a remainder, so this type of "remainder" tends not to be a problem when discussing property rights. Examples " and her heirs, then to " 's estate is not a remainder since a remainder cannot follow an estate held in fee simple absolute. " for life, then to " 's estate is a vested remainder since the remainder is given to an ascertained person () and there are no precedent conditions (such as "if is not married"). " for life, then to if reaches 21, and if does not reach 21 then to and 's heirs" 's and 's estates are both contingent remainders. While and are ascertained persons, the condition (reaching 21) implies alternative contingent remainders for both parties. Special remainder in peerages In the United Kingdom it is possible for a patent creating a hereditary peerage to allow for succession by someone other than an heir-male or heir of the body, under a so-called "special remainder". Several instances may be cited: The Barony of Nelson (to an elder brother and his heirs-male). The Earldom of Roberts (to a daughter and her heirs-male). The Barony of Amherst (to a nephew and his heirs-male). The Dukedom of Dover (to a younger son and his heirs-male while the eldest son is still alive). In many cases, at the time of the grant the proposed peer in question had no sons, nor any prospect of producing any, and the special remainder was made to allow remembrance of his personal honour to continue after his death and to preclude an otherwise certain rapid extinction of the peerage. However, in all cases the course of descent specified in the patent must be known in common law. For instance, the Crown may not make a "shifting limitation" in the letters patent; in other words, the patent may not vest the peerage in an individual and then, upon some event other than death (such as succession to a higher title), shift the title to another person. The doctrine was established in the Buckhurst Peerage Case (1876) 2 App Cas 1, in which the House of Lords deemed invalid the letters patent intended to keep the Barony of Buckhurst separate from the Earldom of De La Warr. The patent stipulated that if the holder of the barony should ever inherit the earldom, then he would be deprived of the barony, which would instead pass to the next