still operate (though in name only, the portions being united into a single incumbent). Patrons in need of ready cash might seek to capitalize on the value of their advowsons by selling turns of presentation; either the next turn singly, or alternate future turns as a long-term asset. Encroachment of canon law Canon law, however, by the 12th century, decreed that the right to present belonged to the saint to whom the church was dedicated and that only ecclesiastical courts could rule on cases involving advowsons. King Henry II's Constitutions of Clarendon held otherwise, and after Thomas Becket's murder, the king once more ruled that cases involving advowsons should be heard by secular courts. Effect of the Reformation In the Reformation in the 16th century, the Dissolution of the Monasteries led to the transfer of much monastic property to laymen, and with the properties passed the advowsons which the monasteries had held: thus creating a large group of lay patrons (see impropriation). In 1603, there were an estimated 3849 livings in the hands of lay impropriators out of a total of 9284. There were also many lords of manors and patrons of appurtenant livings who were recusants, that is to say who remained Roman Catholics and refused to adopt the new Protestant religion. Such patrons were disbarred from making presentations by the Presentation of Benefices Act 1605 (3 Jac. 1 c 5), which transferred the right for the time being to the Universities of Oxford or Cambridge according to the geographical location of the parish. The university was allowed to assign this right to a third party adherent to the new religion, for consideration or otherwise. Legal status Legally, advowsons were treated as real property that could be held or conveyed, and conversely could be taken or encumbered, in the same general manner as a parcel of land. Advowsons were among the earliest incorporeal hereditaments, and often held in fee tail. Litigation (enabled in the temporal courts after the Reformation), on the basis of an advowson was somewhat specialized, with unique forms of action inapplicable to other realty, such as the writ of quare impedit, by which a patron sued a bishop in support of his presented candidate, alleging unreasonable hindrance to succession to a benefice. Following reforms of parish administration in the late 19th century (principally the imposition of secular parishes and wider county and district authorities), the advowson