were such. If certain castles which John had committed to a certain man were left in that man’s custody by Henry’s guardians, they were practically committed or entrusted to him by the guardians as well as by John; and a reason why Falkes should bring Gualo’s name into the matter, rather than the name of the Marshal, is not far to seek. Falkes’s “Complaint” is a piece of special pleading addressed to a special person--the Pope--for the purpose of inducing him (as supreme guardian of his feudatary King Henry) to intervene in English affairs in behalf of the complainant Falkes himself; the case of Peter de Maulay being mentioned as an illustration of the ill-treatment which (according to Falkes) the leaders of the party now in power in England were meting out to faithful old servants of King John. In these circumstances it is perfectly natural that whatever sanction, whether explicit or tacit, was, at a time when these leaders were in a subordinate position, given by the highest authorities in the realm to Peter’s retention of the castles in his keeping, should be described as having been given by the Legate. Nor need the words of Pandulf bear any more definite meaning. The letter in which they occur was misdated by Dr.