Prologue

On 10 April 1668, a petition was presented to three justices sitting in Cliffords Inn, London. This was ‘the Court of Judicature appointed to determine differences between landlords and tenants as to rebuilding after the Great Fire’, better known now as simply the Fire Court.Footnote ¹ The petition stated that the late William Kerby, the ‘owner’ of two houses in Thames Street, had devised them to his daughter Elizabeth for life and then to his grand-daughter, Grace Pope. William's widow, Grace, had been entitled to a third ‘share’ in the premises.Footnote ² Grace and Elizabeth Kerby, the widowed mother and her life tenant daughter, together had leased one of the houses to Benjamin Mat[t]hews, with two-thirds of the rent going to Elizabeth, the daughter, and one third to Grace, the mother. The other house had been leased to Ruth Hennings, a widow, on the same terms. Ruth had then married a Mr Dunsden and the (deceased) owner's daughter Elizabeth had married John Pindar. Grace Kerby then died and Messrs. Matthews and Dunsden (‘being poor’) surrendered their leases. John Pindar petitioned the Court with his wife Elizabeth and was ordered to rebuild with the encouragement of a term of 40 years taking effect on the death of Elizabeth and paying a reduced rent to Grace Pope. If John's wife survived him she was to enjoy a life interest in the rebuilt house. Grace Pope and her future husband were to execute the new lease.

This is a typical Fire Court case. As the summary shows, the rehearsal of the petition affords the historian ready access to a wealth of information about the way Londoners in 1666 occupied, owned, bought/sold and bequeathed their property. Readers will identify their own opportunities for research. This article highlights how petitions like John Pindar's can shed light on two aspects of the London property ‘market’ before and after the Fire. There are undoubtedly many other aspects to explore. The article is primarily concerned with its chosen themes but it also tries to demonstrate what else lies in wait for those ready to tease out other threads from the Fire Court evidence.

The urban property system

Studies of the development of towns and cities have tended to focus on the dynamic not the static. In other words, they have examined physical growth (and decline) and the ‘built environment’ which resulted from the ebb and flow of economic and social change. With honourable exceptions,Footnote ³ urban historians have not concerned themselves with the property system, i.e. the mechanics of the acquisition, management and disposal of houses, shops, workshops and warehouses. There are good reasons for this neglect, if neglect it is. Property development – especially wholesale new build – is important and exciting. Who could not be attracted to what John Evelyn called ‘a mad intemperance’?Footnote ⁴ And the archival resources are plentiful, offering scope for fine-grained research combined with graphic reconstruction. But if the records demonstrating the way property market worked are more difficult and the subject-matter less immediately attractive, the rewards are nonetheless very significant.

Understanding the urban property system helps us answer a number of important questions. Who owned the land and buildings in the towns and cities? How diverse was that ownership and to the extent that it was concentrated in ‘institutions’ and wealthy families how did they manage their property and realize its value? How many ‘ordinary’ owners were there? Did they use their property to live in and/or trade from? Or was it rather a source of income and if so from whom? Does property-holding show how wives/widows and children were provided for? And so on.

The Fire Court evidence

It was the belief that these were important questions to which we did not yet know the answers that drew the writer to the Fire Court Decrees. There are over 1,560 cases in eight-and-‘a-bit’ volumes, a little under half of them (volumes A–D) calendared by Philip Jones in 1966 and 1970.Footnote ⁵ Jones left volume E ready for publication and the writer has completed volume F and will seek to arrange for those volumes to be published shortly. He is at work on the remainder (volumes G–I). The Decrees have their own intrinsic interest, not least for what they tell us about the rebuilding process. In some respects, the 1966 and 1970 publications were supplementary to the post-Fire records (showing site surveys and listing the fees for foundations) which Jones and T.F. Reddaway edited for the London Topographical Society in 1962–67.Footnote ⁶ The Decrees, however, do more than record the incentives for rebuilding; as Jones himself indicated, they also provide an excellent way of examining the workings of the London property market before and after the Fire, by lifting the lid, so to speak, on it.Footnote ⁷ As the Pindar example shows, the petitions to the Court, in asking for an order to determine who should rebuild and on what terms, needed to rehearse the salient details of the current (and occasionally previous) leases to try to secure the ‘right’ decision by the Court. Clearly, they were persuasive not objective but there was ample opportunity for the defendants – invariably supported by specialist lawyers – to contest the petitioners’ case. The process of checking the petitions against the leases themselves is not easy and has hardly begun, but for now the rebuttable presumption is that the Decrees provide reliable data. There is certainly no other practical means of piecing together the information they contain for such a large number of properties on a consistent basis. (A very rough calculation suggests that the cases account for a fifth of the 13,000 houses believed to have been destroyed in the Fire.)Footnote ⁸

