## Facts

- The Crown filed an information of intrusion against Heydon for entering lands in Devon formerly held by the College of Ottery.
- The warden and canons of Ottery had granted Ware (father and son) a copyhold interest “for their lives, at the will of the lord, according to the custom of the manor.”
- While that copyhold interest was still in existence, the warden and canons leased the same land to Heydon for an 80-year term, reserving rents found to be the ancient and customary rents.
- Ottery later surrendered its possessions to King Henry VIII during the dissolution of religious houses.
- The dispute turned on construction of 31 Hen. VIII c. 13, which (in relevant part) voided certain recent leases by ecclesiastical houses where an existing estate or interest for life or years was already in being.
- A jury returned a special verdict setting out the estates, the lease, the surrender, and the statutory provisions; the Exchequer decided the legal effect.

## Issues

1. Whether a copyhold held “for lives, at the will of the lord according to the custom of the manor” is an “estate or interest for life” within 31 Hen. VIII c. 13.
2. What method of statutory interpretation should govern when general statutory words may permit evasions inconsistent with the statute’s remedial purpose.

## Decision

- The Exchequer entered judgment for the Crown.
- The court held that the Ware copyhold “for lives” fell within the statute’s phrase “estate or interest for life.”
- Because that life interest existed when Ottery leased the same land to Heydon for years, Heydon’s lease was void under 31 Hen. VIII c. 13.
- Heydon’s entry under a void lease constituted an intrusion.

## Legal Principles

- In construing a statute, courts should consider: (1) the common law before the Act, (2) the mischief or defect not addressed by the common law, (3) the remedy provided by Parliament, and (4) the reason for that remedy.
- Courts should interpret statutes to suppress the mischief and advance the remedy, preventing evasive constructions that would defeat legislative purpose.
- Copyhold interests may fall within general statutory language when inclusion is necessary to effectuate a remedial statute and does not improperly disturb customary tenure relations.
- A copyhold “for lives,” though described as held at the lord’s will, can be treated in substance as a life estate for purposes of statutory restrictions on conflicting leases.

## Conclusion

The court treated a customary copyhold for lives as an “estate for life” within 31 Hen. VIII c. 13 and therefore voided a later long-term lease granted over the same land, articulating a purposive framework for statutory interpretation focused on curing the mischief the statute targeted.


Heydon’s Case, 76 Eng. Rep. 637 (Exch. 1584)