CHAPTER THREE Thomas Littleton

The motto of Sir Thomas Littleton, Justice of the Common Pleas from 1466 until his death in 1481, was “UngDieu et UngRoU One God and One King—appropriately enough, in the Anglo-Norman French become Law French in which Littleton wrote his Tenures.

Littleton's motto might just as well have been “Ung Droict et Ung Livre,” One Law and One Book. The One Law was the common law of England, particularly the law of property, of which Littleton demonstrated a peerless mastery in his One Book, Les Tenures de Lyttleton.³ For upon that mastery and that book was built the undying fame of Thomas Littleton, as well as the English-speaking world's understanding of the structure and much of the dynamic of its property law for some three and one-half centu­ries.

Littleton’s Tenures was a prodigy, a book that rated as a genuine classic within a few years of its publication.

Littleton’s burgeoning popularity in the last three-quarters of the six­teenth century was closely connected with that remarkable phenomenon, termed “the education of the gentry,” which began just before mid-century and continued until the civil war in the 1640’s. It became the vogue for young gentlemen of the landed aristocracy (or those who aspired to join the landed aristocracy) to be sent in their early teens to one of the univer­sities for a few years, and afterwards for a year or two to study at one of the four Inns of Court.

How did this glut of more-or-less serious young men learn that prop­erty law which was, if anything was, the object of their sojourn at the Inns? Principally, by reading Littleton’s Tenures. The Tenures was the only text on the subject, it was relatively small (and therefore relatively cheap), and it had more direct relevance to legal pedagogy than almost everything else that went on at the Inns. (The semi-annual readings, lectures on statutes by senior barristers, could be enlightening; but these could be too erudite for anyone but the most dedicated apprentice-at-law.) Had there been no market for Littleton other than the crowd of gilded youth on the western fringes of London, the Tenures would still have been a best-seller. Littleton’s popularity reflected a readership that was other, and broader, than merely professional and learned.

The waning of Littleton’s popularity also reflected the student market.

One young student of the law at Littleton’s old Inn, the Inner Temple, in the 1570’s, appears to have taken more than mere pains to digest the Tenures and to bring it up to date. He was impelled by much seriousness of purpose, possessed of a vigor that would still drive him even in his eight­ies, and given to a nostalgia for time and place that moved him to identify with the old judge. Master Edward Coke of Norfolk began in the 1570’s that close familiarity with Littleton’s Tenures which, a half century later, is­sued in his own magisterial renovation of Littleton’s classic.

Littleton mixed not onely with [Year] booke cases and many titles of the lawe intermixed therewith, but with many reports of cases in the raigne of Queene Eliza: before the 32 yeare [1589-1590] of the same Q: with a Cover of Crimson Sattine curiouslie imbrodred with gold silver and silke and over that a Cover of Crimson damaske. / in 8°./ ⁹

This “Littleton mixed” was the first-fruits of Coke’s assiduous redactal ef­forts. The full harvest, in 1628, would be the publication of The First Part of the Institutes of the Laws of England: or a Commentary upon Littleton, Not the Name of the Author only, but the Law It Self—the book better known and forever renowned as Coke upon Littleton.

If by the 1620’s the Tenures looked increasingly moribund, Coke gave the work a new lease on life. He supplied as a thick overlard on Littleton’s spare text a discrete commentary on Littleton’s scholarship by the addition of cases from the Middle Ages going to support Littleton’s citationless as­sertions. None in his age (and possibly none since) commanded like Coke the Year Book erudition of medieval common law. And none before him used the Year Books as if they were “reports” in the modern sense in which Coke’s own volumes of reported cases were reports, sets of substantive prec­edent that counsel would be expected to follow and with which (the formi­dable Lord Chief Justice intended) future courts could square their judg­ments. The first eleven volumes of Coke’s Reports were published between 1600 and 1615.¹⁰ Coke cited his Reports prominently in his Commentary upon Littleton. That is less important than the fact that Coke’s Reports had already begun to revolutionize the way lawyers looked at cases, the purpose they found for cases, and the dawning realization that in cases was to be found the law.¹¹ By the time he published Coke upon Littleton, Coke had already conditioned lawyers and students of the law to look to cases: old cases, new cases, in context, out of context, to the point, irrelevant, it didn’t make much difference.

