reclamation by the Crown. Since many of these religious orders provided charity, much of the local medical and social services were left in disarray. Statute of Uses The Statute of Uses was enacted in 1535, and was intended to end the "abuses" which had incurred in . It declared that any holder of a became the holder of the legal title of the ownership in fee simple. This voided the advantages of a . The feoffee to uses was bypassed. The had seisin. Henry VIII got his incidences back. The land owner lost the ability to will the land to heirs other than those in direct lineage. There could be no bypassing of heirs with a . This condition was modified in the Statute of Wills (1540). One of the effects of the Statute of Uses in executing the use, was to make a mere sale of land without feoffment (the formal public transfer) effective to pass the legal estate. The buyer became the owner by operation of the statute. It necessitated a public announcement of the intended sale to determine if the land had been surreptitiously sold to someone else. The Statute of Uses required a public registry of sale of land, later called the Statute of Enrollments. Lord Hardwicke wrote that the Statute had no real effect other than to add at most three words to a conveyance. He was referring to the doctrine that had become settled before his time: that the old use might still be effected despite the Statute, by a "use on a use". The Statute of Uses had been considered a great failure. It did not wipe out double ownership, legal and equitable, which has survived into the modern system of trusts. The preamble of the Statute went far in enumerating the abuses the system of uses had brought into play. The Statute did not, as had previously been suggested, try to remedy these abuses by declaring any uses void. It merely declared that the possession should be transferred to the use and that the should have the possession after such manner and form as he had before the use. In re Chudleigh's Case In re Chudleigh's Case was the first application of the Statute of Uses, and occurred fifty years after its enactment. This case was argued several times in front of several courts in England. It has been described as a