 After the serjeants-at-law lost their exclusive right of audience in the Court of Common Pleas, it became customary to grant patents of precedence to a number of serjeants, giving them rank immediately after KCs already created and before those of subsequent creation.Mr Justice Phillimore was, on his appointment as a judge of the queen's bench division (in 1897) the only holder of a patent of precedence at the bar, except Serjeant Simon, who died in that year, and who was the last of the serjeants who held such a patent.In Canada, patents of precedence are granted both by the Governor-General and by the Lieutenant-Governors of the provinces under provincial legislation which has been declared "intra vires".