Coke also rescued Littleton's Tenures from falling into a desuetude caused by what was not in the text. His commentary supplied the bulk of the developments since Littleton's day which any lawyer in the 1620's had to master. A glance at the index to Coke's Commentary will testify how considerable the new matter is.¹² Even where one might least expect it—in part because many connections that Coke drew were tenuous, tangential, or eccentric—new matter is inserted, so much that in the end the text cov­ers with a remarkable degree of completeness developments which had no origins in or connection with the law of Littleton's day. Very little is missing which any assiduous student of Coke's day would have needed.

Alas, the commentary did in fact presuppose a very assiduous student indeed. Coke in his Preface, with an earnestness which is genuinely mov­ing, commends his labors to “all students of the law in their beginning of their study”¹³ In his youth at the Inns, even though he had arrived at Temple Bar on his horse with £10 in his purse, a rapier, and a diamond ring inscribed “O Prepare,” Coke had bent himself to learning rather than to lewd boisterousness.¹⁴ Perhaps the old jurist had forgotten how gruel­ing had been the round of scholarship. For more than two centuries, the myriad students of the law who were compelled to plow through Coke upon Littleton complained bitterly over the laminations of learning in the volume—but seldom was the criticism aimed at Littleton's contribution. Sir James Fitzjames Stephen showed the Victorian exasperation of a work­ing jurist and devoted codifier when he wrote, “A more disorderly mind than Coke's... would be impossible to find.”¹⁵ Sir William Holdsworth evinced a starchy Edwardian disdain in characterizing the work as “a le­gal encyclopedia arranged on no plan except that suggested by the words and sentences of Littleton.”¹⁶ Holdsworth's successor as the dean of Eng­lish legal historians, T. F. T. Plucknett, preferred English understatement: “extremely discursive, but full of valuable information.”¹⁷ Percy Winfield, Holdsworth’s contemporary, suggested diplomatically that Coke “was overwhelmed by the learning he possessed.”¹⁸ Perhaps the best balance was struck by Sir John Baker:

Coke shoveled out his enormous learning in vast disorderly heaps, piled around Litteton’s Tenures to form a phrase by phrase gloss on the text. He delighted in wandering off at tangents, and in doing so covered many aspects of the com­mon law which Littleton never hinted at. Coke seems to have been oblivious to the disorder, but the reader can easily forgive him. He wrote like a helpful old wizard, anxious to pass on all his secrets before he died, but not quite sure where to begin or end.¹⁹

With subsequent editions the shoveling of learning was not, of course, entirely Coke’s work. The edition that is probably best-known and most widely consulted, the eighteenth edition of 1823, piles on the learning of Coke’s two most eminent successors as legal scholars, Sir Matthew Hale, Chief Justice of the King’s Bench 1671-1676, and Heneage Finch, Earl of Nottingham, Lord Chancellor 1674-1682. Hale and Nottingham had not­ed-up Coke as Coke had noted-up Littleton. To these contributions were added the antiquarian-historical labors of Francis Hargrave and Charles Butler, stalwarts among eighteenth-century scholars. The heap is high, the weight of learning very heavy.²⁰

For the reader already familiar with Coke upon Littleton, this criticism may perhaps do no more than confirm established frustration. The author, having had to cope professionally with Coke upon Littleton for four decades, has himself used strong language, thought dark thoughts, and foundered in deep despair. He finds consolation in the practical counsel of Coke him­self. The reader should begin by reading Littleton’s text, Coke directed, then read it again, understand it thoroughly, and only then, finally, read the commentary:

And no more any one time than he is able with a delight to bear away and after meditate thereon, which is the life of reading.... And albeit the reader shall not at anyone day (do what he can) reach to the meaning of our author, or of our Commentaries, yet let him no way discourage himself, but proceed; for on some other day, in some other place, that doubt will be cleared.²¹

Following Coke’s advice, the reader can appreciate one of Coke’s maxims elsewhere: “Nemo aliquam partem recte intelligerepotest antequam totum per legit'”’ None can properly understand a part until he has read the whole.²²