It is of course possible that the cases brought to the Fire Court are not representative. Court cases rarely deal with run-of-the-mill facts. No doubt complexity did encourage petitions, but that was not the main factor. Petitions were generally brought by parties whose landlords or tenants simply could not or would not contribute to the cost of rebuilding. A landlord might want to ‘buy off’ a tenant to facilitate a general reconstruction and a tenant might be anxious to escape an unwanted lease. At the root of many if not most of the petitions to the Fire Court was a disagreement over money not law. And in those many cases involving ‘institutions’ (such as St Paul’s), the reason had nothing to do with the nature of the dispute. There was simply a legal restriction which only the Fire Court could remove. It seems fair to conclude that the cases we are analysing here offer insights into property-dealing which – certainly in the absence of any comparably accessible and rich source – deserve close consideration.

Various themes await exploration. This article considers two of the key legal issues arising from the Decrees. One of the reasons why the urban property market has not yet received full attention is that the law and practice which under-pinned that market are not properly understood. In part, it must be acknowledged, this is because the documents are dry and the technicalities forbidding. There are no swift rewards and plenty of pitfalls. As important, however, is the belief that these are issues to be left to the legal historians. But while there are excellent histories of property law, based on humbling erudition, they do not in fact answer the questions ‘ordinary’ historians pose. Legal historians naturally focus on the development of the law and there is a lineal, baton-passing nature to their accounts which militates against describing how the law worked at any one time and in practice. Indeed, there is always the possibility – indeed probability – that legal theory and practice diverged. No one today would rely on statutory provisions and reports of Court cases to demonstrate legal reality. Parliament sets rules for practitioners to comply with (or avoid) and judges either apply those rules or (where parliament has not intervened) use previous cases to deal with the often unusual facts before them.

Of greater use for the urban historian than the landmark cases are the contemporary manuals published to guide property owners and the professionals advising them. There were precedents for lawyers (i.e. conveyancers and scriveners), though chiefly directed towards those dealing with landed estates. And there was valuation guidance for surveyors, including those faced with disputes over rebuilding City property after the Fire. The difficulty with these publications is assessing how frequently they were used. Some certainly ran into several editions, but their influence and representativeness is hard to gauge. For example, no evidence has yet been found that the elaborate calculations for determining terms for post-Fire leases were actually used to settle any disputes in, or agreements endorsed by, the Fire Court.Footnote ⁹

By contrast, the Decrees afford a way of investigating the seventeenth-century London property market which both avoids the lure of the esoteric (the line of precedents) and tests the impact of the self-styled guides (the apparently popular manuals). Of course, without an appreciation of the legal theory – explored in the Courts and analysed by legal historians – there are aspects of the Decrees (tenure, inheritance, assignment and so on) which could not be understood. And were it not for the manuals it would often be impossible (absent accompanying correspondence perhaps) to work out the motive and priorities of landowners and occupiers as they made their decisions and deals. So these other sources are important; but they need to be read alongside a substantial body of evidence showing how urban property was owned, used and traded. That is why the Fire Court Decrees are so valuable.

To demonstrate that value, this article looks at two legal issues, both of interest to, and indeed contested by, lawyers and historians alike.

Trusts and settlements

The first analysis concerns trusts and settlements. The concept of separating the legal and ‘beneficial’ (or real) ownership of property originally took the form of ‘feoffees to uses’ (the nominal owner) holding property on behalf of the ‘cestui que use’ (the beneficiary). The protection afforded to what were termed the equitable rights of the beneficiaries presented a challenge to previous controls over the transfer of land and the king through parliament intervened. Historians have long debated the significance and impact of the Statutes of Uses (1535) and Wills (1540), both designed to protect the crown's revenue derived from feudal dues. An array of devices to avoid payment were brought before the Courts with frequently unpredicted results. The arcane twists and turns can be followed in the legal histories where a reader's bewilderment at the techniques is matched by admiration of the explanations of them. The tangle, not to say chaos, which resulted from this three-way tussle between statute, case law and legal practice did not resolve itself in 1660 when feudal dues were abolished. Lawyers still had to worry about creating – or not creating – an effective (‘executed’) use and it was not until Lord Nottingham's reform in the early 1680s that there was confidence that what was essentially still a use – but was by then called a trust – was enforceable even if not executed under the 1535 Act. The legal historical debate continues, with Neil Jones now building on the earlier work of Brian Simpson and others.Footnote ¹⁰