About the life of Thomas Littleton very little is known and not much more is likely to be discovered. Littleton was born about in 1422 in Worces­tershire near Birmingham, into a family of the minor gentry. His mother came of better lineage than his father, and consequently Thomas took her maiden name for his surname. There is no evidence that he went to either Oxford or Cambridge, and it is very unlikely that one inclined toward a career in the common law would have done so in the 1430’s. Tradition has it that Littleton was a student at the Inner Temple, and that seems probable. We know that around 1540 he gave a reading on the famous property stat­ute De Donis Conditionalibus (Westminster II, c.ι, 1285) at the Inner Tem- ple—indeed, he was the Inn’s earliest recorded reader.²³ At about the same time he became recorder of the city of Coventry in Warwickshire (this also endeared him to Coke, who himself served as recorder of Coventry). His professional rise was rapid if not meteoric: serjeant-at-law in 1453, King’s Serjeant in 1455, and Justice of Common Pleas in 1466. He enjoyed the distinction of being instituted a Knight of the Bath in 1475 at a noble and royal conclave. He made his will on August 22, 1481, died the next day, and was interred in a handsome tomb in Worcester Cathedral.

What moved Littleton to set down at the end of a long and distin­guished career at the bar and on the bench such a comprehensive treat­ment of property law containing so much recondite matter? Following the last pages of his treatise (Section 749), he begins a short epilogue with the words, “Now I have made to thee, my sonne, three books.”²⁴ This may refer directly to his second son, Richard, who became an eminent barrister of the Inner Temple.²⁵ In the late 1470’s, when Littleton wrote the Tenures, Richard may already have been a student at the Inner Temple. Yet there is evidence that Littleton meant the work for more eyes than Richard’s. There are three early manuscript copies (none of which can be termed the origi­nal) of the Tenures in the Cambridge University Library. One has a note that it was bought in St. Paul’s Churchyard, London, on 20 July 1480, a little over a year before its author’s death. That the book went to the printer as early as 1481 indicates that though Littleton addressed his book to one young apprentice-at-law, it had circulated sufficiently in manuscript to ap­peal to others.

Littleton’s graceful epilogue also testified to his method as well as to his didactic purpose:

And know, my son, that I would not have thee beleeve, that all which I have said in these bookes [the three Books of the Tenures] is law, for I will not presume to take this upon me. But of those things that are not law, inquire and learne of my wise masters learned in the law. Notwithstanding albeit that certaine things which are moved and specified in the sayd bookes, are not altogether law, yet such things shall make thee more apt, and able to understand and apprehend the arguments and the reasons of the law, etc. For by the arguments and reasons in the law, a man more sooner shall come to the certaintie and knowledge of the law. Lexplus laudatur quando ratione probatur [the law is most praiseworthy when it is consonant with reason].²⁶

This surprising exhortation, with its elliptical playfulness, easily escapes the serious student mining through the Tenures. It has been overlooked. Worse, Coke's commentary upon Littleton's text, with its perennial hobby­horse riding of one of the commentator's favorite themes, “reason of law,” overshadows and obscures what Littleton meant by reason. Littleton's ex­hortation is a caveat. He warns the reader that what he offers in the work is not a compendium of the established law of property, but rather a dia­lectical analysis of the principles upon which that law is founded. Most significantly, it is a dialectical analysis of the principles upon which the law ought to be founded.

This normative concern expressed by Littleton was, in the three and one-half centuries between Bracton and Coke, a rarity largely unchallenged by other lawyers and law-books. Fortescue's De Laudibus Legum Angliae (c. 1470) and Christopher St. Germain's Doctor and Student (c. 1530) are honorable exceptions. Many have given due credit to Littleton's lonely ac­complishment in having written a book on law at all in an age when law­book meant that potpourri, the Year Book. But they fail to appreciate the significance of his fundamental jurisprudential concerns. Even the astute T. F. T. Plucknett missed the large contribution of Littleton. Regretting the deepening darkness of common-law literature in the later Middle Ages, a space lighted only by Littleton's candle, Plucknett noted:

Beside Littleton there is nothing whatever which can be called a law book, how­ever feeble, to represent the professional writing of his age. The Year Books alone remain, and from that precariously sustained series we learn enough to show that the law was in fact developing steadily and usefully according to its own queer lights.²⁷

None knew better than Littleton how queer were the lights of the law in his age. Alone among the lawyers of his time, he sought to reduce the oddi­ties to ordinaries, capricious rule to rational order, peculiarities in law to jurisprudential generalities.

Of course Littleton started with the law that was. What he chose to emphasize, however, were those features of existing law—doctrines would be too strong a term for them—which he believed most amenable to devel­opment to jurisprudential ends. It was no accident that it is in Book Three that Littleton carefully but vigorously undertook the enterprise of rational­izing and even refashioning English property law. Indeed, Book One on es­tates and Book Two on tenures and the services and incidents pertaining to tenures were preparatory to Book Three. The first two Books were clearly intended as a necessary foundation, based upon the existing learning of the fourteenth century, the “Old Tenures.”²⁸ Littleton saw them as the predicate for a bold departure in property law.

From this perspective, the putative sins of omission and the puzzles with which later scholarship has taxed Littleton either disappear or appear explicable. That there were few citations to cases in the Tenures (and the ones that appear, even wrong ones such as that in Section 420, apparently were interpolated by later editors) has been accounted by many a mystery in a jurist who himself figured prominently in the Year Books during his quarter-century on the King's Bench. However, quite aside from the fact that the Year Books were not “reports” and that no lawyer of the era would have used them as such, the didactic ends of Littleton did not require au­thority. Each short Section was an assertion posed by putting a case.²⁹ It made no difference for analytical purposes whether the case was real or hy­pothetical; it made even less difference for the reader to know whether the case was real or not. If Littleton thought the assertion was open to ques­tion, he would put the arguments for and against it, sometimes concluding as to the assertion's validity, sometimes leaving the question unresolved. It was reason, not judicial pronouncements that determined the issue. Little­ton did not presume to argue that “all which I have said... is law.” His epilogue is a good confession and avoidance.

A much more substantive omission has been charged against Littleton by Holdsworth, who, focusing on Section 364, wrote, “There is no hint either that unbarrable entails are things of the past.”³⁰ Unbarrable entails were not things of the past when Littleton wrote, despite the conventional wisdom that Taltarum^,s Case (1472) made them so. Littleton was indeed one of the two Common Pleas judges in Taltarum who, by accepting that a third party—not the donor or his heir—might be a sufficient single voucher to warranty to bar an entail, pointed the way to the device that would a half­century later make “unbarrable entails... things of the past.” But Littleton would have earned credit for clairvoyance had he maintained in 1480 that all entails were barrable. There is no indication that he would have desired free barring of entails, because the use of the collusive common recovery to bar entails in his day was primarily to condition the rigor of almost two centuries’ interpretation ofDe Donis Conditionalibus in order to allow reset­tlement rather than to disinherit issue.³¹ Indeed, it is not difficult to see why the learned reader on De Donis Conditionalibus at the Inner Temple about 1450 would three decades later still respect the thrust of that old statute’s purpose, to give effect to the wishes of the donor according to the express words of his grant. If in Section 364 Littleton posited a right of entry by a donor or reversioner to enforce a condition of an entail against alienation by a tenant in tail or his heirs, he did so because of the positive value of the old statute, not because he was breasting a wave of new doctrine and new practice which had already washed away De Donis. That wave was only a ripple in 1480.

It is that same sense of conservative probity that moved Littleton in Sections.721-723 to deny the validity of “all such [contingent] remainders in the forme” set down in Section 720. This has been construed as repre­senting the denial of the validity of all contingent remainders. Even Coke appears to have mistaken the matter, for he was obviously much discom­fited by an assertion which by 1550 had crashed in flames; his summary of these Sections is disingenuous.³² Later scholars have been merely puzzled that Littleton could have denied the validity of what ultimately became for a season a perfectly acceptable (when bounded by rules against abuse) fu­ture interest. In Littleton’s day one kind of contingent remainder was ad­mitted by Common Pleas, but all others were discouraged if not damned for sound reasons of law and, perhaps, policy. The one allowed was a gift to the heirs of a living stranger, provided the stranger died while the donor was yet alive. The objections to contingent remainders in the late fifteenth century were centered on three interconnected, doctrines of the common law: that there could be no abeyance of seisin (that is, there must always be a feudal tenant); that a living man had no heir; and that the word “heirs” was a word of limitation, not purchase, and thus an heir must claim by descent rather than by grant. The example above was unobjectionable be­cause it was not in breach of any of these doctrines. There was no abeyance of seisin since seisin was in the donor until the contingent-remainderman heir took it; when the contingent-remainderman took, he was by definition the heir of his dead ancestor; being the heir of a stranger, the contingent­remainderman could not take from the donor by descent. The instance pos­ited in Section 720 was clearly objectionable and it is hard to fault Littleton for roundly condemning it. As to the validity of contingent remainders in general, we do not know what Littleton thought. If he had serious qualms about them, and we might suspect that he did, those qualms were shared by his brethren. It was perfectly in keeping with his normative concerns that he would find contingent remainders perilous to the law's integrity. They had a fraudulent odor to them (they could cheat the lord of his feudal inci­dents) and they were a potentially dangerous obstacle to liberal alienability. From the vantage point of a century later, whatever misgivings Littleton might have had would have proven well-founded, for the contingent re­mainder was a loose cannon on the law's gun-deck—a concept that took on a limited usefulness only after the best efforts of many judges, including Coke, to lash it down.