Economic and social historians have also interested themselves in trusts and settlements, focusing particularly on those ‘strict settlements’, which by confining the descent of family property to the eldest male were often used to keep landed estates intact from the Restoration onwards. This too is a contested – or at least uncertain – area, in part concerning the intentions, application and features of the strict settlement itself but in part also because the research so far has concentrated on those families for whom readily identifiable settlement records survive. There has certainly been a focus on landed estates and county settlements.Footnote ¹¹ Amy Louise Erickson carried out a pioneering study of ‘ordinary’ women's property ownership in sixteenth- and seventeenth-century England, based largely on probate records; but though it provides a valuable counterpoint to the estate/family-based accounts of John Habakkuk and Lloyd Bonfield, it says only a little about urban property and very little about London and other large towns.Footnote ¹²

A review therefore of the trusts and settlements as featured in the Fire Court Decrees is of interest in various ways. Volume C contains 194 cases heard between April 1667 and June 1668 and save for a not-unusual cluster of cases concerning the same landlord (in this case the bishop of London),Footnote ¹³ it is likely to yield representative results. Jones’ calendar of it has been examined for any references to trusts and settlements. A deliberately wide view of those terms has been taken, to make sure that the analysis reflects reality and not just theory. Any degree of separation of legal ownership or title from actual ownership or enjoyment of a property potentially qualifies for these purposes.Footnote ¹⁴ Mention has already been made of the reliability of the petitions. The Court seems to have been particularly anxious to ensure that all those interested in a trust or settlement, however remotely, were represented and protected. Petitions therefore created careful, almost artificial, distinctions between settlors and beneficiaries, parents and children; and minors always appeared with or were given legal ‘guardians’. There is thus good reason to believe that the details in the Decrees are an accurate summary.

Among the 194 cases, there are references in at least 53 (possibly 59) of them to trusts or settlements.Footnote ¹⁵ That approaching a third of the cases featured such arrangements is itself significant. It supports Erickson's important finding that trusts or settlements were not simply the device of the landed elite. As the following break down will show, the 53 (59) cases cover a variety of arrangements but all – in lay terms – involve the separation of ownership and benefit.

Who created them? Here it is important to recognize that most urban property, especially in London, was held on leases. The ‘structure’ described here applied for most of the sixteenth and seventeenth centuries, at least within the Square Mile. (The major change, involving the widespread use of building leases, occurred after the Restoration and in the burgeoning West End.) Much of the land was owned (using somewhat anachronistic terminology) freehold by ‘institutions’ – the City Corporation, the Livery Companies, the church(es) and so on – and they granted long leases and left their lessees to build, re-build and manage the property. Private freeholders, looking to their land-holdings to provide an income and not a home or workplace, often did the same. Those taking ‘long’ leases (say, 41 years or more) from the freeholders were thus effectively owners of their properties and in turn granted shorter (say, 21-year) sub-leases to those who actually occupied the houses/shops. The distinction between owners and occupiers is not always straightforward and produces the occasional inconsistency (because it is influenced by the rehearsal of lessor and lessee information), but it needs to be acknowledged to make sense of the Fire Court Decrees evidence. (There is also further (but separate) work to be done on occupation, with the aid of other evidence, including the Hearth Tax returns.)

In up to 48 of the 53 (59) cases, trusts or settlements were created by ‘owners’ and in these 48 nearly half (23 or 24) may – but only may – have involved freeholders (recognizing the significant difficulties with the analysis and indeed with the term itself).Footnote ¹⁶ If on the same (imperfect) basis of calculation there were 65 (perhaps 68) freehold ‘owners’ in volume C,Footnote ¹⁷ it would appear that freeholders were proportionately rather more likely to create trusts than those with leasehold – even long leasehold – interests. This accords with common-sense: only those with a long-term interest would trouble with a legal mechanism to provide for future needs. It is also predictable that trusts and settlements often involved more than one property. This was true in a half (27–9) of the cases and in over a quarter (15) two or more properties were involved.Footnote ¹⁸ Overall, between 85 and 90 of the cases concerned multiple properties.Footnote ¹⁹ This shows that there were many who ‘owned’ more than one house who did not turn to a trust to exploit or preserve the value of their land. We can nevertheless say that if there were reasons for doing so (financial or personal) then trusts and settlements attracted those who had urban ‘estates’ rather than single plots.