Finally, why did Littleton, who had made grants to feoffees to such uses as he should appoint by his will, have so slighted that portentous develop­ment, the use, that apparently threatened to overpower the common law of real property?³³ On the face of it, Littleton appears to have largely ignored uses. Section 115, touching uses, was a later interpolation and not Littleton's work at all. Section 296 dealt with active uses, which posed no challenge to the common law. Section 352 involved uses to convey, a common device that enabled a tenant in fee simple to convey a lesser estate to himself by the Chancellor's intervention if necessary, something that could not be done directly at law. Sections 462-463 raised issues growing out of the employ­ment of uses to devise realty by will, the major and still expanding function of uses at the time. In Section 499 Littleton raised the important issue of the effect of a tortious enfeoffment to uses by a disseisor countered by a release of real actions at common law to render the disseisor vulnerable to a statutory action.

Littleton's slight is more apparent than real. First of all, he discussed the principal kinds of uses employed at the time he wrote. Secondly, proper to his enterprise, he dealt with uses according to their impact upon the com­mon law of property, not as matters of concern themselves. Lastly, Littleton was doubtless aware of what recent scholarship now enables us to appreci- ate—that is, the extent to which uses were becoming a species of property increasingly subject to legal rather than mere equitable interpretation and thus on the way to becoming subject to the jurisdiction of the common-law courts. This development had already begun by the time Littleton wrote. It would be stimulated by a statute passed three years after his death that explicitly gave jurisdiction over certain uses to common-law courts. It ter­minated in 1536, with the Statute of Uses, which destroyed the classical uses fashioned by the length of the medieval Chancellor's reach and loosed a swarm of mischievous doctrines in the common law of property.

Until very recently our received learning saw uses as the shock-troops of a vital, expanding, liberating system of “equity,” challenging a rigid, os­sified, and decadent common law. In the nineteenth century, when Charles Dickens was visiting derision upon Serjeant Buzfuz and Benthamite re­formers were visiting wholesale statutory reform upon the common law, equity was vested with almost magical or at least mythopoeic properties— hailed as redeeming, liberating, and cleansing. Ironically, this was the mo­ment when equity was about to be absorbed finally into the common law and its importance, with that of all doctrines bound up with real property, reduced to a shadow of its former self in an industrial and commercial age. But the myth of “equity” was safe and secure in the next generation of le­gal scholars. Holdsworth evinced an almost chiliastic fervor in describing Littletoifs treatment of the law of real property as riven with complications growing from the “enthusiasm of the legal profession for the technicali­ties of a vicious system of procedure” and “the lawlessness of the age,” a “savagely litigious age.” Holdsworth went on to bemoan not only the fact that the land law was under the “incubus” of the “barren technicalities of a worn-out system of procedure,” but also that unfortunately the “incubus [had been] removed, not by the clean and incisive process of direct legisla­tion, but by piecemeal changes and improvements introduced by the legal profession.”³⁴

Littleton’s silence on procedural matters, which were after all largely irrelevant to his substantive-law emphases, maintains its silence in the face of Holdsworth’s purplish criticism. Littleton knew, though, what Holds­worth would probably not have believed had he seen it: that for all of the activity of the great ecclesiastical chancellors of the late Middle Ages, the chancellors had not fashioned a system of equity, and that the singular (and single) device the chancellors had nurtured and protected, the use, was be­ing pared away to destruction in the later fifteenth century by a resurgent common law of property. While Holdsworth vaunted the “clean and inci­sive process of direct legislation” to effect legal reform, there was never a cleaner or more incisive act than the Statute of Uses of 1536. The misfortune of the way in which the incubus of uses was removed lay precisely in the fact that it was by legislation, rather than by the piecemeal changes of lawyers. The act was fatally flawed. By “executing” uses (converting the beneficiary’s equitable interest into a legal estate), rather than by absolutely prohibiting the employment of uses in conveyancing, the Statute opened the common law of property to all of the anomalous interests which unsystematic devel­opment under ecclesiastical chancellors had spawned. Later generations of legal scholars, enamored of “equity,” failed to see that if uses were a cure for the ills of the common law of property, it was worse than the disease. The only thing worse than both was the Statute of Uses.

Littleton may have chosen to underemphasize uses because he suspect­ed, with reason, that they had little future per se. Instead, he concentrated his greatest efforts on those features of property law which appear to us dreadfully archaic and doomed to such radical reduction as to lose almost all importance in the following two centuries: descents which toll entries, continual claims, discontinuances, warranties, remitters, releases and con­firmations. These subjects comprised some 60 percent of Book Three, consisting of Chapters 6-9 and 11-13 of that Book. Commentators who dismiss such detailed treatment as an egregious waste of effort, mere slav­ish adherence to the shackles imposed by the “technicalities of a vicious system of procedure,” should note that in these chapters Littleton was at his creative and normative best. In Littleton’s day, the common law, for all of its procedural shortcomings, had reached the point when the true owner (or more correctly, the claimant with the better title) was recognized as the fit subject for protection against the tortious disseisor and the disseisor’s feoffees. Another way to put it is, that by the end of the fifteenth century, the common law had finally slipped the shackles first imposed upon it in the twelfth century (albeit for commendable reasons and to admirable ends) by the possessory assizes and the emergence of the doctrine of seisin. This was a considerable advance, and it had been worked largely by weighing some of the doctrines treated in these Chapters against others—continual claims against descents which toll entries, warranties against discontinu- ances—as well as by new emphases in other Chapters on safeguarding the rights of the true owner. This was indeed complicated, torturously so; it was over-fine, and it displayed some of the worst procedural features of the law. Nonetheless, from the vantage point of a jurist and jurisprudence dedi­cated to both instructing in the law and providing a rational, even scientific, basis for change in the law, it was not a misplaced emphasis.

How important this was is not yet fully appreciated. The doctrines and features of the subject are only now being opened in new scholarship. Le­gal historians of the immediate post-Maitland generation largely ignored the subject (and the period as a whole) in favor of the classical formative common law of earlier centuries. With some few exceptions, most notably S. F. C. Milsom, those historians who have ventured beyond the magic year 1307, when Edward I died, have tended to leap from the fourteenth century to the sixteenth. Littleton’s century, and so Littleton’s learning, conclusions, and purposes, are only now beginning to receive the degree of attention that has revealed so much about the early common law.³⁵ Until such work is done, we should be leery of standing too adamantly upon Coke's maxim, “Stabit praesumptio donec probetur in contrarium” A presumption will stand good until the contrary is proved.³⁶

What is known—and not merely presumed—about Thomas Littleton's contribution is that his arrangement of the tenures and the estates of medi­eval English law passed into the entire literature of the law and the history of medieval English institutions. What none can deny is that his Tenures was a masterly summation of English property law as that law stood on the eve of far-reaching adaptations. What all appreciate is that his book was a rose of rational analysis and jurisprudential concerns in a thicket of how-to and what-was-done works. Littleton's achievement was enormous, if for no other reason than that the Tenures demonstrated that the common law of property was not all procedures but also substantive rules. The Tenures bears more kinship to present-day legal literature in what it sought to do, what it did, and how it did it, than any other law-book written before the last half of the seventeenth century, Coke's work included. If this seems to disparage Lord Coke, remember that he knew better than all other post- medieval jurists the excellence of Littleton. His encomium of the Tenures admits of no demurrer or plea in bar:

this book is the ornament of the common law, and the most perfect and abso­lute work that ever was written in any human science; and in another place, that which I affirmed and took upon me to maintain against all opposites whatso­ever, that it is a work of as absolute perfection in its kind, and as free from error, as any book that I have known to be written of any humane learning, shall to the diligent and observing reader of these Institutes be made manifest.³⁷

Made manifest it is.