Why were these trusts and settlements created? Somewhere between 23 and 33 of the 55 were for wives and children/grandchildren.Footnote ²⁰ Many of the remainder (19–23) were primarily for children and grandchildren. And, interestingly, in a majority of these cases (13) provision was made for daughters and/or grand-daughters.Footnote ²¹ Overall, in up to 20 – and certainly in 13 – cases the trusts and settlements provided for daughters (as well as and other family members),Footnote ²² chiefly through remainders (i.e. future entitlements to property). The main concern, therefore, was simply to ensure that loved ones – especially female loved ones – would be financially protected in the future. The concern of wealthier, landed settlors to protect the family estate is difficult to trace. It is noteworthy that there are only five references to entails, that classic device for at least attempting to prevent future disposals.Footnote ²³

When were trusts and settlements created? This is not always clear but most of them appear to have arisen on death. In other words, the property owner bequeathed his urban estate to his family for two or more generations. This is true in 21, possibly 27, of the cases.Footnote ²⁴ In rather more cases – somewhere between 23 and 29 – it is reasonably clear that the trust or settlement was created during the owner's lifetime and in 9 or 10 of these the trust or settlement related to marriage.Footnote ²⁵

Many of the arrangements were simple affairs, deserving (informally, perhaps anachronistically) to be called mere trusts. In somewhat fewer than half (25–7) of the cases is the term settlement warranted or did the arrangements otherwise involve a degree of legal sophistication. In seven of these cases there were marriage settlements of some kind.Footnote ²⁶ None of the settlements qualified as a strict settlement.

Given the simplicity of these arrangements, and the relatively modest value of even the multiple properties involved, it is not surprising that there is no evidence that the trusts and settlements were contested or even refashioned by agreement. It may or may not be significant that only nine or ten cases reveal possible instances of life interests or remainders being ‘traded’ (i.e. sold in some which way) have been identified.Footnote ²⁷

Here, then, we have a picture which differs markedly from those settlements made outside London on which scholarly attention has so far been focused (as a result of Habakkuk's and Bonfield's work). Property owners did (and quite frequently) create trusts and settlements but on a small scale, on straightforward terms, intending simply to look after their wives and other loved ones who were clearly regarded as being entitled to a proper share of the husband’s, the father's or the family's wealth when the settlor was dead. And they did so when their legal status permitted. For those who merely occupied urban property, there was no incentive to make such provision. Apart from benefiting from the remainder of the lease, the next generation – or at least the generation after that – would have to fend for itself.Footnote ²⁸

Women

The second analysis concerns women. As with trusts and settlements, this is a contested area but for different reasons. Gender historians have interested themselves closely in women's property rights, keen to see how those rights (or rather the absence of them) affected women's financial and domestic circumstances. The studies strikingly demonstrate the different approaches of legal and social historians. The former, notably Susan Staves, have focused on the law itself and the process of reform.Footnote ²⁹ They do not hide their distaste for the ‘feme covert’ and ‘sole’ rules, which had the effect of denying women a full legal personality during marriage. Their property rights were essentially suspended.Footnote ³⁰ Only as widows did women become ‘sole’ again, able to deal with their property as they saw fit. Social historians, by contrast, have looked not so much at law as practice, concerned with women's experience of the rules and not with the attempts to change them. Amy Louise Erickson again led the way, pointing out how women and indeed their fathers and husbands worked within or round the law to mitigate its effects and make practical provision for the wives’, widows’ and daughters’ needs. Her work, as already noted, does not look at urban contexts and so her findings need to be tested by studies like this one; but Erickson fulfils a valuable role in encouraging us to dig deep into first-hand experience of the law and let the results speak for themselves.Footnote ³¹

We start with women as ‘owners’, bearing in mind the artificiality of the term and the occasionally arbitrary distinctions which have to be made between ‘ownership’ and ‘occupation’.Footnote ³² Women featured as owners in 71 out of the 194 cases.Footnote ³³ This was somewhat more than half of the 116–19 cases where men were owners.Footnote ³⁴ (‘Institutions’, such as the City Corporation, Livery Companies and the church largely accounted for the balance.) There are at least 37 (possibly 43) cases where women were ‘sole’ owners,Footnote ³⁵ compared with up to 103 men.Footnote ³⁶ No doubt a demographic analysis, based on life expectancy, male/female ratios, re-marriage rates and so on, might show whether these are predictable figures; and the fact that for many women ‘ownership’ meant a life interest ‘only’ (as explained below) makes the comparison with men less than straightforward. Nevertheless, the totals certainly demonstrate that women had a significant role to play as owners of London property.

Many of these ‘owners’ were widows: there were perhaps 54 and certainly 49 cases (among the 71) in which this was true. And it will not be a surprise, given the findings of the previous section of this article, that in at least 24 and possibly 27 of these 50 or so cases the widow had a life interest.Footnote ³⁷ That meant that the widow was not able freely to dispose of the property but it is clear that even with only a life interest widows found willing lessees, and in order to encourage rebuilding the Fire Court often added a substantial term of years to take effect on the widow's death. In this respect, therefore, even when constrained in this way, widows were important ‘players’ in the London property market. And, of course, re-marriage added to widows’ importance in this respect.

It is also important to appreciate that the ‘feme covert’ rule did not mean that women played no part in property dealings. Of course, there may have been some pragmatism at work here: why take the risk of failing to ‘join in’ a female owner? But this could in fact have been simply the proper application of the rule: women may have (temporarily) lost their legal independence but they still needed to be contracting or consenting parties. Whatever the reason, petitioners or their counsel not infrequently treated women owners as important participants in legal negotiations. In 20 cases, wives featured as ‘joint’ owners with their husbands.Footnote ³⁸ Certainly, when taken with the occasional cases where there were women who were sole owners and not recorded as widows,Footnote ³⁹ and recognizing the life interests of the ‘widow owners’, the ‘story’ of property ownership is more positive, less demeaning than the law-based studies suggest.

What now of occupation? There were 54, possibly 57, Decrees (among the 194) in which one or more women featured as ‘occupiers’.Footnote ⁴⁰ This is a sizeable proportion but given that almost all the other occupiers were men (‘institutions’ of course being owners), female occupiers were a significantly smaller category than female owners. This will not surprise. We have just seen that women ‘owners’ were often life tenants and earlier that trusts and settlements were regular devices for property ownership (as opposed to occupation).

Who then were these female occupiers? There are only 13 cases where women are found taking leases in their own names and one of those cases involved a husband too.Footnote ⁴¹ Many more acquired their leases, either as devisees or executrices. The distinction between the two roles is often unclear:Footnote ⁴² the figures reveal at least 16 but up to 36 cases involving devisees. In a substantial number of cases (between 13 and 19), these actual or possible devisees were executrices or administratrices.Footnote ⁴³ The view that women usually acquired what lawyers call their ‘occupational leases’ from their deceased husbands is supported by the fact that most of the women occupiers were widows. In only eight to ten cases were there no references to widowhood and six of these involved daughters.Footnote ⁴⁴

We therefore see women occupying leasehold property in London as successors to their late husbands. Many of the lease transactions traced in the Fire Court Decrees were by and with men, taking new leases, assigning existing leases or granting sub-leases; but since the properties were usually, in whole or part, in household occupation it was natural for the husband, when he died, to arrange for the lease to vest in his wife. A widow could usually rely on her husband's will. The number of ‘occupation’ cases where there is no mention of widowhood falls even lower (to four) if only devisee cases are counted.Footnote ⁴⁵

This leads to a separate comment on women as devisees and executrices (and as already mentioned no distinction is made between the two categories). A comparison of owners and occupiers is again interesting. In the first place, there were proportionately somewhat fewer devisees/executrices among the owners: in up to 35 of the 71 cases as opposed to 40 out of 54 (57).Footnote ⁴⁶ It can be surmised that this was because, as we have seen, many of the ‘owned’ properties were placed in or were already subject to trusts or settlements. Secondly, in only a maximum of 8 ‘owner’ cases are women described as executrices (or equivalent), as against a possible 19 ‘occupier’ cases.Footnote ⁴⁷ The references are haphazard (‘inheritance’, ‘passed to’ and so on) and thus could hide an intervening executorship or administration process, but the difference is still noteworthy. Lessee-occupiers – or in legal language occupational lessees – passed their interests to their wives and used them as executrices more frequently than owners. This was surely not because owners were less concerned with their wives’ welfare but because they were establishing trusts and settlements instead. Indeed, the overall frequency with which male propertied testators entrusted their estates to their wives is significant and worthy of systematic investigation, outside the Decrees. It is further indication of those familial attachments and concerns explored in this article. And there is value in further work, building on Henry Horwitz's interesting study, on the so-called Custom of London, which entitled widows to at least a third share of their husbands’ personal estates. The Custom may have been formally in decline but probably only because (as in Grace Kerby's case) it was being replaced by specific bequests.Footnote ⁴⁸

Another way of looking at the role of women in London property is to analyse how they acquired or disposed of their properties, either alone or with others. There were 46 or more cases where women sold property or (more frequently) granted leases as ‘owners’. In 24 cases they did so jointly with their husbands or family members.Footnote ⁴⁹ Far fewer ‘occupiers’ (10–12 cases) did so (mostly by assignment),Footnote ⁵⁰ presumably because there was less need or scope for assigning (with some years of a short-ish lease already expired). Acquiring ‘ownership’ is rarely recorded in the Decrees, in part no doubt because it was not a relevant fact,Footnote ⁵¹ but probably also because it was simply an infrequent occurrence. A maximum of nine cases have been found, with three of them uncertain (and with some signs of family arrangements) and one dealing with the same circumstances.Footnote ⁵² And most ‘acquisitions’ were of property interests not leases. Only one possible such woman assignee has been found in the sample.Footnote ⁵³ There were also very few assignees among the women ‘occupiers’.Footnote ⁵⁴ Occupational leases were regularly assigned (in 40 or so of the cases),Footnote ⁵⁵ but a woman rarely took such a lease herself. A widow ‘occupier’, it might be presumed, did not want, or have the need, to take on a ‘new’ lease.

All this is not to deny the reality of ‘feme covert’. A wife's loss of legal independence is regularly reflected in the Decrees. There are up to 30 cases where a husband is found, in effect, assuming the interest of his wife or joining her in granting, taking or surrendering leases and so forth. In eight or nine of these cases, a husband became the rebuilding tenant, acquiring long(er) term and (usually) a reduced rent.Footnote ⁵⁶ And in at least one instance the Court required that a future husband should join in the new lease.Footnote ⁵⁷ The point is not so much that the ‘feme covert’ rule – properly understood – was not observed (though it may be that historians need to be more alert to the availability of equitable relief)Footnote ⁵⁸ but rather that its observance does not signify what modern observers can easily assume it signified. It did not displace and was not incompatible with genuine, practical concern for marital and familial love and support.

Future opportunities

The results of the analysis presented in this article have been plain enough and do not require repetition or reinforcement. Let us instead go back to the Pindars’ petition, summarized at the outset, to make plain how the necessarily abstract information which forms the body of this article is drawn from very real, personal circumstances. In the Pindar case, we find all the key themes we have been exploring: a family settlement (daughter and grand-daughter); provision for the surviving wife; a corresponding ‘split’ of rents from the two properties; a widow and her unmarried daughter together granting leases to secure themselves an income; a widow taking a lease but then her new husband surrendering it himself; the daughter's new husband getting a rebuilding lease beyond his wife's life interest but with his wife being entitled to enjoy that life interest if she survived him; and the grand-daughter granting that rebuilding lease herself, with any future husband joining in. Multum in parvo?

It will be clear that there is much more work to be done on the Decrees – all 1,560 of them – before confident conclusions can be made about technical points of law and practice. The current work on the remaining un-calendared Decrees will undoubtedly assist. There is, however, also a need to supplement, systematically, the findings analysed here with evidence from those other records produced not just in response to the Fire but also the ‘steady state’ tax and other listings of the time. The 1660s are uncommonly rich in this respect, particularly given the availability of the Hearth Tax returns. Data is already available on-line. An edition of the 1666 return is due out shortly. Elsewhere, the author has suggested how London in 1666 could be ‘recreated’ with the aid of this data.Footnote ⁵⁹ Jacob Field has already shown what can be done in his sensitive study of Londoners’ Fire ‘experience’.Footnote ⁶⁰ Within this multi-sourced statistical structure, researchers can then trace individuals through their wills and other more qualitative material to answer some of the questions which have been posed but not fully answered here. What does pre- and post-Fire property ownership and occupation tell us about the family relationships, the economic power of women, the (growing?) role of widows and so on? Exciting opportunities await historians prepared to familiarize themselves with the legal and property systems – and then count!